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SETTLEMENT AGREEMENT
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TWCCRD Charge No.: I A 18798
EEOC Charge No.: 31 C-2018-00694C
COMPLAINANT: Edward Ramirez
RESPONDENT: CITY OF PORT WORTH
1. In exchange for the promises made by CI'T'Y OF FORT WORTH, hereinafter referred to as the
"Respondent", contained in this Agreement, Edward Ramirez, hereinafter referred to as the
"Complainant," agrees:
A. Not to institute a lawsuit under the Texas Commission on Human Rights
Act, as amended, Title VII of the Civil Rights Act of 1964, as amended, the
Age Discrimination in Employment Act, or the Americans with Disabilities
Act, as amended, based on the complaint number(s) referenced above and
filed with the Texas Workforce Commission's Civil Rights Division and the
U.S. Equal Employment Opportunity Commission. Complainant releases all
claims that he has brought, or could have brought, against Respondent, its
employees, agents, and officers under the "Texas Commission on Human
Rights Act, as amended, Title VII of the Civil Rights Act of 1964, as
amended, the Age Discrimination in Employment Act, or the Americans
with Disabilities Act,as amended
B. Complainant agrees that submission of this Settlement Agreement will
constitute a request for closure of the Texas Workforce Commission Civil
Rights Division Complaint No. I A 18798 and the U.S. Equal Employment
Opportunity Commission Complaint No. 31 C-2018-00694C. Complainant
agrees to execute and submit to the Texas Workforce Commission Civil
Rights Division and the U.S. Equal Employment Opportunity Commission a
Request for Withdrawal of Charge of Discrimination form. If the U.S. Equal
Employment Opportunity Commission or the Texas Workforce Commission
Civil Rights Division refuses to withdraw or dismiss any pending charge and
pursues a claim for damages, injunctive relief, or other relief on his behalf,
Complainant agrees to waive or forego his right to receive such damages or
relief.
2. In exchange for the above promises of lite Complainant, above, the Respondent agrees to:
A. Restore 150 hours of Complainant's accrued work leave. The hours will
be divided and restored as follows: 86.5 hours will be restored to
Complainant's Major Medical Sick Leave pool, 57 hours will be restored to
Complainant's Vacation Leave pool, and 6.5 hours will be restored to
Complainant's Sick Leave pool. All 150 hours will be restored to the
picviously-relcreneed leave pools within seven (7) days after the execution
of this settlement agreement.
OFFICIAL RECORD
Piwe ff i CITY SECRETARY
TWCCit) If i A 18798; EEOC a31 C-2018-00694C Ir'1'.WOR'1''11TX
3. The parties each agree that neither they, nor their representatives, will disparage the other
party. Disparage as used herein shall mean any communication, oral or written, of false
information or the communication of inforniation with reckless disregard to its truth or
falsity. Respondent also agrees that it shall not make any statements, either internally or
externally, that reflect adversely on the Complainant's job performance, other than in the
regular course of business. This promise includes, but is not limited to, refraining from
publication of negative or disparaging remarks on the Internet or in any other media.
Providing truthful and non-malicious testimony under a lawful subpoena is not a violation of
this clause. For Respondent, this non-disparagement obligation is limited to management-
level employees.
4. It is understood that this Agreement does not constitute an admission by the Respondent of
any violation of Title VII of the Civil Rights Act of 1964, as amended, the Age
Discrimination in Employment Act, the Americans with Disabilities Act, or the Texas
Commission on Human Rights Act, as amended.
S. The Complainant and the Respondent agree that this Agreement may be used as evidence in
a subsequent proceeding in which any of the parties allege a breach of this Agreement.
6. Should any provision be determined to be invalid, it is agreed that such determination shall
not affect the enforceability of other provisions herein. Texas law shall govern the validity
and interpretation of this Agreement. The parties stipulate that jurisdiction and venue shall
be in the district courts of Tarrant County, Texas, for any action involving the validity,
interpretation, or enforcement of this Agreement, or for any claim for breach of this
Agreement, for damages, or for any other relief brought under this Agreement.
7. The provisions of this Settlement Agreement will be held in strictest confidence by
Complainant and the Respondent, to the extent allowed by law, and will not be publicized
or disclosed in any manner whatsoever;provided however, that: (a) the Complainant may
disclose this Agreement to his spouse; (b) the parties may disclose this Agreement in
confidence to their respective attorneys, accountants, auditors, tax preparers, and
Financial advisors; (c) the Respondent may disclose this Agreement as necessary to fulfill
standard or legally required corporate reporting or disclosure requirements; and (d) the
parties may disclose this Agreement insofar as such disclosure may be necessary to
enforce its terms or as otherwise required by law. The Parties acknowledge that a
violation of this covenant would constitute a material breach of this Agreement. The
Complainant or Respondent is to reply with the following statement, if asked by anyone:
"The Dispute was resolved to the parties' satisfaction." Complainant understands that
Respondent is a public entity and is required to comply with the Texas Public
Information Act, Texas Government Code Chapter 552.
S. This Agreement may be executed in counterpart facsimile signatures and all such
counterparts shall constitute a single form of this Agreement.
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TWCCRD 111 A 18798; EEOC 1131 C-2018-00694C
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'OMPLAI� Iv DATE,
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RESPONDENT DATE
JAY Cl IAPA,ASSISTANT CITY MANAGER
CITY OF FORT WORTI
APPROVED AS TO FORM AND LEGALITY
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SENIOR ASSISTANTCITY ATTORNEY
ATTEST:
ARY KA R T SE ZETA.RY DATE
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[OFFICIAL RECORD
CITY aI1CRETARY
FT.WORTHO TX
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TWCOM NOA18798; FLOC 43IC•2018-00694C
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Contract Compliance Manager:
By signing, I acknowledge that I am the
person responsible for the monitoring and
administration of this contract, including
ensuring all performance and reporting
requirements
By:
Name: Christopher A. Troutt
Title: Senior Assistant City Attorney
Date: June 20, 2018
OFFICIAL RECORD
CITY SECRETARY
Ira WORTH,TX