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Case 1:09-cv-06338

Document 1

Filed 10/09/2009

Page 2 of 11

apparent scope of

his authority.

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


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