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IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN

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					              Case 1:09-cv-06338                        Document 1       Filed 10/09/2009        Page 1 of 11



   IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF
                       ILLINOIS, EASTERN DIVISION

 CORRE GEHRLS,                                                           )
                                                                         )
                                     Plaintiff,                          )
                                                                         )
                         vs.                                             )
                                                                         )
 MYRON GOOCH, KIRBY BUMPUS, and                                          )         Plaintiff demands trial by jur
 HARPO, INC.,                                                            )
                                                                         )
                                    Defendants.                          )

                                                                 COMPLAINT

            Plaintiff, by her attorneys, for her Complaint against defendants, states:

                                                    Parties and Persons of Interest

            1. Plaintiff, Corrine GehrIs, is a resident and citizen of                   New Hampshire.

            2. Harpo, Inc., ("Haro"), is an Ilinois corporation having its principal place of


business in Cook County, Ilinois.

            3. Oprah Winfrey ("Winfrey"), is a resident of Cook County, Ilinois. Plaintiff is

informed and believes that Winfrey is a principal and owner of
                                                                                     Haro. At all relevant times,

Winfrey acted within the actual and apparent scope of                        her authority at Haro.

            4. Plaintiff is informed and believes that Defendant, Kirby Bumpus ("Bumpus"), is a


citizen and resident of Connecticut. Bumpus is the daughter of Gayle King ("King"). She is also

Winfrey's Goddaughter. King is a close personal associate of
                                                                                    Winfrey and is the Editor at Large

of 0 Magazine, a magazine owned by Winfrey and Harpo.


           5. Defendant, Myron Gooch ("Gooch"), is a citizen and resident of Cook County,

Ilinois. At all relevant times, Gooch was an agent of Harpo, acting within the actual and
              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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        Case 1:09-cv-06338                        Document 1   Filed 10/09/2009    Page 3 of 11




provided with his own rental car versus sharing the car rented by the rest of the flght crew.

        10. On virtually all occasions, Gooch's demands concerning his duties and otherwise

were acceded to by Pansing or GehrIs. Notwithstanding these accommodations, Gooch's

complaints about and resistance to his duties persisted, thereby perpetuating and exacerbating the

logistical and morale issues for the Jet's flght crew that he had created.

        11. Winfrey and Haro were made aware of                   the ongoing problems created by Gooch's

insubordinate attitude and demands, which were reported to Elizabeth Moore, the intermediary

through whom Winfrey insisted Pansing report any problems. Winfrey allowed Gooch, however,

to report to her directly when it came to complaints about Mr. Pansing and Ms. GehrIs.

       12. Winfrey ignored Gooch's misconduct, which would not have been tolerated of


any other Jet employee. Indeed, Haro's employee handbook is clear. Its "Attendance and

Tardiness" Policy provides:

       "We hired you because we need you to be at work when scheduled. We depend
       on you to report to work regularly and on time each day, and to remain on the job
       during working time. When someone is absent, late for work, or leaves early,
       someone else must fill in and do extra work."

Harpo's "General Rules" likewise provide:

       "the following examples of offenses which wil result in disciplinary action under our
       progressive discipline procedure. In certain situations, depending on the severity and/or
       frequency of the offense, the first offense wil result in immediate discharge."

                  "Failing to follow prescribed work rules or policies."

                  "Uncooperative attitude."

                  "Unauthorized absence from work."

                  "Failure to work assigned...overtime work."



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         Case 1:09-cv-06338             Document 1      Filed 10/09/2009       Page 4 of 11



 Haro's handbook further provides

        "the following examples of offenses which are so intolerable that they wil result in
        immediate, severe disciplinary action up to and including immediate termination on the
        first offense":

                   "Failure to complete...work assignment."

                   "Insubordination, including refusing or failing to obey a reasonable work request
                   or instruction of a supervisor."

                   "Failure to return from a leave of absence or vacation when notified to do so or
                   upon expiration of  the leave or vacation."

        13. The only component of          Gooch's conduct that might have been objectively

acceptable was his food selection for the Jet, a responsibility of flght attendants. Winfrey

commented on at least one occasion that "white folks don't know what southern food should

taste like." Disparate food selection concerns, however, were resolved when Pansing

implemented the simple curative of having Ms. GehrIs procure for Winfrey the same food as

Gooch as well as three chefs that were to Winfrey's culinary satisfaction. That, however, did

nothing to address the Gooch's persistent resistance to his flght attendant duties, and the

ongoing strife caused by his conduct.

        14. Ultimately, Gooch decided to have Ms. GehrIs and Mr. Pansing terminated. As


set forth more fully below, this would be facilitated by virtue of Gooch's unique, unilateral

access to Winfrey and his consequent ability to control Harpo' s decisionmaking concerning

fellow employees.

       15. Gooch recognized, however, that their termination could not be based on

objective job pedormance, because Pansing's and GehrIs' historical performance had been

without incident. Neither had ever been insubordinate, refused duties, or in any way guilty of


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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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               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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              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).




                                                                           7
                Case 1:09-cv-06338                     Document 1                  Filed 10/09/2009                 Page 8 of 11




                                                        Count I
                                       Defamation of Gehris by Bumpus and Gooch

             1 - 21. As paragraphs 1 through 21 of Count I, Plaintiff realleges and incorporates by

reference paragraphs 1 - 21 of the Complaint.

            22. Bumpus' and Gooch's false statements about Plaintiffs conduct on June 14,2009

and the necessary implications therefrom knowingly and falsely impeached Ms. Gehrls' integrity,

virtue, human decency, and reputation and thereby were designed to lower Ms. GehrIs in the

estimation of         her employer as well as the community.

            23. In addition to being defamatory per quod, Bumpus' and Gooch's statements


constituted defamation per se, because they prejudiced Plaintiff in her occupation and profession

and because they accused her of                     adultery and fornication with Pansing, a maried man. Gooch's

knowingly false statements about Plaintiff were made with the direct intention to injure Plaintiff

or a reckless disregard of her rights, and they were further made the intention to benefit Gooch.

            24. As a direct and proximate consequence of                               Bumpus' conduct, Plaintiff              has been

injured in an amount in excess of $75,000. Additionally, Ms. GehrIs has suffered severe

embarassment, humiliation, and emotional har.


            WHEREFORE, for the foregoing reasons, Plaintiff requests judgment in her favor and

against Bumpus and Gooch, jointly and severally, for actual damages in an amount in excess of

$75,000, plus costs, attorneys fees, punitive damages, and such other relief                                        that is just and proper.

                                                  Count II
                             Defamation by Harpo Based Upon Respondeat Superior

           1 - 24. As paragraphs 1 through 24 of Count II, Plaintiff realleges and incorporates by

reference paragraphs 1 - 24 of Count 1.


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             Case 1:09-cv-06338                           Document 1      Filed 10/09/2009                   Page 9 of 11



            25. At all relevant times, Gooch was Haro's agent, acting within the actual and


apparent scope of            his authority.

            26. As a consequence, Harpo is vicariously liable for Gooch's false and defamatory

statements, which Harpo additionally ratified by its conduct including, inter alia, its failure to

reinstate Plaintiff, its failure to seasonably terminate Gooch, and its failure to adhere to the

provisions of the employee handbook concerning all of these matters.

            27. As a direct and proximate consequence of                        Harpo's conduct, Plaintiff           has been

injured in an amount in excess of $75,000. Additionally, Ms. GehrIs has suffered severe

embarrassment, humiliation, and emotional harm.

            WHEREFORE, for the foregoing reasons, Plaintiff requests judgment in her favor and

against Haro for actual damages in an amount in excess of$75,000, plus costs, attorneys fees,

punitive damages, and such other relief                      that is just and proper.

                                                          Count III
                                            Interference With Gehris' Prospective
                                          Economic Advantage by Bumpus and Gooch

            1 - 27. As paragraphs 1 through 27 of                  Count II, Plaintiffrealleges and incorporates by


reference paragraphs 1 - 27 of Count II.

           28. At all relevant times, Ms. GehrIs had a reasonable expectation of prospective


economic advantage through her employment with Harpo of which Defendants Bumpus and

Gooch were aware.

           29. As described above, Bumpus and Gooch wilfully, maliciously and unjustifiably

interfered with Ms. GehrIs' prospective economic advantage.

           30. As a direct and proximate consequence of                        Bumpus' and Gooch's conduct, Ms.


                                                                     9
          Case 1:09-cv-06338                           Document 1      Filed 10/09/2009       Page 10 of 11

.;




      Gehris has been injured in an amount in excess of $75,000.

                WHREFORE, for the foregoing reasons, Plaintiff requests judgment in her favor and

      agait Bumpus and Gooch, jointly and severally, for actual damages in an amount in excess of

      $75,000, plus costs, attorneys fees, punitive damages, and such other relief tht is just and proper.

                                                                Count iv
           Intenerence With Gehris' Prospective Economic Advantage By Harpo Based Upon
                                         Respondeat Superior

                1 - 30. As paragrphs 1 through 30 of             Count IV, Plaitiffrealleges and incorporates by


     reference paragrphs 1 - 30 of               the Count m.

               31. As a direct and proximate consequence of                 Gooch's misconduct, for which Haro

     is vicaously liable and which Haro ratified, Plaintiff has been injured in an amount in excess

     of $75,000.

               WHREFORE, for the foregoing reasons, Plaintiff requests judgment in her favor and

     against Haro for actual damages il! an amount in excess of$75,000, plus costs, attorneys fees,

     puntive damages, and such other relief that is just and proper.




     Staes & Scalan, P.C.




                                                                  10
Case 1:09-cv-06338   Document 1    Filed 10/09/2009   Page 11 of 11




                              11
        Case 1:09-cv-06338                       Document 1-2                   Filed 10/09/2009            Page 1 of 6




                             Southwest Polygraph Services, Inc.
                                                         Originally Established in i 979


 Lawrence S. Beaumont
 Director


 July 25, 2009

Andrew Staes
Attorney-at-Law



                        PsvchophvsioIo2icaI Detection of Deception Examination

Subject:                                        Corrine L. GehrIs

Date of Birth:

Date of Examination:                            July 24, 2009

Place of Examination:                           Southwest Polygraph Services, Inc. (Chicago)


Identifvin2 Information and Reason For Examination:

Ms. Corrine L. GehrIs is a 39 year-old female who was referred by Andrew Staes,
Attorney at Law, for a Forensic Psychophysiological Detection of
                                                                                                       Deception (PDD)
examination. The purose of                     the PDD examination was to verify the truthfulness of
                                                                                                                         Ms.
GehrIs' statements regarding her denial of                         having sexual contact with fellow employee
Terr Pansing.


Ms. GehrIs stated she is currently residing at
                                                                                    . She
appeared to be in good physical condition. She was dressed in clean casual clothing, and
appeared to be slightly apprehensive regarding the examination. She presented as being
alert and well oriented to person, place and time. She did not appear to be under the
influence of any drug or ilegal substance. She stated that she had not taken any
medications in the last 24 hours. She appeared to be of above average intelligence, and
no deficits in attention span or concentration were noted. Her comprehension of simple
commands was unimpaired, and she exhibited no memory impairment relative to the
alleged sexual conduct.




                                                       ¡g          EXHIBIT
                                                       f;
                                                       ~
                                                        ii
                                                       ~
                                                       ..           L
    Case 1:09-cv-06338                   Document 1-2                     Filed 10/09/2009    Page 2 of 6



Corrine L. Gehrls
Page two.

Based on my observations of Ms. GehrIs at the time of the examination, it was my expert
opinion that she was a suitable candidate for a psychophysiological detection of
deception examination.

Procedure

The following procedure was utilized prior to and during the PDD examination:

       1. A review of the reports in this case indicated that Ms. GehrIs is currently a
           flight attendant working for Oprah Winfrey. It was alleged that the Ms.
           GehrIs had sexual contact on a Harpo, Inc., jet with pilot Terr Pansing. It
          was further reported that both individuals deny such sexual contact.

      2. Prior to the examination, Ms. GehrIs read and signed a consent form assuring
          all concerned she was taking the examination voluntarily. The consent form
          further released Southwest Polygraph Services, Inc., and Andrew Staes,
          Attorney, of any liability that may result from the taking of                      the examination.
          Finally, the consent form expressly allows the examiner to furnish the results
          of the examination and any statements made by Ms. GehrIs to Attorney
          Andrew Staes. The original form wil be kept in the laboratory file in this
          case.

      3. A thorough pre-test interview was conducted with Ms. GehrIs. During this
          interview, Ms. Gehrls denied that she ever had any sexual contact with Terr
          Pansing. When asked why there had been an allegation of such conduct, she
          stated she was suspicious about the allegation but did not know for sure why it
          was lodged. She adamantly denied ever having any sexual contact with Terry
          Pansing.
     Case 1:09-cv-06338             Document 1-2       Filed 10/09/2009   Page 3 of 6



 Corrine L. Gehrls
 Page three

         4. All of   the PDD examination questions were reviewed with Ms. GehrIs. She
              stated that she fully understood each question. It is this examiner's
              professional opinion that Ms. GehrIs understood each of the questions.

         5. The Reid Control Question technique was utilized during the examination.
             The examination was conducted on a Stoelting polygraph which
             simultaneously records changes in blood pressure levels and pulse rates,
             changes in rate and depth of respiration, and changes in galvanic skin
             response. The following relevant questions were asked on three separate
             charts:
                        QUESTION                                      RESPONSE
                     1. Have you had sexual contact with
                        Terry Pansing?                               No

                     2. On June 14,2009, did you have sexual
                        contact with Terry Pansing?                  No

                     3. While on a Harpo jet, did you have
                        sexual contact with Terry Pansing?           No

       There were no significant emotional responses usually indicative of deception
noted when Ms. Gehrls answered each of the questions listed above.


CONCLUSION:

       It is my professional opinion, based on the lack of reactions to the formulated test
questions that the examinee was truthful when she answered each of the questions listed
above.

IS/Lawrence S. Beaumont
Lawrence S. Beaumont
     Case 1:09-cv-06338         Document 1-2               Filed 10/09/2009   Page 4 of 6




                   Southwest Polygraph Services, Inc.
                                     Originally Established in 1979


Lawrence S. Beaumont
Director


July 24, 2009

Andrew Staes
Attorney-at-Law




                 PsychophysioIo2icaI Detection of Deception Examination

Subject:                       Terry B. Pansing

Date of Birth:

Date of Examination:           July 23,2008

Place of Examination:          Southwest Polygraph Services, Inc. (Chicago)


Identifvin2 Information and Reason For Examination:

Mr. Terry B. Pansing is a 57 year-old male who was referred by Andrew Staes, Attorney
at Law, for a Forensic Psychophysiological Detection of          Deception (PDD) examination.
The purpose of           the PDD examination was to verify the truthfulness ofMr. Pansing's
statements regarding his denial of having sexual contact with fellow employee Corrine
GehrIs.

Mr. Pansing stated he curently resides
                                                        . Mr. Pansing is currently married
and has one child. He appeared to be in good physical condition. He was dressed in clean
casual clothing, and appeared to be slightly apprehensive regarding the examination. He
presented as being alert and well oriented to person, place and time. He did not appear to
be under the influence of any drug or ilegal substance. He stated that he had not taken
any prescribed medication in the last 24 hours with the exception of medication a thyroid
problem. He appeared to be of above average intelligence, and no deficits in attention
span or concentration were noted. His comprehension of simple commands was
unimpaired, and he exhibited no memory impairment relative to the alleged sexual
contact.
    Case 1:09-cv-06338         Document 1-2        Filed 10/09/2009      Page 5 of 6



Terr B. Pansing
Page two

Based on my observations of Mr. Pansing at the time of the examination, it was my
expert opinion that he was a suitable candidate for a psychophysiological detection of
deception examination.

Procedure

The following procedure was utilized prior to and during the PDD examination:

       1. A review of the referral report in this case indicated that Mr. Pansing is
          currently a pilot for Oprah Winfrey. It has been alleged he had sexual contact
           with flight attendant Corrine GehrIs while on board a Haro, Inc. jet. It was
           furher reported both individuals deny having any such sexual contact.

      2. Prior to the examination, Mr. Pansing read and signed a consent form assuring
           all concerned he was taking the examination voluntarily. The consent form
           further released Southwest Polygraph Services, Inc., and Attorney Andrew
           Staes, of any liability that may result from the taking of the examination.
           Finally, the consent form expressly allows the examiner to furnish the results
           of the examination and any statements made by Mr. Pansing to Attorney
           Andrew Staes. The original form wil be kept in the laboratory file in this
           case.

      3. A thorough pre-test interview was conducted with Mr. Pansing. During this
           interview, Mr. Pansing denied having any sexual contact with flght attendant
           Corrine GehrIs. He stated he had no idea why the allegation was made. He
           adamantly denied ever having sexual contact with Corrine GehrIs.
    Case 1:09-cv-06338            Document 1-2       Filed 10/09/2009     Page 6 of 6




              Terry B. Pansing
              Page three

        4. All of   the PDD examination questions were reviewed with Mr. Pansing. He
             stated that he fully understood each question. It is this examiner's
             professional opinion that Mr. Pansing understood each of the questions.

        5. The Reid Control Question technique was utilized during the examination.
            The examination was conducted on a Stoelting polygraph which
            simultaneously records changes in blood pressure levels and pulse rates,
            changes in rate and depth of respiration, and changes in galvanic skin
            response. The following relevant questions were asked on three separate
             chars:
                           QUESTION                                  RESPONSE

                    1. Have you had sexual contact with
                       Corrine?                                      No

                    2. On June 14,2009, did you have sexual
                       contact with Corrine?                         No

                    3. While working on a Harpo jet, did you
                       have sexual contact with Corrine?             No

       There were no significant emotional responses usually indicative of deception
noted when Mr. Pansing answered each of the questions listed above.


CONCLUSION:

       It is my professional opinion, based on the lack of reactions to the formulated test
questions that the examinee was truthful when he answered each of the questions listed
above.

IS/Lawrence S. Beaumont
Lawrence S. Beaumont
                                 Case 1:09-cv-06338                          Document 2                      Filed 10/09/2009                        Page 1 of 1

                                                                      CIVIL COVER SHEET
The civil cover sheet and the infonation contained herein neither replace nor supplement the filing and serice of pleadings or other papers as required by
law, except as provided by local rules of cour. This fon isrequired for the use of                          the Clerk of Cour for the purpose of initiating the civil docket sheet. (SEE
INSlRUCTIONS ON THE REVERSE OF THE FORM.)

    (a) PLAINTIFFS DEFENDANTS

    (b) County of       Residece of   First Listed Plaintiff Rockingham                                           County of Residece of      First Listed Defendant Cook
                                  (EXCEPT IN u.s. PLAITIFF CASES)                                                                         (IN u.s. PLAITIFF CASES ONLY)
                                                                                                                      NOTE: IN LAND CONDEMNATION CASES, USE THE LOATION OF THE
                                                                                                                                LAN INOLVED.

    ( c) Atorey's (Firm Name, Addess, and Telephone Numbe)                                                         Attoreys (If   Known)
            Andrew Staes
            STAES & SCALLAN
            111 W. Washington, Suite #1631
            Chicago, Ilinois 60602
II. BASIS OF JURISDICTION (Place an "X" in One Box Ony)                                          III. CITIZENSHIP OF PRINCIPAL P ARTIES(Place an "X" in One Box for Plaintiff

o 1 U.S. Goverent                         o 3 Federal Question
                                                                                                                                 PTF DEF PTF DEF
                                                                                                       (For Diversity Cases Only) an One Box for Defendat)
                                                                                                     Citizen of This      State 0 (2 1 Incorpted or Principal Place 0 4 ~4
            Plaintifl                               (U.S. Goverent Not a Part)                                                              of Business In This State


o 2 U.S. Goverent                         (1 4 Diversity                                             Citizen of Another State      lX 2      02       Incorpated and Principal Place           0   5        05
            Defennt                                 (Indicate Citizenship ofParties                                                                       of   Business In Another State
                                                    in Item II)
                                                                                                     Citizen or Subject of a       03 03              Foreign Nation                           0   6        06
                                                                                                         Forei"" Countr
IV. NATURE OF SUIT                           (Place an "X" in One Box Onlv)
         CONTCT                                                    TORTS                             FORFITURE/PENAL TY                       BANUPTCY                         OTHER STATUTES
0 110 In                       PERONAL INJURY                            PERSONAL INJURY             0    610 Agrcutur                 0    422 Appeal   28 USC 158        o 40 State Reapportionment
0 120 Mare                  0 310 Ailane                             0   362 Persona Injur-          0    620 Other Foo & Drg                                              o 410Antitrst
0 130 Miller Act            0 315 Airplane Product                          Med. Malpracice          0    625 Drg Related Seizue       0    423 Withdrawa                  o 430 Bans and Bang
0 140 Negotiable Intrnt            Liability                         0   365 Persona Injur -                  of Prpert 21 USC 881             28 USC 157                  o 450 Commere/ICC Ratesíetc.
0 150 Recover of Overpyment ex 320 Assault, Libel &                          Prodct Liability        0    630 Liqur Laws                                                   o 460 Deporttion
       & EnfOrcement of Judgent                Slande                0   368 Asbestos Personal       0    64 RR & Truck                    PROPERTY RIGHTS                 o 470 Racketeer Influence and
0   151 Medicar Act                   0    330 Federal Employers'            Injur Product           0    650 Airline Regs.
                                                                                                                                       0    820 Copyrghts
                                                                                                                                                                                  Corrt Orization
0   152 Recover ofDefulied                     Liability                     Liability               0    660 Ocpational
                                                                                                                                       0    830 Patent
                                                                                                                                                                           o 480 Consumer Credit
        Student Loan (exc!. vet.)     0    340 Mare                   PERSONAL PROPERTI'                       SafetyíHealth
                                                                                                                                       0                                   o 490 Cable/Satellite TV
0   153 Recovery of Overpyment        0    345 Marne Product         0   370 Oter Fraud              0    690 Other
                                                                                                                                            840 Tradeniar
                                                                                                                                                                           o 810 Selectve Service
        of V etemo' s Benefits                 Liability             0   371 Truth in Lendig                                                                               o 850 Securty/Coinodity/Exch.
0   160 Stockholders' Suits           0    350 Motor Vehicle         0   380 Other Personal                     LABOR                      SOCIA SECURITY                  o 875 Customer Cliallenge
0   190 Oter Contr                    0    355 Motor Vehicle                 Propert Damge
                                                                                                     0    710 Fair Labor Stadads       0                                          12 USC 3410
0   195 Contrt Product liability               ProUi:t Liability     0   385 Property Diiage
                                                                                                                                       0
                                                                                                                                            861 IDA (I395fI
                                                                                                                                                                           o 891 Agcultual Acts
0   196 Franchise                     0    360 Oter Persnallnj.             Prodct Liability
                                                                                                    0
                                                                                                             Act
                                                                                                          720 LlIbor/Mgmi. Relations   0
                                                                                                                                            862 Black Lung (923)
                                                                                                                                            863 DIWCiDIWW(405(g))
                                                                                                                                                                           o 892 Econontc Stabilization Act

     REAL     PROPERTY                     CIVIL RIGHTS              PRISONER PETmONS                                                  0    864 ssm Title ),:VI
                                                                                                                                                                           o 893 Environmental Matters

                                                                                                    0     730 LaboríMgmi.Reprtil1g     0    865 RSI (405(g))
                                                                                                                                                                           o 894 Energy Allocation Act

0 210 Lad Condenmtion                 0    441 Voting                0   510 Motioii to Vacate                & Disclosur Act
                                                                                                                                                                              895 Fredo ofInforion Act
0 220 Foreclosure                     0    442 Emplo)ment                    Sentence               0     740 Ralway Lar Act               FEDERAL TAX SUITS               o 90 Appeal of    Fee

0 230 Rent Lease & Ejectmnt           0    443 Housin                    Habeas Corpus:
                                                                                                                                                                                  Detenation Uuder
0 240 Tons to Lad                             Accommodtioii          0   530 Genera                 0     790 Otber Lar Litigaon
                                                                                                                                       o 870 Taxes (U.s. Plaitiff
                                                                                                                                               or Detèndat)
                                                                                                                                                                                  Eqil Access to Justice
                                                                                                                                                                           o 950 Coiititutionality of
0 245 Toll Pr Liability               0    44 Welfa                  0   535 Death Penaty
0 290 All Oter Real Prrt              0    445 ADA-Employment        0   540 Mandaus & Oter         0     791 Empl. Rei. Inc.
                                                                                                                                                                                   State States
                                      0    44 ADA - Oter             0   550 Civil Rights                     Secuity Act
                                                                                                                                       o 871 IRS-Thrd Par                  o 890 Oter Statutory Actions

                                      0    44 Oter Ci\~1 Rights      0   555 Prson Condtion
                                                                                                                                            26 USC 7609


V. ORIGIN                  (PLACE AN "X" IN ONE BOX ONLY)                                                                                                                                  Appeal to District
                                                                                                                                Tranfered from Judge from
ex 1 Origil              o 2 Removed from                  03       Remded from               o 4 Reinstated or 0 5 another distrct 0 6 Multidistrict 0 7 Magistrate
        Procn                      State CourtA Hate Court               Reo cned (speifY) Liti                                                                   ation Judgment
VI. CAUSE OF ACTION (Enter u.s. Civil Statute under which you are filing and "Tite VI. PREVIOUS BANKRUPTCY MATTERS (For                                                                            nature   of
                                            a bref sttement of cause.)                                                suit 422 and 423, enterthe case numbe and judge for any assiated
                                                                                                                      banptcy matter perviously adjudicated by a judge of this Court. Use a
         Defamation                                                                                                   searate attchment if necssry)


VI. REQUESTED IN                            o CHECK IF THIS IS A CLASS ACTION                         DEMANS $75,000                              CHECK YES only if demanded in complaint:
     COMPLANT:                                 UNDER F.R.C.P. 23                                                                                  JURY DEM.A"f: àles 0 No
                              cK is not a refiling of a previously dismissed action.
IX. TWs case




                                                                      ~~
                              o       is a ref"iIng of case number                                        , previously dismissed by Judge
DATE

    October 8, 2009

				
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