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This is a sample Settlement Agreement from the U.S. Department of Interior - Bureau of Reclamation

Settlement Agreement

This Settlement Agreement (hereinafter "Agreement") is made and entered into voluntarily between Mr./Mrs. XXXXX XXXXXXXX, an employee of the Bureau of Reclamation, and the Bureau of Reclamation (Reclamation), U.S. Department of the Interior (DOI). Mr./Mrs. XXXXXXXX and Reclamation are collectively referred to herein as "the parties." Accordingly, under the authority of Title VII of the Civil Rights Act of 1964 and the Civil Rights Act of 1991, Reclamation and Mr./Mrs. XXXXXXXX each agrees to the following actions.

  1. Reclamation agrees to:
    1. Compensate Mr./Mrs. XXXXXXX in a reasonable amount (not to exceed $XXXX) as supported by records and acceptable evidence provided by Mr./Mrs. XXXXXXXX.
    2. Pay such compensation within 60 calendar days of the date on which Mr./Mrs. XXXXXXXX submits the appropriate evidence for pecuniary and other compensatory damages to Reclamation.
    3. Pay reasonable attorney fees, not to exceed $XXXX. A verified statement of attorney costs/fees/time shall be submitted to Reclamation within 15 calendar days of the date this Agreement is signed by all parties. The amount of fees or costs to be awarded shall be determined by the Solicitor's Office, DOI.
    4. Reassign Mr./Mrs. XXXXXXXX to the Region, at the same grade and pay she/he now receives, within 15 days of the date on which this agreement is signed by the parties.
  2. Mr./Mrs. XXXXXXXX agrees to:
    1. Submit all requested documents, records, statements, and other evidence related to his/her claim for compensation to Reclamation within 30 calendar days of the date on which this agreement is signed by the parties.
    2. Submit all required paperwork to retire or resign from Reclamation no later than 2 full years after this agreement is signed by all the parties.
    3. Submit to Reclamation, no later than 15 calendar days after this agreement is signed by all parties, a verified statement of attorney costs/fees/time.
    4. Withdraw all complaints currently pending with Reclamation and/or DOI, and waive any and all rights to pursue complaints, claims, appeals, and grievances against Reclamation and/or DOI and/or its employees on any matter relating to his/her employment with Reclamation which occurred prior to the date on which this Agreement is signed by the parties. His/her signature on this Agreement constitutes a voluntary withdrawal of Mr./Mrs. XXXXXXXX's formal EEO complaints WBR-97-XXX and WBR-98XXX.
    5. Initiate action to withdraw any other grievances or appellate or complaint actions related to employment with Reclamation initiated prior to signing this agreement and not initiate any further complaints, grievances, or appellate actions, either administrative or judicially, on any action of Reclamation or DOI or its employees prior to the date this Agreement is signed by the principals.
    6. Acknowledge she/he has been advised of his/her right to, and the advisability of, seeking legal counsel prior to executing this Agreement, and has been given adequate time to do so.
  3. All parties agree to the following:
    1. This Agreement does not constitute an admission by Reclamation, DOI, or the employee that there has or has not been a violation of any law or regulation.
    2. The terms of this Agreement will not establish any precedent nor will the Agreement be used as a basis by Reclamation, DOI, Mr./Mrs. XXXXXXXX, or any representative organization to seek or justify similar terms in any subsequent case.
    3. This Agreement constitutes the complete understanding between Mr./Mrs. XXXXXXXX and Reclamation. No other promises or agreements shall be binding unless in writing and signed by both parties.
    4. This Agreement may be used as evidence in a subsequent proceeding in which either of the parties alleges a breach of the Agreement.
    5. Signature on this document is voluntary and is done without coercion, duress, or pressure on the part of either party.
    6. The parties agree that this Agreement is valid and legal to the best of their knowledge and that the validity or legality of this agreement will not be challenged through any forum, either administrative or judicial.
    7. If the actions identified above are not carried out as specified, or if they are in any way rescinded, then Mr./Mrs. XXXXXXXX may, in accordance with 29 C.F.R. 1614.504, petition DOI to implement the terms of this Agreement or to reopen the complaint for further processing from the point processing ceased under the terms of this Agreement. This request shall be made in writing to the Director, Office for Equal Opportunity, U.S. Department of the Interior, within 30 days of when Mr./Mrs. XXXXXXXX knew or should have known of the alleged noncompliance. The parties further agree that if Mr./Mrs. XXXXXXXX fails to pursue the commitments made herein for any reason not attributable to acts of Reclamation, Reclamation shall be relieved of its obligations, and it may take actions to revoke any or all items agreed to above.
____________________________                      __________
Mr./Mrs. XXXXX XXXXXXXX, Date
Employee

____________________________ __________
XXXX XXXXX,   Date
Acting Asst. Director, Policy,
Budget and Administration


Technical Review:


____________________________ __________
XXXXXXX XXXXXXX,   Date
Equal Employment Manager


____________________________ __________
XXXXXXX XXXXXXX, Date
Personnel Director