John P. and Carolyn L. Raney - Page 4

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          not hired.  On August 1, 1989, petitioner executed a Final Claim            
          Form in the class action suit, challenging the February 1, 1976,            
          appointment of Donald B. Buchanan.3  Petitioner subsequently                
          became a claimant in the class action suit against State Farm.              
          In November of 1991, petitioner and State Farm entered into a               
          "Settlement Agreement and General Release" (settlement                      
          agreement), which provided in relevant part:                                
                    1.   For and in consideration of the sum of $75,000.00,           
               less all required payroll deductions applicable to the                 
               period of Trainee Agency, if any, Carolyn L. Raney * * *               
               does hereby completely release and forever discharge * * *             
               [State Farm] * * * from any claim * * * or liability of any            
               and every kind based on any federal, state, or local law,              
               statute, or regulation (hereinafter "Claim") which arose               
               prior to the execution of this Settlement Agreement and                
               General Release, and which were raised, or could have been             
               raised in the above-captioned case, as well as any and all             
               Claims arising out of or relating to any alleged                       
               discriminatory, improper, or unlawful act or omission of               
               State Farm in connection with any term or condition of                 
               employment or independent contractor status or the process             
               of securing or attempting to secure employee or independent            
               contractor status including, without limitation,                       
               recruitment, selection, hiring, job assignment, job                    
               transfer, training, promotion, or termination, which she may           
               have filed or caused to be filed * * * prior to the                    
               execution of this Settlement Agreement and General Release.            
                              *    *    *    *    *    *    *                         

          3    Before petitioner filed the Final Claim Form, on or around             
          Jan. 13, 1988, a Consent Decree Regarding Monetary Relief,                  
          Instatement Relief, and Notice (consent decree) was filed in the            
          class action suit in which the parties to the class action suit,            
          inter alia, reached an agreement as to the remedy phase of the              
          litigation.  Section A of exhibit 9 to the consent decree                   
          provides, at par. IV.E.2.c., that "Negotiated Settlements are not           
          governed by the calculation rules for any of the types of damages           
          available under this [Consent] Decree."  Petitioner alleges that            
          she had never seen the consent decree until she received a copy             
          from respondent.                                                            




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