Edward P. Knoll and Mary K. King-Knoll - Page 9

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          (approximately 6 months after petitioner began psychological                
          counseling) that he introduced a claim for personal injuries into           
          the negotiations.  On August 6, 1993, approximately 16 months               
          after receiving the March 23, 1992, severance letter, petitioner            
          proposed revision of clause 2(b) of Winston’s June 22, 1993,                
          draft agreement.  The proposed revision contained only general              
          references that the $55,000 lump-sum payment was for personal               
          injury, as follows:                                                         
               in consideration of Mr. Knoll’s release of defamation,                 
               intentional infliction of emotional distress, loss of                  
               personal reputation and other personal injury claims                   
               described in paragraph 1.n. of this Agreement.                         
               Deborah Haude was the Winston attorney who was primarily               
          responsible for negotiating settlement agreements with severed              
          partners.  Ms. Haude was experienced in employment torts, and               
          during the course of the negotiations she also consulted with               
          other Winston attorneys who specialized in taxation and                     
          employment torts.  During a break in the August 6, 1993, meeting,           
          Ms. King-Knoll spoke with Ms. Haude in the restroom.  Ms. King-             
          Knoll indicated to Ms. Haude that the extended negotiations and             
          Winston’s manner of negotiating was “destroying” petitioner.                
               Petitioner, however, did not make Ms. Haude and/or Winston             
          aware of a specific tort claim, such as the IIED claim.  Ms.                
          Haude and other Winston negotiators knew that the negotiations              
          caused petitioner stress; however, they did not know that he was            
          receiving counseling treatment or know of his emergency room                





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