gore serge amatuer. ermuen — SETTLEMENT AGREEMENT AND RELEASE ‘This Settlement Agreement and Release (“Agreement”) is made and entered into by and between Al Dixon (hereinafter referred to as "Claimant"} and the Plainfield Municipal Unlities Authority (hercinefter referred to 28 “Emplayer"). In considesation ef the following promises. the parties agree to the following: A ‘The parties desire to resolve ail matters arising out of Claimamt’s employment related claims against Employer: B. _ Claimant hes alleged certain ciaims against Employer based upon and arising out of his employment with Employer. C. The parties desire to settle and resolve all disputes and claims which have been oF, could have been asserted between them. NOW THEREFORE for and in consideration of the mutual releases. covenants and undertakings hereinafter set forth, and for other good and valuable consideration, which each party acknowledges, it is agreed as follows: 1. Payment Jin 15 business day’ following execution of this Agreement Ernployer agrees to pay Claimam the totel amovnt of Sever, Thovsand Five Hundred Dollars and Zero Cents (37,5100.00) for settlement of all claims against Employer that Claimant could have sought Soid payment shail be made payable to Giblin & Giblin and shall be disbursed by counsel 2s follows: a. $6,000.00 for Claimant in settlement of claimes of emotional distress alleged by sth respect 10 his employment with the employer: momey fees to Giblin & Giblin,2, Withdrawal and Dismissal. In exchange for the receipt of the payment provided to ‘ent, Claimant agrees (0 take ne further ection in 7 age [Slaimant pursuant fo the terms of this A\ which have arisen as of the date of the signing of this yegard to any employment claims 3, Release of Claims. Claimant and Employer hereby mutually release and forever dicchorge each other ond each of their affitistes, ssbsidiaries, parent corperations snd Uhcir respective agents. present and former directors, officers, executives. employees. predecessors andlor successors in interest, zitomeys, heirs and sesigns, from any and al) matters, claims. complaints, charges, demands, damages, causes of action, debts. liabilities, controversies. judzments and suits of every Kind and nature whetsoever, this aim as of the date of this 4 to. those foreseen or unforeseen, known ox unknown, including but not limi ent with Employer Jaimant and Employer hereby mutuaily release end forever discharge cach other and each of their affiliates, subsidiaries, parent corporations and their respective agents. pres ors. offices sutives, employses. predecessors andlor successors in interest. attomeys, heirs and assigns, from any and all matters, claims. complaints, chorpes. demands. demages, causes of action, debts, [abilities controversies and suits of every kind and nanme whatsoever, as of the date of this Agreement foreseen ar unforeseen, ke wn or unknown, inchiding but not limited 16, those arising out of Joyrnent with Employer and the Claimant's esnp on of such employment, complaints ané acti released include. hut arc not limited to, any claims Claimant may have s employment with Employer, incloding any claims far at meys' foes or claims of solations arising under the Ci Rights Act of 1964. 42 US.C. §2000e} er seq., the2] et seq., the Americens with Disebilities Act en, Diserimination in Employment A of 1990, 42 U, ity Act, 20 U.S.C. § S.C. § 12161 ot seq, the Employee Retireznent income Secu 1001 et seq, (encept as excluded by Paragraph 6C), the Fair Labor Standards Act Act of 1973, 29 U.S.C. § 71 et seq., the False Claims WSC. § 201 et seq., the Rehabiti Act, 31 US.C. § 3729 et seq, the Family and Medical Leave Act, 29 U.S.C. § 2601 et seq. oF any otker relevant federal, state or local statute or ordinance, or arising under commen law, including but not fimited to torts, contracts or public policy claims. 5. if elther pany violates this Agreement by g the other party for any reason fos which suit is prechsded by this Agreement. the suing party agrees that he will pay all costs and party in defending such 2 te expenses incurred by the non-suing sit, incheding reasonable 6 xr party sues the other porty for enforcement. of this ‘Agreement, the prevailing pany shall receive its reasonable ariomeys fees and expenses Tor 7. Mutual Non: Admission Ciarmant and Employer agree that nothing herein. shail be consirued as an admission by cither of them of any wrongdoing whatsoever or violation of 4 that nothing in this Agreement shall he so construed by any other person. & - Moiual_ Confidemtaiisy. The nature of Ci art's allegations against the over and fhe dollar emount of this Agreement may net be disclosed to any person or entity except as set forth herein. Claim disclose and Employer may he dolar amount of this ‘Agreement: (a) To their respective attomeys. and as also applicable to Claimant's allegations. to their respective sax advisers, 1 agents of govemmentalt 1g autherities acting in their official copacities, 1¢ agents of gevernmemz! equal-employment. fnir-employment.