Settlement Agreement Language Review

my client is only willing to sign a settlement agreement to release claims related ONLY to the EEOC charge, based on this information, act as my co-counsel and red line any blanket agreement language in this document "*. In exchange for the promises made by the Respondent pursuant to Charge Numbers *-*, the Charging Party agrees not to institute a lawsuit under Title VIl of the Civil Rights Act of *, as amended. *. Further we agree that submission of this agreement to EEOC will constitute a request for closure of EEOC Charge Numbers *-*-* and any dual-filed charge with the applicable State or Local Fair Employment Practices Agency. *. It is understood that this agreement does not constitute an admission by Respondent of any violation of Title VIl of the Civil Rights Act of *, as amended. *. Respondent agrees that there shall be no discrimination or retaliation of any kind against Charging Party because of filing this charge or against any person because of opposition to any practice deemed illegal under Title VIl, the ADA, EPA, or the ADEA, as a result of filing this charge, or for giving testimony, assistance or participating in any manner in an investigation, proceeding or a hearing under the aforementioned Acts. *. This document constitutes a final and complete statement of the agreement between the Charging Party, Respondent and EEOC. The parties acknowledge that the Charging Party and Respondent will enter into a Supplemental Agreement. The parties also acknowledge that EEOC will not enforce any provision(s) of a Supplemental Agreement. *. The parties agree that the EEOC is authorized to investigate compliance with this agreement including confirmation that Charging Party was paid all monies under this Agreement and that this agreement may be specifically enforced in court by the EEOC or the parties and may be used as evidence in a subsequent proceeding in which a breach of this agreement is alleged. 6a. As evidence of a good faith effort to resolve EEOC Charge Number *-*-* Respondent offers, and Charging Party accepts the following proposal of settlement: 6b. Respondent agrees to issue payment to the Charging Party, the total gross sum of Fifteen Thousand Dollars ($*,*.*) less necessary federal and state tax withholdings to be paid directly to the Charging Party. The payment will be paid within 30 days or less Page * of 2my client is only willing to sign a settlement agreement to release claims related ONLY to the EEOC charge, based on this information, act as my co-counsel and red line any blanket agreement language in this document "*. In exchange for the promises made by the Respondent pursuant to Charge Numbers *-*, the Charging Party agrees not to institute a lawsuit under Title VIl of the Civil Rights Act of *, as amended. *. Further we agree that submission of this agreement to EEOC will constitute a request for closure of EEOC Charge Numbers *-*-* and any dual-filed charge with the applicable State or Local Fair Employment Practices Agency. *. It is understood that this agreement does not constitute an admission by Respondent of any violation of Title VIl of the Civil Rights Act of *, as amended. *. Respondent agrees that there shall be no discrimination or retaliation of any kind against Charging Party because of filing this charge or against any person because of opposition to any practice deemed illegal under Title VIl, the ADA, EPA, or the ADEA, as a result of filing this charge, or for giving testimony, assistance or participating in any manner in an investigation, proceeding or a hearing under the aforementioned Acts. *. This document constitutes a final and complete statement of the agreement between the Charging Party, Respondent and EEOC. The parties acknowledge that the Charging Party and Respondent will enter into a Supplemental Agreement. The parties also acknowledge that EEOC will not enforce any provision(s) of a Supplemental Agreement. *. The parties agree that the EEOC is authorized to investigate compliance with this agreement including confirmation that Charging Party was paid all monies under this Agreement and that this agreement may be specifically enforced in court by the EEOC or the parties and may be used as evidence in a subsequent proceeding in which a breach of this agreement is alleged. 6a. As evidence of a good faith effort to resolve EEOC Charge Number *-*-* Respondent offers, and Charging Party accepts the following proposal of settlement: 6b. Respondent agrees to issue payment to the Charging Party, the total gross sum of Fifteen Thousand Dollars ($*,*.*) less necessary federal and state tax withholdings to be paid directly to the Charging Party. The payment will be paid within 30 days or less Page * of * following receipt of the fully executed agreements and shall be reflected on IRS Form W2, as appropriate."

is this language blanket language? *. Further we agree that submission of this agreement to EEOC will constitute a request for closure of EEOC Charge Numbers *-*-* and any dual-filed charge with the applicable State or Local Fair Employment Practices Agency.