She and other Wal-Mart officials also asserted that time-clock records could have been wrong in indicating that minors had worked illegally during school hours.
Retailing analysts, lawyers and Wal-Mart officials say it is hard to estimate the potential liability to the company in all these cases.
Expansion Studied Wal-Mart officials said that if their approach proved successful, they planned to dot the nation's cities with the giant stores.
When asked about the memo, Wal-Mart officials made available the updated copy that actually went to the board.
They praised Wal-Mart officials for providing complete cooperation after the October 2003 raids.
(Wal-Mart officials did not respond to inquiries seeking comment.)
But Wal-Mart officials said that yesterday's developments showed that the company had made major improvements in wage compliance.
A Wal-Mart official complained that "outside special interests" had snookered the natives into rejecting the store.
Mr. Whitcomb said Wal-Mart officials could find no record of the letter at its home office.
The occasion was celebrated by town and Wal-Mart officials.