|
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
<br /> Page 1 of 3
<br /> 4368-030555 744406x
<br />
|