James T. Sinyard and Monique T. Sinyard - Page 6

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          provide equal opportunity for individual employees of IDS age 40            
          and older.                                                                  
               The injunctive relief sought by EEOC was prospective in                
          nature and intended to benefit all employees of IDS including               
          employees who were plaintiffs in the Glass and Stephens class               
          actions.  Intervention by EEOC in the Glass and Stephens class              
          actions enhanced the merits of the class action lawsuits against            
          IDS.                                                                        
               Legal services of Winthrop and Weinstine on behalf of the              
          class action plaintiffs complemented the legal services of EEOC’s           
          attorneys, and vice versa.                                                  
               On November 21, 1991, in the Glass and Stephens class                  
          actions, the District Court granted partial summary judgment in             
          favor of IDS and against the class action plaintiffs dismissing             
          certain breach of contract, ERISA, and tort claims made against             
          IDS.  Some of the legal services performed by Winthrop and                  
          Weinstine prior and subsequent to November 21, 1991, were                   
          attributable to the advancement of plaintiffs' contract and ERISA           
          claims.                                                                     
               In early August of 1992, a comprehensive settlement in the             
          Glass and Stephens class actions was entered into in which IDS              
          agreed to pay $35 million to resolve all remaining claims                   
          relating to the above class actions, including claims for                   
          litigation costs and attorney's fees.                                       






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