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This is a sample Settlement Agreement from the U.S. Department of Air Force

EEO Settlement Agreement

U.S. Equal Employment Opportunity Commission
Philadelphia District Office
                       

__________________,   )
)
Complainant   ) EEOC Complaint No.
) _______________
)
V. )
)
)
F. Whitten Peters, Acting Secretary, ) Agency Case No.
Department of the Air Force, ) _________________
)
  Agency   )

Negotiated Settlement Agreement

In exchange for the mutual consideration set forth below, the Agency, The United States Air Force, and the Complainant, ___________________, amicably agree to resolve this matter as follows:

  1. The Complainant,_____________, in exchange for the promises of the Agency contained in paragraph 2 of this Agreement, hereby agrees freely without fear of coercion or intimidation to:
    1. Withdraw her informal/formal EEO complaint, Base Docket No. ____________, dated ______________ and release the government, the Agency, its employees, in both their official and individual capacities, from any and all liability, claims, causes of action, etc., resulting from or relating to, in any manner whatsoever, the subject matter of this settlement, and her employment with the Agency, this agreement being a complete accord and satisfaction of any and all claims, including any and all equitable and legal relief, e.g., back pay, attorney fees and costs, compensatory and consequential damages, etc.
    2. Not file a formal complaint of discrimination or to institute a lawsuit under the Civil Rights Act of 1964, Title VII, as amended, which prohibits discrimination in employment based on race, color, national origin, religion or sex, or under the Age Discrimination in Employment Act of 1967 (ADEA), which prohibits age discrimination in employment, or under the United States Constitution, or any other state or federal law prohibiting employment discrimination.
  2. In exchange for the promises of the Complainant contained in paragraph 1 of this Agreement, the Agency hereby agrees that:
    1. Annual Leave of ___ hours and Sick Leave of ____ hours will be restored to the complainant for the pay periods of ___________________.
    2. Complainant will be placed in the next available vacant GS-05 position for which the complainant is fully qualified. Until such a vacant position becomes available, complainant will continue on official detail working in the _________________.
    3. Agency agrees to pay the complainant the sum of $______ dollars in monetary compensation.
  3. In addition, the parties mutually agree to the following terms:
    1. The terms of this Agreement are binding and will not establish any precedent, nor will this agreement be used as a basis by the complainant or any representative organization to seek or justify similar terms in any subsequent case.
    2. The parties agree that the facts of this negotiated settlement agreement and all terms contained herein shall be kept confidential, and parties agree not to disclose or discuss the fact of settlement with other agency employees (except complainant's representative or responsible management personnel).
    3. This Agreement constitutes the complete understanding between the complainant and the Agency. No other promises or agreements will be binding unless signed by both parties.
    4. The parties agree that this agreement may be used as evidence in a subsequent proceeding in which either of the parties alleges a breach of the Agreement.
    5. This Agreement does not constitute an admission by the Agency of any violation of Title VII of the Civil Rights Act of 1964, as amended, the United States Constitution, or any other federal or state statue or regulation.
    6. All parties have entered into this agreement voluntarily and with a complete and thorough understanding of its terms.
  4. If the Complainant believes the Agency has not complied with the terms of this settlement agreement, she may, under 29 C.F.R. 1614.504, notify the Chief of Equal Employment Opportunity in writing within 30 days of the date of the alleged violation.

_________________________________   ______________________________
Complainant   Agency Management Representative


Date: ____________________________ Date: ______________________

This agreement is subject to final review and approval by appropriate Air Force Personnel.