- 6 -
* * * * * * *
7. It is understood and agreed that this compromise
settlement includes the compromise settlement of any and all
legal, evidentiary, discovery, and document production
issues regarding Claim No. 624 * * *. The parties further
agree and understand that neither State Farm nor * * *
[petitioner] will bring any motions, either individually or
as part of the class, relative to such Claim No. 624 issues
* * *
13. * * * The approximate full value
of * * *
[petitioner's] claim under the Consent Decree damage formula
as of February 1, 1992, is $510,254.00, 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
$190,539.00, which is approximately 37% of the
estimated full Consent Decree value of her claim, to
release her claims against State Farm. * * *
* * * * * * *
c. Incentive Cash for Acceptance Rate Above 90%:
The Incentive Cash will be $1,800.00 per claimant for
each full percentage point by which the Acceptance Rate
* * * exceeds 90%. * * *
* * * * * * *
e. Attorney's Fees: The payments State
Farm is offering to * * * [petitioner] include her
attorneys' fees and costs * * *. That is, * * *
[petitioner] will have to pay her attorneys' fees * * *
out of the payment State Farm makes to her. * * *
On April 15, 1992, pursuant to the terms of the settlement, State
Farm issued petitioner and her attorneys a check in the amount of
$206,739, which included an "incentive cash" payment of $16,200
(State Farm payment). Petitioner's attorneys retained legal fees
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011