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Case 1:09-cv-06338

Document 1

Filed 10/09/2009

Page 6 of 11

causing to be created and placed in Ms. Gehrls' personnel fie a report that supplied the purported

basis for termination, namely that they had engaged in "inappropriate intimate behavior" in the

galley during the Jet's June 14,2009 flght. No such conduct occurred, as was explained to

Winfrey, who either conducted no investigation into the facially untenable charge or if one was

conducted, it was ofthe most perfunctory nature. Nor were Harpo's "progressive discipline

procedures" applied..

18. Indeed, Bumpus' and Gooch's report was obviously false and known to be false

by Winfrey. The time pegged by Winfrey for the occurrence of

the purported "inappropriate

intimate behavior" made the charge inherently implausible, because at that time, the Jet was on

the ground refueling. During that time, the new flght crew was replacing the prior flght crew.

Because the plane was grounded, the curtain between the galley and the cockpit was open,

thereby exposing any "inappropriate" conduct to the view not only of the cabin but of the cockpit

as well. It further would have been openly exposed to the oncoming crew. No one would engage

in such conduct in plain view of one's employer, fellow employees, and flght passengers. Nor

could such conduct have been competently reported during the actual flght, because Bumpus,

Winfrey, and the other passengers of

the June 14 crew (with the exception of

the security officer)

slept throughout the flight following their ingestion of sleeping pils. The precise prescription( s)

is presently unkown and can only be learned in discovery.

19. On August 6, 2009, Winfrey and Haro were provided with the attached results of

a polygraph examination administered by a respected former Assistant United States Attorney,

which reflected that Pansing's and GehrIs' denials of

having engaged in any inappropriate,

intimate conduct on June 14, 2009-or ever-were truthful. On that date, GehrIs accordingly


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