SEPARATION AGREEMENT AND RELEASE

THIS SEPARATION AGREEMENT AND RELEASE ("Agreement" or "Release"), effective

August 4, 2015, sets forth the terms of the separation agreement and release between St. Mary's
Academy ("St. Mary's") and Lauren Brown ("Brown").
St. Mary's is withdrawing Brown's contract offer as of the date of this Agreement.
The parties desire to formalize the terms of Brown's separation from St. Mary's.
AGREEMENT

1.
Contract Withdrawal. St. Mary's hereby withqraws its contract offer to
Brown as of August 4, 2015. Except for purposes of this Agreement and for unemployment
insurance purposes, Brown will be considered to have voluntarily withdrawn from the contract.
2.
Payment. In consideration for withdrawing ll'e c ntract offer, St. Mary's~ ~
will pay Brown all wages Brown would have earned for the first six onths under her contract,+~~~.S
in accordance with regular payroll procedures, including normal
oll withholdings, provided
however, that St. Mary's will make full payment on August 4, 2015.
3.
Brown Release. Brown hereby releases St. Mary's and its insurers,
directors, administrators, agents, representatives, attorneys, successors, predecessors, affiliated
corporations, parent corporations, assigns and Brown further releases all parents of St. Mary's
students and all St. Mary's students, from any and all liability, damages, suits, demands, claims
and causes of action of any kind whatsoever, whether known or unknown, liquidated or
unliquidated, contingent or fixed, direct or indirect, whether in tort, contract or based on statute,
which Brown now has, ever had or may hereafter have or claim to have, which are or may be
based in whole or in part upon, or may be due to or arise out of, or arre or may be related to any
action, transaction, agreement, occurrence or event on or prior to the date of this Release,
including, but not limited to claims relating to Brown's contract with ~t. Mary's or her separation
from St. Mary's. This Release specifically includes, but is not limited to all claims for relief or
remedy under any state or federal laws, including, but not limited to Title VII of the Civil Rights
Act of 1964, the Civil Rights Act of 1991, the post-Civil War Civil Rights Act (42 U.S.C.
1981-1988), the Equal Pay Act, the Age Discrimination in Employment Act ("ADEA''), the
Rehabilitation Act of 1973, the Vietnam Era Veterans Readjustment Assistance Act, the Fair
Labor Standards Act, the Americans with Disabilities Act, the Family and Medical Leave Act of
1993, Executive Order No. 11246, all as amended, the civil rights, employment and labor laws of
the state of Oregon, and the law of any other state.
4.
Covenant Not to Sue. Brown agrees that she will not, for herself or on
behalf of any other person or entity, bring, commence, institute, maintain, prosecute or
voluntarily aid any action at law or in equity, or otherwise prosecute or sue any of the parties
released by this Agreement, either affirmatively or by way of cross-complaint, defense or
counterclaim, or in any other manner with respect to the claims released herein.

5.
No Liability Admitted. Nothing in this Agreemept shall be construed as an
admission of liability of any of the parties released, each of whom expressly denies liability.
6.
Confidentiality and Nondisparagement. St. Mary's and Brown agree to
keep the terms of this Agreement confidential and Brown will not disclose such terms to any
third party, except as reasonably necessary to family members, attorneys and accountants, or as
required by law. However, Brown may post on her social media pages the following statement to
describe her separation from St. Mary's: "Friends, I want to let you all know that I will no longer
be at St. Mary's in the fall. Please message me if you know of any job~ available. {3"
Except as provided above, if Brown is asked about the reasons for th,e separation, she agrees to
provide the following explanation: "I learned that my intent to enter into a same-sex marriage is
in conflict with the teachings of the Catholic church.".
The parties agree that they will not disclose to the public any of the pircumstances surrounding
Brown's termination and will not disparage each other or any related persons or entities to any
third parties.
7.
Governing Law. This Agreement shall be construed in accordance with
and governed by the laws of the state of Oregon.

8.
Entire Agreement. This Agreement is an int~grated agreement which
constitutes the entire agreement between the parties with respect to its subject matter and except
as otherwise provided herein supersedes all prior agreements, representations or understandings,
written or oral, with respect to the subject matter, and may not be altered or amended except in a
writing signed by the parties. The parties further acknowledge that the terms of this Agreement
are contractual and not mere recitals. The parties further acknowledge that they have not relied
upon any other consideration or representations except as providep in this Agreement and
expressly waive any claim for fraud in the inducement in entering into this Agreement.
9.
Severability. In the event any provision of this Agreement is found to be
unenforceable, the parties intend that the remainder of the Agreemept be given full force and
effect to the fullest extent allowed by law.
10.
Section Headings.
The section headings <:;ontained herein are for
reference purposes only and will not affect in any way the meaning or interpretation of this
Agreement. The parties acknowledge that this is a negotiated agreement that is to be interpreted
according to its words and is not to be construed against either party as the drafter.

St. Mary's Academy

By~--------------------
Christina Friedhoff, President
Dated -----------------------

La~ren

Dated

Brown

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