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apparent scope of
6. Terr Pansing is and was at all relevant times a resident of
Kane County, Ilinois.
Mr. Pansing is married. Mr. Pansing's disputes with Harpo have been resolved.
7. In about May 29,2007, Corrine GehrIs was hired by Winfrey and Harpo to serve
as a flight attendant on Winfrey's private jet. ("the Jet"). At all relevant times, the other flight
attendant for the Jet, whose duties alternated with Ms. GehrIs, was Gooch.
8. In about May 29,2004, Mr. Pansing was hired by Winfrey and Haro to serve as a
pilot for the Jet. Mr. Pansing ultimately was elevated to the position of Chief Pilot. The Jet had
three other pilots, each of whom, like Ms. GehrIs and Gooch, served under the immediate
supervision of Mr. Pansing, whose authority included setting the work schedules and
assignments of the pilots and flght attendants.
9. For an extended period of
time, not less than several months, dissension arose and
persisted among the Jet's flght crew by virtue of
Gooch's resistance to the flight schedule set by
Mr. Pansing. When work schedules and assignments were not to Gooch's liking, he either would
refuse to adhere to them or insist to Mr. Pansing or Ms. GehrIs that Ms. GehrIs switch
assignments with him or otherwise take his assignment. Among the reasons Gooch offered in
resistance to assigned flght duty was his extraordinary belief that he should not be expected to
work after being on vacation. Other times, Gooch required schedules to be reworked so that he
could be specially flown home to Chicago to attend to his cats. Gooch's resistance to flght
schedules that were not to his liking included threatening to call in "sick." Beyond his
scheduling demands, Gooch frequently insisted upon being lodged in better hotels than the rest of
the flght crew on out of town trips. This accommodation additionally required Gooch to be