SETTLEMENT AGREEMENT & RELEASE

Between the Michigan Department of Labor and Economic Opportunity

&
Steve Gray

SETTLEMENT AGREEMENT
This agreement is non-precedent setting and is made voluntarily, without any
duress or coercion, and constitutes a final and binding agreement resolving all
issues pertaining to the
employment of Steve Gray with the Michigan Department
of Labor and Economic
Opportunity. Further, the parties agree that the
employment matters to which this Agreement relates and resolves, shall be non-
actionable in any forum. Nothing in this Agreement bars an action to enforce its
terms.

1. The Michigan Department of Labor and Economic

Mr. Steve Gray agree that Mr.
Opportunity (LEO) and
will
Gray voluntarily resign his employment
effective Thursday, November 5, 2020.

2. In consideration for releasing all claims

against LE0 arising out of his
employment, the Department will pay Mr. Gray the sum of $85,872.56 which
represents pay from November 6, 2020 to June 1, 2021. The payment shall
be made as follows:
a. A final paycheck will be issued to Mr. Gray, including a gross
pay adjustment in the amount of $76,626.19, which will constitute wages and
for which a W-2 will be issued to Mr.
Gray. This will be received on or about
November 25, 2020.
b. A check to be mailed within 10
days of Mr. Gray's
execution of
this agreement made payable to Fagan McManus, PC in the amount of
$9,246.37 for Mr. Gray's costs and attorney fees and for which a 1099 will be
issued to Fagan McManus, P.C. The check is to be mailed to Mr.
counsel, Jennifer McManus, Esq., 25892 Woodward Ave., Gray's
Royal Oak,MI
48067

3. Both parties shall maintain confidentiality

with and departure from with the
regarding Mr. Gray's employment
Department, unless required by law to
release information regarding his employment and
any actions taken during
Mr. Gray's employment with the
Unemployment Insurance Agency.In
addition, both parties agree that they will not make any statements or take
any action disparaging the reputation of the other, whether written or oral.
Nothing in this provision prevents either party from testifying truthfully in
any legal proceeding, responding fully and truthfully to any inquiries made
by a government agency, or otherwise providing lull and complete
 information as required by law. LEO will provide a neutral reference to any
inquiries, i.e. confirm dates of employment, salary, and classification.

4. In exchange for this agreement Mr. Gray agrecs to fully and finally release
all claims against LEO and the State of Michigan as described below.

FULL AND FINAL RELEASE OF ALL CLAIMS

I, Steve Gray, for myself, my successors, heirs, assigns, and any other persons who
could lawfully make claim on my behalf, do hereby release, forever discharge, and
hold harmless the State of Michigan and the Michigan Department of Labor and
Economic Opportunity, and each of its divisions, agencies, commissions, officers,
and employees and former employees, and the successors, heirs and assigns of such
persons and entities, from any and all rights, actions, grievances, claims, liabilities,
duty disability retirement claims, demands, suits, and causes of action, whether in
law or equity, of each kind and nature, and description, whether known or
unknown, suspected or arising out of my employment with the Department of Labor
and Economic Opportunity, including, but not limited to, any claim for costs or for
attorney fees and any claim related to my employment.

WITH FULL KNOWLEDGE AND UNDERSTANDING OF MY

RIGHTS,,I
specifically release and waive any federal or state civil rights claims and any
violations of state and federal constitution and/or statutory rights as well as all
other legal claims I may have had arising out of my employment with the State of
Michigan and, Department of Labor and Economic Opportunity, including, but not
limited to, any claim for costs or for attorney fees and any claim related to
mny
employmnent.
This release includes all claims and grievances for age discrimination, race
discrimination, gender discrimination, national origin discrimination, religious
discrimination, discriminatory harassment, unlawful retaliation, breach of express
or implied contract, breach of the duty of fair
representation, violation of public
policy, workers' compensation, violation of any applicable compensation plan,
intentional or negligent iníliction of emotional distress, breach of the covenant of
good faith and fair dealing, fraud, misrepresentation, conspiracy, unpaid wages,
overtime and/or commissions, defamation, retaliation, tortuous conduct, violation of
due process, federal or state civil rights claims or any other type of claim
claims arising under Michigan Civil Service Rules and including
Regulations, tort, or contact,
that arises from or related to employment with the State of
of Labor and Economic Opportunity and/or
Michigan, Department
any wages and benefits available in
connection with such employment. I further acknowledge that I have not sustained
any work-related injury or illness during my employment with the State of
Michigan and/or the Department of Labor and Economic Opportunity.
This release has been executed for the valuable consideration agreed to above
between the parties that is incorporated in its entirety herein.

It is expressly understood and agreed that the sole consideration for this Release is
the consideration set forth in the Settlement
Agreement and incorporated herein;
that the consideration herein is contractual and not a mere recital; that all
agreements between the parties released herein do not admit liability but expressly
deny the same and shall not be construed to be an admission of liability; and that
said consideration is paid in compromise and settlement of a disputed claim or
claims.

I represent and
acknowledge that before signing this Release, I read the same,
consisting of two (2) pages; that I fully understand its terms, content, and effect;
and that I have had the benefit of advice from
attorneys of my choosing and have
relied fully and completely on my judgment and on the advice of my attorneys in
executing this Full and Final Release of All Claims. I further acknowledge that
under the Older Workers' benefits Protection Act, I have the right to consult an
attorney prior to executing this agrement. I also specifically waive any right under
the Older Workers' Benefits Protection
Act, to consider the agreement for the full
twenty-one (21) day period. I further acknowledge that I have a right to revoke the
agreement within seven (7) calendar days of the date of my signature and further
agree that any revocation will be communicated in writing addressed to the Human
Resources Director, Office of Human Resources, Department of Labor and Economic
Opportunity, 105 West Allegan Street, Lansing, MI 48933, via hand deliver or
certified mail delivery. I represent and acknowledge that I execute this Release
voluntarily and willingly.

INT WITNESS WHEREOF, I SRUe TX executed this FULL AND FINAL

RELEASE OF ALL CLAIMS by my free act and deed on
l-S2020

1/-5-03O
KeriM Lardie/ Date
Department of Labor and Economic Opportunity

Steve Gray
l 52ODD
Date