Walter E. Hess and Helen L. Hess - Page 6

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          (5) $12,594,636 for conversion of commissions, (6) $1,756,147 for           
          equity in sales territory, and (7) $4,108,158 for constructive              
          discharge.  Petitioner alleged that his damages for constructive            
          discharge were:  (1) $2,352,011 in commissions owed him for                 
          Prudential, AT&T, the New York Giants, and NBA contracts and                
          (2) lost equity payments of $1,756,147 from not being allowed to            
          retire under Balfour's equity program.  Petitioner did not assert           
          any claim for damages for a physical or emotional injury                    
          purportedly caused by Balfour.                                              
               Balfour and petitioner both moved for summary judgment on              
          petitioner's claims of lost equity, statutory wage violations,              
          and conversion, and petitioner also moved for summary judgment on           
          all of Balfour's counterclaims.  On December 16, 1992,                      
          petitioner, through his attorney, submitted a document to the               
          District Court explaining his position on his claims.  This                 
          document addressed petitioner's claims for:  (1) Commissions owed           
          on the AT&T, Prudential, and the New York Giants contracts,                 
          (2) lost commissions on NBA accounts removed from his sales                 
          territory, (3) lost equity in his sales territory, (4) violations           
          of Connecticut wage statutes, (5) conversion, (6) wrongful                  
          discharge, and (7) Balfour's counterclaims.  The document did not           
          address any physical or emotional injury purportedly suffered by            

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