Lance R. and Elaine C. LeFleur - Page 7

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            Blount, returned from retirement to serve as interim president of                         
            the company.                                                                              

                  The Settlement Negotiations and Agreement                                           
                  On November 25, 1991, Reak met with petitioner to discuss                           
            the possibility of a settlement (the November 25 meeting).  Reak                          
            had no interest in partially settling the litigation with                                 
            petitioner and was interested only in a settlement that resolved                          
            all outstanding issues.  After the November 25 meeting, Reak                              
            tendered a written settlement offer to petitioner dated November                          
            27, 1991 (the November 27 offer).  Petitioner did not accept the                          
            November 27 offer.                                                                        
                  Jim Alexander (Alexander), defendant's counsel, was first                           
            advised of petitioner's response to the November 27 offer by a                            
            telephone call from Bolton the next day, November 28, 1991                                
            (Thanksgiving Day).  On Thanksgiving Day, extensive discussions                           
            took place between Bolton and Alexander.  By the end of the day,                          
            Alexander and Bolton reached an agreement in principle for a                              
            basis of settlement of the lawsuit (the agreement in principle),                          
            and Alexander reported to his clients that the matter had been                            
            resolved.  On Saturday, November 30, 1991, Alexander faxed a                              
            draft settlement agreement to Bolton.                                                     
                  On December 2, 1991, Alexander met with L. Daniel Morris                            
            (Morris), Blount's vice president of legal services, and                                  

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