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In 1988, while the District Court's decisions were under
review in the Court of Appeals for the Ninth Circuit,5 the law
firm which represented the class representatives in Kraszewski
contacted petitioner and advised her of the class action. As a
result, petitioner filed a Final Claim Form in the class action.6
Petitioner maintained in the Final Claim Form that she had been
sexually discriminated against in that she was deterred from
applying for a trainee sales agent position with State Farm
during the period December 15, 1975, through May 31, 1976.
Petitioner also challenged the January 1, 1977, promotion of
State Farm trainee agent James M. Mitchell.
On January 30, 1992, petitioner and State Farm entered into
an agreement entitled "Settlement Agreement and General Release",
which provided in relevant part:
The approximate full value of [petitioner's] * * *
claim under the Consent Decree damage formula as of
February 1, 1992, is $715,931.00, which represents back
pay as a State Farm agent accrued from the year of the
challenged appointment to February 1, 1992, plus six
months of front pay from that date forward.
b. Settlement Cash at 87.5% Acceptance Rate:
State Farm offers [petitioner] * * * Settlement Cash of
$267,343.00, which is approximately 37% of the
5The Kraszewski appeal was decided favorably to the
plaintiffs. See Kraszewski v. State Farm Gen. Ins. Co., 912 F.2d
1182 (9th Cir. 1990).
6Petitioner did not file a complaint against State Farm at
any time.
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