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requested to be reinstated, given the obvious, and now scientifically confirmed, falsity of the
allegation that had led to her dismissaL. Harpo and Winfrey refused. They were as impervious to
the absence of
misconduct by Ms. GehrIs as they were to Gooch's actual misconduct. Indeed,
the latter now included additional "offenses which are so intolerable that they wil result in
immediate, severe disciplinary action up to and including immediate termination on the first
...falsely reporting any
Disloyalty, including disparaging, maligning, or defaming the reputation of
Company or its employees
20. The refusal to reinstate Ms. GehrIs cannot be justified based upon Winfrey's and
Harpo's purported concern about "inappropriate intimate behavior" on a Jet flght, for that charge
was demonstrably untrue, to say nothing of
Gooch's conduct on a 2008 flght, which met with no
reprisal, let alone termination. On that flght, as the Jet was traveling from the Canar Islands to
Chicago, Gooch accepted King's offer to share the Jet's double bed with her. Winfrey knew of,
but did nothing about, this highly intimate and unprofessional flight conduct by Gooch.
Jurisdiction and Venue
21. Jurisdiction over the federal causes of action below is proper under 28 U.S.C.
§ 1332, because Plaintiff and Defendants are citizens of different states and the matter in
controversy exceeds the sum or value of $75,000, exclusive of interest and costs. Jurisdiction
over the remaining counts is proper under pendant claim and supplemental jurisdiction pursuant
to 28 U.S.C. § 1367(a). Venue is proper in this
judicial district pursuant to 28 U.S.C. §1391(b).