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Respondent's motion is based on a stipulation of facts and
attached exhibits which are incorporated herein by this
reference.
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
regulation.
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