SETTLEMENT AGREEMENT AND RELEASE “Tuis Semtlement Agreement and Release (“Agreement”) is made and entered into by and between ‘Thomas Robinson (hereinafter referred to 9s “Cleimant”) and the Pleinfielé Municipal Utaites shority Qhereiuafter referred to as “Eraployer"). In consideration ofthe following promises, the parties agree to the following ‘A. The parties desire to resolve all matters arising out of Claimant's employment related claims against Employer: B, _Claimant has aifeged certain claims against Employer besed ypon and arising out of his employment with Em C. The parties desire to settle and resolve ali disputes and claims which have been cr could have been asserted between them. NOW THEREFORE, for and in consideration of the mumel es, covenants and undertakings hereinafier set forth. ané fos other good and velusbie consideration, which each acknowledges, itis agreed 2s follows: 1. Payment. Within 15 business days following execution of this Agreement Employer mant the total amount of Seven Thousand Five Hundred Dollars and Zero agrees to pay Cla Cents ($7,500.00) for settlement of all claims against Employer that Claimant could have sought Said payment shall be made payable te Giblin & Giblin and shall be disbursed by counse follows: 2. $6,000.00 for Cleimant in settlement of cizims of emotional disiress alicged by the Cisiment with respect to his employer: with the employer, 0.00 as ettomey fees te Gib & Giblin, \znyznaa weaz:71 Lin? ne 260 yeyWithdrawal snd Dismissal. In exchange for the receipt of the payment provided to ‘Agecement, Claimant agrees to take no further action in eof th ant pursvsnt to the te ard to any employment claims which have arisen as of the date of the signing of this Claimant aod Employer hereby mutually release end forever discharge each other end cach of their affiliates, subsidiaries, parent corporations and their respective agents, present and former directors, officers, executives, employees. predecessors andlor successors in interest, attomeys, heirs and assigns, from any end all matters, clairas, < of action, debts, hebilities, controversies, compizints, charges, demends, damages. cat jever, this cleim as of the date of of every kind and nature whi judgments and sui Agreement, foreseen ov unforeseen, known or unknown, inchuding but not Himited to, those arising out of Cleimant’s employment with Employer. 4 Senera) Release. Claimant end Employer hereby mutuelly release and forever discharge cach cther and each of their affiliates, subsidiaries, parent corporations and their respective agents, present and former directors, officers, exceutives, employees, predecessors ° es emp pr and/or suecessors in interest, attemeys. heirs and assigns. ftom any and ell matters, claims, gee, causes of action, debts, Hebilities, controversies, complaints, charges, demands, dem judgments and suits of every kind and mature whatsoever. as of the date of this Agreement, or unknown, i a foreseen oF unforeseen, know Luding but not limited to, @ 1g out oF Cisimant’s employment with Employer and the termination of such employment. The dims are not limited to, any claims Claimant may have plaints and actions released inch selatin J 10 his employment with Employer, including any cleims for anomeys’ fees or claims of violations arising under the Civil Rights Act of 1964, 42 U.S.C. §2000(e) ei seq.. the Age \z0/E00d wdgz:21 LL0z 06 990 reeDiscrimination in Employment Act, 29 U.S.C. § 621 et seq. the Americans with Disabilities Act of 1990, 42 US.C. § 12101 et seq. the Employee Retirement incame Security Act, 25 U.S.C. § Loot et sag, (except as exciuded by Paregreph SC), the Fair Labor Standards Act of 1938, 29 the Rehabilitation Act of 1973, US.C § 701 et 69, the False Claims ‘Act, 31 U.S.C, § 3729 et seq, the Family and Medical Leave Act, 29 U.S.C. § 2601 et s¢9., oF any other relevant federal, state or local ststute or ordinance, or arising under common. law, including but not limited to torts, contracts or public policy claims. 5, If either party violates this Agreement by suing the cther party for any reason for which suit is precluded by this Agreement, the suing pany agrees that he will psy all costs and expenses incurred by the non-suing party in defending such # lawsuit. including reasonable 6. Suit for Enforcement. Yf either party sves the other party & forcernent of Ageernent, the preveiling party shall receive its reasonable anomeys' fees and expenses for pursuing said setion, ssion. Claimant and Employer agsee that nothing herein shel! 7. Mutual Non-Ad: constrved as an admission by either of them of any wrongdoing whatscever or violation of ment ry applicable lew. shall be so construed by any other person. 3. Mutwal_ Confidentiality. The nature of Claimant's allegations ageinst the Employer and the dollar amount of this Agreement may not be disclosed to any person. oF entity except as set forth laimant and Employes may disclose the dollar amount of this Agreement: 4a) To their respective ettomeys, and 85 also applicable to Claimant's allegations. to their respective tax advisors, to agents of governmentel texing autho official s acting capacities, 1¢ agents of goverrmental equel-employment, fair-empleyment, umen-rights, oF Lzayenaa edez-71 1un7 er cen py