In his successful campaign for Kane County Treasurer, Chris Lauzen vowed he would earn an additional $2 million in investment income for the county.
But last week, he agreed to pay a 17-year employee of the treasurer’s office more than $46,000 in a severance agreement, released after a Freedom of Information Act request.
Original Title
Separation agreement between Chris Lauzen, 17-year employee, released through FOIA
In his successful campaign for Kane County Treasurer, Chris Lauzen vowed he would earn an additional $2 million in investment income for the county.
But last week, he agreed to pay a 17-year employee of the treasurer’s office more than $46,000 in a severance agreement, released after a Freedom of Information Act request.
In his successful campaign for Kane County Treasurer, Chris Lauzen vowed he would earn an additional $2 million in investment income for the county.
But last week, he agreed to pay a 17-year employee of the treasurer’s office more than $46,000 in a severance agreement, released after a Freedom of Information Act request.
SEPARATION AND Gi
This Separation and General
date written below, voluntarily and
LL RELEASE. ‘EMENT
elease Agreement ("Agreement") is entered into as of the
pely, by and between CARROLLYN BRADY, on behalf of
herself, her heirs, executors, administrators, assigns, representatives and agents (collectively,
"CARROLLYN BRADY” or “MS. BRADY) and the KANE COUNTY TREASURER
CHRISTOPHER LAUZEN, on behal
predecessors and successors, assigns,
agents, in their official and individual
‘of himself individually and his elected capacity and his
lemployees, representatives, indemnitors, attorneys and
capacities, (hereinafter, collectively and jointly and
severally, the "CANE COUNTY TREASURER” or “TREASURER”).
WHEREAS, CARROLLY!
Director of Financial Operations and
TREASURER since October 17, 2
BRADY is currently employed as the TREASURER’S
as been employed by the KANE COUNTY
5; and
WHEREAS, TREASURER and CARROLLYN BRADY (collectively, the
“Parties”) have mutually agreed to
jerminate their employment relationship in accordance
with the terms of this Agreement; and
WHEREAS, the Parties des
exist between them and to anticipa
hereafter arise.
NOW THEREFORE, in ci
‘covenants and other good and valu
receipt and sufficiency of which is
jire to compromise and resolve any differences that may
fe and avoid any future claims or differences that might
nsideration of the mutual agreements, general releases,
ble consideration set forth in this Agreement, the
\ereby acknowledged, the Parties agree as follows:
1|Page1, Employment Status.
IThe Parties agree that the TREASURER and
CARROLLYN BRADY have mutually agreed to terminate their employment relationship
effective the end of business May 1,
2
1, 2023, the parties agree that CARR(
of wages via payroll, which will be s
contributions. The parties further ack
eligible for any employee benefits for
employment, not to extend past May
t
Severance. From the
3, in accordance with the terms of this Agreement.
1 of the execution of this Agreement, and through May
LLYN BRADY will continue to receive regular payment
foject to all applicable taxes, withholdings, deductions and
wledge and agree that CARROLLYN BRADY is
lwhich she is properly enrolled through the term of her
, 2023 (with health insurance for the month of May, 2023
being covered). CARROLLYN BRADY’S required employee contribution for the premium of
such benefits will be made through re
and the Kane County Personnel Polic}
CARROLLYN BRADY for any rem:
‘gular payroll deductions. In accordance with Illinois law
Handbook, the TREASURER further agrees to pay
ining unused or accrued vacation time (¢.g., as of May 1,
eeeeeerrrrsrS—srsS and
any earned but unused sick/personé
unused sick/personal time), via her|
time (¢.g., as of May 1, 2023, 14 hours of earned but
last regular payroll check, less applicable taxes,
withholdings, deductions and contributions. In addition, the TREASURER agrees to pay
to CARROLLYN BRADY a one-t
seventeen (17) weeks’ wages), as
which severance payment will be
contributions. The Parties acknowl
and other consideration set forth in|
known and unknown claims CARR‘
ime, lump-sum amount of $33,947.39 (representing
Jeverance, to be paid via regular payroll in [May], 2023,
ibject to all applicable taxcs, withholdings, deductions and
ige and agree that the payment of additional wages
this Agreement, are in full satisfaction of any and all
LYN BRADY may have relating to her employment with,
2|Pageor separation from, the TREASURER,
COUNTY OF KANE, ILLINOIS (“Ct
‘Agreement and exceeds any amount of pas
TREASURER or the COUNTY.
3. Unemployment. The J
for unemployment insurance benefits
agreement.
4, Health Insurance Co
by law to purchase continued health i
Revenue Code (commonly known as
insurance benefit offered by Kane Cot
5. Retirement Benefits.
have to benefits under the Illinois Mu}
6. Neutral Letter of Ret
or any other claims against the TREASURER or the
JUNTY”», arising prior to the execution date of this
yyment or debt due and owing to her from the
REASURER agrees not to contest any truthful application
CARROLLYN BRADY may make after the date of this
lerage. CARROLLYN BRADY retains all rights provided
surance coverage pursuant to §4980B of the Internal
OBRA continuation coverage) or any other health
nty,
ICARROLLYN BRADY retains all vested rights she may
cipal Retirement Fund (“IMRF”).
srence. The TREASURER agrees to provide
CARROLLYN BRADY with a neutral letter of reference signed by Kane County Treasurer
‘Christopher Lauzen on KANE COI
reference is attached hereto as Exhibit
BRADY, and a copy of the letter will
CARROLLYN BRADY is responsibl
TREASURER will not distribute the
“se General Release. ALI
discharge the EACH OTHER PARTI
expenses, attorneys’ fees, debts, dem:
ITY TREASURER letterhead. A copy of the letter of
‘A. The executed letter will be provided to CARROLLYN
lbe placed in CARROLLYN BRADY'S personnel file.
lc for distributing the letter to any potential employers; the
letter of reference.
L PARTIES hereby fully release, waive and forever
IES AND THE COUNTY from any and all claims,
inds, costs, grievances, contracts, liabilities, damages of any
3|Pagekind, including without limitation pur
payment, compensation, wages, bene!
compensation benefits, and causes of.
law whether common, constitutional,
equity, whether known or unknown,
employment with or separation from
injtive, liquidated, and consequential damages, rights to
ts, back or front pay awards, disability, workers’
(collectively, “Claims") under any theory under the
|, $tatutory or other, of any jurisdiction, whether in law or in
ising out of or relating to CARROLLYN BRADY’s
KANE COUNTY TREASURER or any other Claims
ANY PARTY may have against EACH OTHER OR THE COUNTY atising prior to the
execution date of this Agreement. These Claims specifically include, but are not limited to,
claims for intentional or negligent in
termination, breach of contract, fraud
iction of emotional distress, invasion of privacy, wrongful
conspiracy, misrepresentation, interference with
contractual relations or prospective business advantage, libel, slander, defamation, negligence,
disability, severance pay, worker's co}
national origin, ancestry, citizenship
status or service, veteran status, unfay
identity, pregnancy, political affiliat
disability, age and/or any legally pro
federal or local law, constitution, sta
Human Rights Act, the Illinois Work
ynpensation, retaliation and/or discrimination based on race,
status, marital status, order of protection status, military
rable iniitary discharge, sex, sexual orientation, gender
mn, genetic information, religion, color, mental or physical
fected status and/or any other violation under any state,
ute, or regulation, including without limitation the Illinois
r's Compensation Act, the Illinois Public Labor Relations
Act, the Illinois Whistleblower Act, the Illinois State Officials and Employees Ethics Act, the
Ilinois Public Officer Prohibited Act
Rights Act of 1964, as amended, inel
Equal Pay Act, the Americans with
the Family and Medical Leave Act o}
vities Act, 42 U.S.C. Section 1983, Title VII of the Civil
luding the Equal Employment Opportunity Act of 1972, the
jisabilities Act, as amended, the Rehabilitation Act of 1973,
1993, the Age Discrimination in Employment Act of 1967
4|Page(“ADEA”), as amended, and/or the O1
extent permitted by law, ALL PARTI
instituted any action in any federal, st
against the OTHER PARTY. The afor
to enforce the terms of this Agreement
8. Assignment. All Parti
way conveyed, transferred, or encumb}
Agreement,
9. Nature of Considerati
not receive the consideration set forth
Agreement and their fulfillment of the
iler Workers Benefit Protection Act, To the maximum
'$ covenant not to sue or to institute or cause to be
te, or local agency or court, or in any arbitration forum,
smentioned Release shall not apply to any claim pursued
s warrants and represents they have not assigned or in any
red all or any portion of the Claims covered by this
mn, Each Party understands and agrees that they would
in this Agreement, except for her execution of this
[promises contained herein. CARROLLYN BRADY
acknowledges and agrees that the monptary payment she is receiving pursuant to this Agreement
exceeds any amount of payment or de
or the COUNTY, but for her signing t
10.
shall immediately return all TREASUI
1t that may be due or owing to her from the TREASURER,
\is Agreement.
Employer Property and Confidential Information. CARROLLYN BRADY
RER and COUNTY property, documents and passwords
she may have in her possession. CARROLLYN BRADY further agrees never to disclose to any
person or entity any confidential or pri
COUNTY, to which she has had acces
written authorization and consent of the
11. Non-Admission. All Pi
hereunder constitutes an admission of fi
jileged information belonging to the TREASURER or the
‘as a part of her job duties, except upon the express
REASURER and/or the COUNTY.
[
ies agree that neither this Agreement nor performance
ability by any other Party, who expressly deny any
liability to each other and further expressly deny any violation of any federal, state or local
5|Pageconstitution, law, regulation, common
any other wrongdoing of any type.
13, Additional Provision:
law, or any breach of any contract, express or implied, or
oth parties, if asked, will state that CARROLLYN
BRADY and the TREASURER separated amicably and on mutually acceptable terms. Itis the
preference of CARROLLYN BRADY|
remain confidential and the parties mu
confidentiality over any alleged unlaw/
performance by CAROLLYN BRAD’
past, present, and potentially future sh
mentioning CARROLYN BRADY'S
terms of this provision are bargained-f¢
that any allegations concerning employment practices
tually agree not to disparage the other and to maintain
ful employment actions or any alleged lack of
|. The parties agree that the TREASURER can discuss
ricomings in the Treasurer's Office in general, without
lame or her position. The parties further agree that the
9, and consideration has been provided for the same.
CARROLLYN BRADY agrees to provide reasonable transiton assistance to the
Treasurer's Office prior to her departu
log-in and acess information, passwor
including, but not limited to, providing all computer
is, standard operating procedures, and the like. THE
‘TREASURER has prepared and the Patties have exchanged via counsel a list of requested
transition items after the execution of
e contract for CARROLLYN BRADY to use her
reasonable efforts to complete within normal working hours on or before May 1, 2023. Said
work may completed in the office or remotely. All communication related thereto shall be
through the deputy assistant Treasurer,
14, Knowing and Voluntat
Agreement that they have read and und
fy. Alll Parties acknowledge and agree by signing this
ferstand this document and the consequences of signing it.
All Patties further acknowledge and agree that they have entered into this Agreement voluntarily
and knowingly, after opportunity to consult with legal counsel of their choice, and that no
61Pagerepresentations or inducements have been made to her except as set forth herein. CARROLLYN
BRADY acknowledges and agrees pu
she has been given twenty-one (21) dal
understands the terms of this Agreeme
has the right, within seven (7) days of
written notice to the Kane County Stat
100 S. Third Street, Fourth Floor, Gen}
15,
parties with respect to the subject matt
agreements, commitments and writing
‘modified in any manner except by an i
trument shall be construed as a wh
hereto.
16. Choice of Law, Venue,
this Agreement shall be governed by I
suant to the ADEA and the Workplace Transparency Act
sto review and consider this Agreement, she fully
and the General Release, and their legal effect, and she
igning this Agreement, to revoke the same by delivering
C Attorney's Office, ATTN: Chief of the Civil Division,
a, TL 60134.
Entire Agreement. This instrument contains the entire agreement between the
+ hereof, and supersedes and cancels all previous
between the parties. This instrument may not be
trument in writing signed by the parties hereto. This
and not strictly for or against any one of the parties
Interpretations and Severability. All Parties agree that
linois law. Venue shall lie in Kane County, Illinois or in
the Northern District of Illinois, Eastemn Division, as applicable. CARROLLYN BRADY and
the TREASURER further agree that this Agreement shall not be construed against any party on
account of authorship and, ifa court fi
\ds any part of this Agreement to be illegal or invalid, the
illegal or invalid portion of the Agreement shall be severed, and the rest of the Agreement will be
enforceable.
17. Attorney's Fees and Ci
costs, expenses and attorneys’ fees.
sts, Each party shall be responsible for its respective
7\Page18. Binding Effect on Ott
the benefit of each of the parties here
jers. This Agreement shall be binding upon and inure to
>, and their respective affiliates, legal representatives,
estates, successors, assigns, heirs, administrators, personal representatives and executors,
19, Execution in Counterparts. This Agreement, consisting of seven (7) pages, may
bbe executed in separate counterparts ahd have the same force and effect as if the parties had
executed it as a single document.
20, Severability. Ifany of
ithe provisions of this Agreement are held by a court of
competent jurisdiction to be invalid, void, or otherwise unenforceable, the remaining provisions
shall nonetheless continue in full force and effect without being impaired or invalidated in any
way.
[PageNOTICE: YOU MAY CONSULT WITH AN ATTORNEY OF YOUR CHOICE
[ERAL RELEASE AGREEMENT.
PRIOR TO SIGNING THIS SEPARATION AND G
YOU WAIVE IMPORTANT LEGAL RIGHTS.
CARROLLYN BRADY
KANE COUNTY TREASU
Christopher Lauzen
-46-23
Date ¢ Date:_0
Christopher Lauzen, Individually
Date: eatenExhibit A
urer’s Letterhead)
May 1, 2023
To Whom It May Concern:
rer’s Office from
This letter is to verify Carrollyn Brady was employed by the Kane County ‘Trea
October 17, 2005 to May 1, 2023 as the Director of Financial Operations.
On behalf of Kane County, we wish her success in her future endeavors
rsiopher Lauzen
Kane County Treasurer