HomeMy WebLinkAboutContracts & Agreements_47-2003_CCv0001.pdf GENERAL AND SPECIAL RELEASE AND SETTLEMENT AGREEMENT
This General and Special Release and Settlement Agreement (hereinafter referred to as
"Agreement") is between the City of Redlands ("City") and Bonnie J. Johnson ("Johnson").
WHEREAS City and Johnson wish to agree upon her resignation with a severance: and
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WHEREAS the City and Johnson wish to finally settle and resolve all grievances, disputes.
controversies, claims and actions between them in order to make their peace and avoid the
uncertainties of any litigation, investigation or review, and the expenses and costs incident thereto.
NOW,THEREFORE, City and Johnson covenant and agree as follows:
I Johnson submits her resignation and City accepts it effective March 18, 2003.
2City agrees to pay Johnson the equivalent of three-months salary($25.710) as a full
and final settlement of all matters resolved by this Agreement upon full execution of this Agreement
and approval by the City Council. Johnson will be responsible for paying any and all taxes
associated with this Settlement Agreement. Nothinc, herein shall affect Johnson's right to receive
any salary due her through March 18,2003 or to receive any payment for accrued benefits provided
for by City personnel rules or agreement with the management employees.
3. Johnson does hereby and forever release and discharge City, and any past and/or
present affiliated entities, as well as all direct or indirect successors, officers, officials, directors,
heirs,predecessors,assigns,agents,insurers,employees,attorneys and representatives,and each of
them, past and present, from any and all causes of action, actions,judgments, liens, indebtedness.
damages, losses, claims, liabilities, and demands of whatsoever kind or character, known or
unknown,suspected to exist or not suspected to exist, anticipated or not anticipated,whether or not
heretofore brought before any state or federal court or before any state or federal agency or other
governmental entity, and from all claims arising from or related or attributable to Johnson's
employment with the City and/or her resignation and from any grievance or other dispute between
the parties whenever such claims may have occurred. This release and discharge includes,but is not
limited to, any claims Johnson may have for wrongful termination, discrimination under state fair
employment laws or federal law, harassment, emotional distress, violation of constitutional, civil
or statutory rights and claims for attorneys' fees and costs.
4. Johnson understands that this Agreement extends to all grievances,disputes or claims
of every nature and kind, known or unknown, suspected or unsuspected, past, present or future,
arising from or attributable to the above-referred matters and disputes. Johnson understands and
expressly agrees that this Agreement also extends to any other matter,event or claim occurring prior
to the date of execution of this Agreement. Johnson further acknowledges that any and all rights
granted her under Section 1542 of the California Civil Code,or any other analogous federal or state
law or regulation,are hereby expressly waived. Said Section 1542 of the California Civil Code reads
as follows:
SECTION 1542. CERTAIN CLAIMS AFFECTED BY GENERAL RELEASE. A
GENERAL RELEASE DOES NOT EXTEND TO CLAIMS WHICH THE CREDITOR
DOES NOT KNOW OR SUSPECT TO EXIST IN HIS FAVOR AT THE TIME OF
EXECUTING THE RELEASE, WHICH IF KNOWN BY HIM MUST HAVE
MATERIALLY AFFECTED HIS SETTLEMENT WITH THE DEBTOR.
Cal. Civil Code Section 1542.
5. Johnson understands and expressly agrees that this Agreement shall bind and benefit
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her spouse, children, heirs, agents, attorneys, representatives and assigns.
6. Johnson covenants not to sue or participate in any legal action or proceeding against
the City or any person or entity described in this Agreement under any policy, contract, law or
regulation, federal, state or local, pertaining in any manner whatsoever to the subject of these
disputes.including,but not limited to.Johnson's employment and resignation and any rights she may
have under any policy, or local, state or federal statute, law or regulation.
7. Each party acknowledges that he or it has carefully read this Agreement and has been
advised fully of the legal and binding effect of its terms. Each party acknowledges that the only
promises made to induce her or it to sign this Agreement are those stated herein. Having been fully
advised and informed,each party voluntarily enters into this Agreement and/or the waiver of rights
covered by this Agreement.
8. Johnson agrees that she shall not make any disparaging comments or reports about
the City, the City Council or any of its members, the City Manager or any other City Department
Head. City agrees that it shall provide Johnson with a letter of reference,a copy of which is attached
to this Agreement. If City receives inquiries about Johnson,it will provide dates of employment and
position held unless Johnson has provided to the City a written release to provide other information
or the City is otherwise compelled by law. Neither City Council nor any City management employee
shall make any disparaging comments or reports about Johnson.
9. Each party understands, acknowledges, and agrees that this is a compromise
settlement of a disputed claim or disputed claims, and that nothing herein shall be deemed or
construed at any time or for any purpose as an admission of the merits of any claim or defense.
10. No waiver of any party of any breach of any term or provision of this Agreement shall
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be construed to be.nor be, a waiver of any preceding. concurrent or succeeding breach of the same.
or any other term or provision thereof. No waiver shall be binding unless in writing and signed by
the party or individual to be charged or held bound.
11. Should any provision of this Agreement be declared or determined by any court to
be illegal or invalid. the validity of the remaining parts. terms or provisions shall not be affected
thereby and said illegal or invalid part, term or provisions shall be deemed not to be a part of this
Agreement. The parties agree that this Agreement was reviewed by counsel for both parties and
shall be construed without regard to who drafted the language.
12. This Agreement sets forth the entire agreement between the parties hereto regarding
the subject matter hereof.
DATED: Iiµ l 2003
Bonnie yJvKnson
DATED: 2003 CITY OF REDLANDS
By
KarlN. "Kaley" Haws
Mayor
THIS AGREEMENT IS SUBJECT TO CITY COUNCIL APPROVAL(PENDING)
APPROVED: DATE: MARCH 18,'200-
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City of Redlands
City Manager
John Davidson
March 18, 2003
To Whom It May Concern:
This letter is being written as an employment reference for Bonnie Johnson.
Ms. Johnson was employed with the City of Redlands as the City's Finance
Director from December 1, 1997 to March 18, 2003. During the past two and
one half years that I have been the Redlands City Manager, she has proven
herself to be a dedicated employee with strong leadership skills, high standards
and sound ethics. She has also demonstrated the ability to make decisions in a
timely manner and be creative. In addition, Ms. Johnson has been asked to be
the Acting City Manager during my absence a number of times over the past
couple of years.
Ms. Johnson would make a major addition to any team. Please feel free to
contact our Personnel Services Office at (909) 798-7514 if you have any further
questions concerning her employment.
Sincerely,
6OH
DAVID ON
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"Preserving the Past, Protecting the Future"
P.Q. Box 3005,Redlands, CA 92373-1505 (909)798-7510 FAX(909)791-7503
information or evaluation is needed. Motion seconded by Councilmember
Harrison and carried by AYE votes of all present.
Variance No. 645 - Councilmember George moved to approve Variance
No. 645 subject to the findings and conditions of approval contained in the
staff report. Motion seconded by Councilmember Harrison and carried by
AYE votes of all present.
Commission Review and.. Approval No. 746 - Councilmember George
moved to approve Commission Review and Approval No. 746 subject to the
findings and conditions of approval contained in the staff report. Motion
seconded by Councilmember Harrison and carried by AYE votes of all
present.
PUBLIC COMMENTS
None forthcoming
CLOSED SESSION
The City Council meeting recessed at 8:50 P.M. to a the Redevelopment
Agency meeting and reconvened at 8:53 P.M. at which time Mayor Pro Tern
Susan Peppler was present. The meeting recessed to a closed session to discuss
the following:
1. Conference with legal counsel: Anticipated litigation - Government Code
Section 54956.9(b) - one case
The City Council meeting reconvened at 9:27 P.M.
ANNOUNCEMENT
Settlement Agreement - Bonnie Johnson - City Attorney McHugh
announced the City Council, by unanimous vote, approved a General and
Special Release and Settlement Agreement with Bonnie Johnson, the
former Finance Director; Ms. Johnson submitted her resignation effective
March 18, 2003.
ADJOURNMENT
There being no further business, the City Council meeting adjourned at
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9:29 P.M. The next regular meeting will be held on April 1, 2003.
City Clerk
March 18, 2003
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