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1989, the Saperstein firm provided petitioner with a document
entitled "Overview of Final Claimant Selection Process." On
September 1, 1989, Mrs. Easter filed a final claim form with
State Farm.
In January 1988, the Saperstein firm, representing the
plaintiffs, and State Farm entered into a Consent Decree
Regarding Monetary Relief, Instatement Relief, and Notice
(hereinafter referred to as the Consent Decree) in order to
facilitate resolution of the remaining claims. The Consent
Decree limited damages available to class members to: "(1) back
pay; (2) front pay; (3) prejudgment interest; (4) postjudgment
interest; and (5) reasonable attorneys [sic] fees and costs."
The Consent Decree also provides the manner in which the
available damages will be calculated.
On January 17, 1992, District Court Judge Eugene Lynch sent
a document entitled "Communication of State Farm's Settlement
Offer" to all claimants, including Mrs. Easter, that had attached
various documents describing State Farm's settlement offer.
Included in the documents attached was the Master Settlement
Agreement dated January 17, 1992, entered into by the Saperstein
firm and State Farm's attorneys.
On February 12, 1992, petitioner signed a Settlement
Agreement and General Release. In exchange for $135,000 plus
additional payments of up to $18,000 (conditioned upon the
percentage of claimants who settled), petitioner agreed to
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