Robert J. and Anne L. Wilson - Page 7

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          State's total offer was $87,466, which the State rounded to an              
          offer of $87,500.                                                           
               On July 14, 1989, in response to the foregoing offer,                  
          petitioner's attorney made the following counteroffer:                      
               If you will add the $3,500 additional compromise ahead of              
               the pre-judgment interest and figure the pre-judgment                  
               interest at 10% for nine years and two months, I will                  
               recommend the settlement, on condition that this amount of             
               money is on the table.                                                 
          On July 28, 1989, the AAG responded to the foregoing                        
          letter as follows:                                                          
               I am writing in reply to your letter of July 14, 1989.  As             
               you know, on January 7, 1988 we posted in Court an                     
               additional $13,996.  Therefore, I believe the additional 1-            
               1/2 years of interest at 10% per annum would be on $17,756             
               as opposed to the larger amount.  That amount of interest              
               comes to $2,663.40.                                                    
               As to the other point you made, I am not agreeable to paying           
               interest on the $3,500 additional compromise.  That is                 
               simply a "sweetener" to close this case.                               
               However, adding the $2,663 to the $87,466 brings us to                 
               $90,129.  If that is acceptable to your client, I will seek            
               authority from our Baltimore Office to do a Consent                    
               In a further attempt to settle the case without a trial, the           
          AAG and petitioner's attorney met for a settlement conference on            
          September 20, 1989.  In connection with the conference, the                 
          parties completed settlement conference statements.  In the                 
          settlement conference statement completed by the AAG, the State             
          indicated that it would settle the matter for "$63,652 + pre-               
          judgment interest of $26,477 = $90,129.00 total."  In the                   
          settlement conference statement completed by petitioner's                   

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