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We request assistance from members of the proposed class and other witnesses in prosecuting the claims. At this time, we ask any person possessing any non-privileged information about the topics identified below to contact us. You dont necessarily need to be able to prove the information you have; instead, we would like to hear from you even if your knowledge is limited to what youve heard from others. Also, please contact us even if you believe it is unnecessary because other agents who know of the same incident may also contact us.
At this time, we would like information concerning:
1. Any statement, written or oral, by any Allstate manager at any time after 1984, whether at a meeting or individually, in which the manager indicated that Allstate intended to reduce or eliminate employee benefit payments for employee agents or that funding of employee benefits for employee agents had become or might soon become too expensive for Allstate or that;
2. Any statement, written or oral, by any Allstate manager at any time after 1984, whether at a meeting or individually, in which the manager indicated that Allstate hoped, intended or anticipated that older agents would leave the company's service in response to Allstate's actions, including its implementation of the Mass Termination Program.
If you have such information, please contact in writing or by telephone either of the legal assistants listed below:
Mail:
Morgan, Lewis
& Bockius LLP
1111 Pennsylvania Avenue, N.W.
Washington, DC 20004
Sprenger &
Lang, PLLC
310 4th Avenue South
Suite 600
Minneapolis, MN 55415
Tel: 612-486-1848
Fax: 612-871-9270
contact@sprengerlang.com
Jacqueline
Olson
Sprenger & Lang
1614 Twentieth Street N.W.
Washington, DC 20009
(202) 265-8010
jolson@sprengerlang.com
Vivian
Lam
Sprenger &
Lang
1614 Twentieth
Street N.W.
Washington, DC 20009
(202) 265-8010
vlam@sprengerlang.com
Toll-Free:
1-877-739-5114
If you have any documents, including video or audio tapes, about the events or incidents you wish to describe, please send them to Jacqueline or Laura as well.
Please do not use email until we have a secure email communication system. If you choose to contact us in writing, remember to include your name, email address, street address and/or telephone number(s) so that we respond to you if necessary.
To the extent allowed by law, we will keep your information confidential. By submitting this information to us, you intend, as do we, that all the information you provide will be privileged from disclosure to Allstate as a communication between a potential client and an attorney. However, Allstate may seek the information, and we cannot guarantee that the judge will not compel us to produce it.
If you are still an agent with Allstate, any retaliation by the company or its affiliates against you for exercising your legal rights by participating in the suit, providing us with information, or otherwise assisting us provides a separate basis for bringing a suit. Please report any act that you consider retaliatory to us immediately. Also, if Allstate learns that you are participating in this suit in some fashion (for example, by sending information to us), its lawyers may approach you to answer questions. You are under no obligation to answer any questions from Allstate about anything to do with this suit, to explain why you provided us with information, or to provide Allstate with a copy of any information that you provide to us. If you wish to speak with someone other than us who is independent of Allstate before deciding whether to answer Allstate=s questions, we will provide the name of lawyers who can give you independent advice free of charge or for a minimal fee.
Note that we cannot promise that you will be found to be a member of the proposed class or any subclass or, indeed, that a class or subclass will be certified at all. Also, by receiving your information, we are not agreeing to act as your personal attorney, although we do and will represent you in your capacity as a potential class member. Currently, we are personally representing only the individuals listed as plaintiffs in the Complaint. Should you wish to become more actively involved in the suit beyond providing us with information, we would be happy to discuss that with you.
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© 2002-2008 Morgan, Lewis & Bockius LLP, AARP Foundation Litigation
and Sprenger & Lang, PLLC.
All Rights Reserved.