Law Offices of DENNIS HOLAHAN 2049 Century Park East, Suite 3180 Los Angeles, California

November 5, 2010 VIA FEDERAL EXPRESS AND FACSIMILE TRANSMISSION

Edward Sabin, COO Eileen O'Neill, President

The Learning Channel (TLC) 1 Discovery PlaceSilver Spring, MD 20910

David Zaslav CEOPeter Liguori, COODiscovery Comm., LLCOne Discovery PlSilver Spring, MD 20910Fax: 240 662 1845

Mark Burnett, President Mark Burnett Productions640 N Sepulveda Blvd Los Angeles, CA 90049 Fax: 310 903 5566

RE:"Sarah Palin’s Alaska" // Invasion of Privacy of Joe McGinniss

Dear Ms. O’Neill, Mr. Sabin, Mr. Zaslav, Mr. Ligouri and Mr. Burnett:

This law firm represents Joe McGinniss. It has come to our attention that the first episode (titled "Mamma Grizzly") of the above referenced television show, scheduled to air on Sunday, November 14, 2010 at 9:00 PM on TLC, contains unauthorized videotaped images of Mr. McGinniss which were obtained without his knowledge or consent. In addition, you have already placed a video clip containing this image of Mr. McGinniss on your website and it has been picked up and reproduced by the Huffington Post and many other online sites.

Mr. McGinniss was not asked if any production crew could videotape him as he read a book on the secluded deck of the house he was living in at that time. He was not aware that any camera crew was in fact videotaping him. Mr. McGinniss had a reasonable expectation of privacy under those circumstances. The mere taking of the video therefore gives rise to an actionable claim for invasion of his privacy. The publication of the video on your website and in the television show constitutes an additional wrong – the unauthorized use of the likeness of Mr. McGinniss. Finally, the manner in which Ms. Palin describes Mr. McGinniss in the episode is defamatory: Mr. McGinniss has never invaded the Palins’ privacy, contrary to the many statements made by Ms. Palin and her husband, both prior to this television production, and now repeated in the episode referenced above.

DEMAND IS HEREBY MADE upon each of you that all images of Mr. McGinniss be removed from any television show produced by any of you, and removed from any website controlled or operated by any of you. If you do not do so, Mr. McGinniss will be forced to pursue all his available remedies. Please confirm in writing by November 12, 2010, to this office that you will remove these images.

Mr. McGinniss reserves all of his rights.

If you would like to discuss any of the above, contact this office.

Very truly yours,

Dennis Holahan