Sample Settlement Agreement And Release Page 5

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C.
Employer has denied, defended and disputed the allegations and claims contained
in the Charge and Action; and
D.
The parties desire to settle and resolve the Charge and Action and all other
disputes and claims which have been or could have been asserted between them. [Note: If any
claims are not resolved by this Release, so indicate in Paragraph 6B and 6C below.]
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. Within 15 business days following execution of this Agreement or
within 15 business days following the period required by Paragraph 15 (Special Provisions for
Age Discrimination), if applicable, Employer agrees to pay Claimant the total amount of
___________________ Dollars and Zero Cents ($________.00) for settlement of all claims
against Employer that Claimant could have sought, including but not limited to his/her claim for
damages alleging physical injury. Said payment shall be divided as follows:
a.
$________.00 in back pay with applicable taxes withheld.
b.
$________.00 in compensatory damages from which Employer will not withhold
any taxes.
c.
$________.00 as attorney fees to Claimant’s attorney and made payable to
Claimant’s attorney.
d.
$________.00 as _____________________________ (please specify category).
Page 2 of 13
Initials __________ Initials ___________________________________

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