Geraldine M. and Arthur F. Reid - Page 4




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               Petitioner commenced a lawsuit in Florida State court                  
          against Chevron and its subsidiary American Personnel Services,             
          Inc. (APSI), Reid v. APSI/Chevron, docket No. 96-01490.                     
          Petitioner did not produce to either respondent or the Court a              
          copy of the complaint.  As indicated in a statement made in                 
          petitioner’s attorney’s letter, we understand that his cause of             
          action against Chevron was wrongful discharge, intimidation,                
          coercion, and harassment in violation of Fla. Stat. Ann. sec.               
          440.205 (West 1998), Coercion of employees.  The parties settled            
          the litigation in March 1998, and the case was dismissed with               
          prejudice on March 24, 1998.  Petitioner received $5,000 in                 
          settlement proceeds.                                                        
               Petitioner executed a hold harmless agreement pursuant to              
          which he agreed to indemnify and hold harmless Chevron and APSI             
          from any and all liens and third-party rights, including                    
          subrogation from any medical care providers, insurance companies,           
          or any collateral source provider such as Medicare, Medicaid, and           
          Social Security, and from “any claims of said nature including              
          any attorney’s fees and costs incurred in defending such                    
          actions”.                                                                   
               Petitioner also executed a Release and Settlement of Claim             
          pursuant to which he agreed to release and discharge Chevron and            
          APSI from the following:                                                    








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