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SETTLEMENT AND RELEASE AGREEMENT
<br />THIS AGREEMENT is made and entered into this 3rd day of January 2022, by and
<br />between the City of Everett (the "City"), a local government entity, and Jason Anderson ("Mr.
<br />Anderson").
<br />RECITALS:
<br />WHEREAS, Mr. Anderson was employed by the City's fire department in the position of
<br />paramedic; and
<br />WHEREAS, on November 15, 2021, the City medically separated Mr. Anderson's employment;
<br />and
<br />WHEREAS, Mr. Anderson filed a lawsuit against the City for alleged race discrimination,
<br />harassment, and retaliation; and
<br />WHEREAS, Mr. Anderson is represented by Jamal Whitehead, Esq. of Schroeter Goldmark &
<br />Bender; and
<br />WHEREAS, at a mediation on January 3, 2022, Mr. Anderson and the City have agreed to settle
<br />and compromise any claims Mr. Anderson has against the City; and
<br />WHEREAS, Mr. Anderson acknowledges that this agreement is subject to approval by a majority
<br />of the city council in an open public meeting, and if such approval is not given, the agreement is
<br />null and void; and
<br />NOW THEREFORE, Mr. Anderson and the City mutually agree as follows:
<br />TERMS:
<br />1. The sum of three hundred seventy five thousand dollars ($375,000.00) (hereinafter,
<br />"Total Settlement Amount") shall be paid to Mr. Anderson if he signs this Agreement. Mr. Anderson
<br />agrees that payment of the $375,000 (Three Hundred and Seventy -Five Thousand Dollars and zero
<br />cents) for general damages, including claimed physical manifestations of emotional distress and
<br />physical sickness, as well as attorneys' fees and costs shall be made by check payable to "Trust
<br />Account of Schroeter Goldmark & Bender in trust for Jason Anderson" and delivered to Jamal
<br />Whitehead within fourteen (14) calendar days of the City Council's approval of this settlement
<br />agreement.
<br />2. In exchange for the consideration set forth in Paragraph 1, Mr. Anderson forever
<br />releases and discharges the City, its past and present council members, officers, employees, attorneys,
<br />agents, affiliates, assigns and successors, and any other person acting on the City behalf,
<br />("Releasees"), from any and all claims, whether known or unknown, suspected or unsuspected,
<br />arising out of Mr. Anderson's employment with the City or separation therefrom, or arising on or
<br />before the date of this Agreement. This release shall include any claims arising under any federal,
<br />state, or local law prohibiting discrimination, harassment, or retaliation in employment, as well as any
<br />claims for breach of contract, defamation, FMLA interference, violations of RCW 42.56, unpaid
<br />wages, salary, bonuses, or other sums, emotional distress, personal injury, attorneys' fees, or any other
<br />statutory or common law claims.
<br />3. It is further understood that Mr. Anderson agrees to indemnify and hold harmless the
<br />SETTLEMENT AND RELEASE AGREEMENT
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