Tommy Jean Hayes - Page 3

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          discouraged in their efforts to obtain the entry level sales                
          position."  One year later, the District Court ordered hearings             
          to determine individual liability and damages.                              
               The District Court referred the Lawsuit to Judge Eugene                
          Lynch as mediator.  After September 24, 1991, under Judge Lynch,            
          State Farm and class action counsel started negotiations to                 
          attempt to settle the claims of individual litigants.  As a                 
          result of the negotiations, a Master Settlement Agreement was               
          reached on January 17, 1992.  The agreement provided a formula              
          for the computation of damages that State Farm would offer to               
          each claimant, who was free to accept or reject the offer.                  
               On or around January 17, 1992, the District Court provided             
          petitioner with a document entitled "Communication of State                 
          Farm's Settlement Offer", accompanied by a "Summary of Terms of             
          State Farm's Settlement Offer", which had been reviewed and                 
          approved by Judge Lynch.  State Farm offered petitioner $204,523            
          to release her claims against State Farm.  The offer was                    
          conditioned upon acceptance of State Farm's offers by at least              
          87.5 percent of the 821 final claimants represented by class                
          action counsel to whom offers of that type had been extended.               
          The $204,523 represented 37 percent of the full Consent Decree              
          value of petitioner's claim.                                                
               The offer also provided that petitioner would share in any             
          "incentive cash" payable.  This was an additional amount computed           
          under a formula based upon the number of percentage points by               




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