Darrell D. and Jane E. Moran - Page 3

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          Seattle, Washington.  From petitioner’s point of view, the higher           
          level position in Bozeman was petitioner’s old position with a              
          new title.  Petitioner was offered the alternative of a position            
          in Seattle or a sales position in Montana, and the acceptance of            
          either position would require the relocation of petitioner’s                
          family.  The positions offered to petitioner would not have been            
          considered promotions.                                                      
               Petitioner had little warning preceding these events, and he           
          was profoundly affected by them.  When petitioner was advised               
          that he was not going to be offered the new position in Bozeman,            
          he asked for an explanation, but no explanation was provided,               
          further upsetting petitioner.  Petitioner had heard that other              
          employees had been offered "attractive buy-outs".                           
               Petitioner sought severance pay from Holnam under its policy           
          and procedure manual, but he was refused on the grounds that                
          severance pay was only available for involuntary separations.               
          Thereafter, petitioner was offered a choice between a severance             
          package or continuing in a particular job position, but he could            
          not come to terms with company representatives.  Petitioner would           
          have been satisfied with a reasonable severance package, but the            
          company representatives did not provide what he regarded as                 
          reasonable alternatives.  Subsequently, petitioner hired Michael            
          J. San Souci, an attorney, to seek redress from Holnam.  Attorney           
          San Souci sent a nine-page letter, dated October 29, 1993, to               
          Alex Pappas, vice president of Holnam's Human Resource                      



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