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started to accrue damages such as lost wages I suggest
you consider the following offer of settlement. This
is not to be construed as an admission of liability but
merely as an offer of settlement.
* * *
A lump sum payment to me amounting to 8 months
salary and benefits, ignoring deductions which would
normally be made under payroll conditions, should be
paid to me forthwith. In my opinion a court or jury
would find at least one years salary would be in order
as damages if it is found that General Counsel breached
an employment agreement to employ me.
Shortly after his receipt of the March 1, 1989, letters,
Anacker instructed Kahn to prepare a memorandum detailing the
events surrounding petitioner's termination. A copy of this
memorandum was introduced at trial. Bearing the date March 2,
1989, the memorandum essentially sets forth Kahn's belief that
petitioner had produced substandard work while at ABMI. Kahn
states therein that petitioner was given several opportunities to
improve his performance, but failed to do so.
At some point, soon after Kahn prepared his memorandum,
Anacker met with petitioner. During this meeting, the two
apparently reached an understanding regarding petitioner's
grievances. Thereafter, Anacker had a proposed settlement
agreement executed on behalf of ABMI and sent to petitioner. In
relevant part, the proposed agreement provided petitioner a lump-
sum payment in the amount of $20,000 to satisfy any and all
claims, known or unknown, against ABMI.
Subsequent to his receipt of the proposed settlement
agreement, petitioner sent two additional personal and
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