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Case 1:09-cv-06338

Document 1

Filed 10/09/2009

Page 5 of 11

malfeasance or misfeasance in the performance of

their duties. Indeed, Pansing's historical

critiques not only had been devoid of criticism, they had been exemplar, consistent with his

having been promoted to chief pilot. Gehrls' historic job performance was likewise free of

blemish, save for Winfrey's momentary criticism about "white folks(')" ignorance concerning

southern cuisine. Gooch's job performance and attitudes, by contrast, were of a nature that no

objective employer would tolerate, much less prefer over that of competent, responsible

employees. And notwithstanding his recalcitrance, Gooch received both a substantial bonus and

raise in 2008. By contrast, the compliant and dutiful GehrIs received neither.

16. In order to implement his decision to have Pansing and Gehrls terminated, Gooch

devised a scheme by which they would be terminated predicated upon a false basis and which

would be facilitated by his influence with Winfrey and hence Harpo. Pursuant to that scheme, at

some point prior to July 5, 2009, Gooch approached Bumpus and prevailed upon her to join him

in the making of a false and defamatory report about Pansing and GehrIs, namely that they had

engaged in inappropriate intimate conduct during a Harpo flght. Bumpus agreed, and thereafter

on about July 3,2009, Gooch and Bumpus falsely told Winfrey and Harpo that on the June 14,

2009 Harpo flght, the passengers on which included Winfrey and Bumpus, Pansing and GehrIs

had been observed having inappropriate intimate conduct outside the cockpit of the plane. At no

time during that flght, or at any other time, had any such conduct occurred. Indeed, after the

June 14 flght, Haro rewarded GehrIs for her historic exemplary work efforts with a paid, two

week Mediterranean cruise.

17. There then followed, however, Bumpus' and Gooch's knowingly false charge,

which resulted in Winfrey and Harpo terminating Pansing and GehrIs on about July 7, 2009 and


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