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www.courthousenews.com

Case 1:09-cv-06338

Document 1

Filed 10/09/2009

Page 7 of 11

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

offense," namely:

Dishonesty, lying,

...falsely reporting any

act

Disloyalty, including disparaging, maligning, or defaming the reputation of

the

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).

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