Leslie R. Foster and Mattie J. Foster, et al. - Page 3

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               Respondent's motion is based on a stipulation of facts and             
          attached exhibits which are incorporated herein by this                     
               At the time the petitions were filed, Leslie and Mattie                
          Foster resided in San Antonio, Texas; Charles and Carole Payne              
          resided in Kissimmee, Florida; and Wayne and Marie Smith resided            
          in Loveland, Colorado.                                                      
               Prior to and during a portion of 1992, petitioners Leslie,             
          Mattie, Charles, and Wayne were employed by the United Services             
          Automobile Association (USAA).  In 1992, each of them                       
          (hereinafter referred to as the participants) became eligible to            
          participate in USAA's Special Retirement Offer (retirement                  
          program).  To participate in the retirement program, which                  
          included the receipt of a single, lump-sum payment, each of the             
          participants was required to sign a Special Retirement Offer                
          Election Notification and General Release.  The release                     
          agreements are identical but for the parties and the amounts of             
          the payments.                                                               
               The agreements provide in part as follows:                             
               [Name] acknowledges that this payment is solely in exchange            
               for the promises in his/her General Release and is not                 
               normally available under company policy to employees who               
               resign.  [Name] further acknowledges that such payment does            
               not constitute an admission by the Released Parties of                 
               liability or of violation of any applicable law or                     

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