CONTRACT PERM - 6294 Other CLOSEDAgreement No. 6294
SEPARATION AND RELEASE AGREEMENT
1. PARTIES
This Separation, Severance and General Release Agreement ("AGREEMENT") is made
and executed as of the last date set forth on the execution page of this Agreement, by
and between Scott Mitnick ("EMPLOYEE") and the CITY OF El Segundo ("CITY").
2. RECITALS
2.1 EMPLOYEE commenced employment with the CITY as City EMPLOYEE on or
about July 1, 2019, pursuant to that EMPLOYMENT AGREEMENT entered into
between the parties on or about June 18, 2019.
2.2 This AGREEMENT is made to amicably resolve all matters between EMPLOYEE
and the CITY regarding EMPLOYEE's employment and the cessation of said
employment.
2.3 The parties understand and agree that a material purpose of this AGREEMENT
is to resolve any disputes and CLAIMS arising from or relating to EMPLOYEE's
employment with CITY, if any, and provide for a separation payment for
EMPLOYEE.
3. CONSIDERATION
3.1 In exchange for EMPLOYEE's execution, faithful performance and compliance
with this AGREEMENT, including without limitation the granting of the releases
set forth herein, and in full satisfaction and settlement of EMPLOYEE's CLAIMS,
if any, the CITY shall pay EMPLOYEE the sum of $130,000 and to pay for City
health, dental, vision and other group insurance to the extent permitted by the
applicable insurance plans and benefit programs for a period of six-month
following the EFFECTIVE DATE of this AGREEMENT("SEVERANCE
PAYMENT").
3.2 EMPLOYEE shall be allowed to keep the cell phone that he used while employed
by the City. CITY copied the information from the cell phone subsequent to
EMPLOYEE's separation from the City. EMPLOYEE has returned the laptop that
he used while employed by the CITY to the CITY and the CITY is providing
EMPLOYEE with a payment in the amount of $1,500. The CITY shall provide a
written, and if possible, an electronic version of the EMPLOYEE's contact list
information to EMPLOYEE from the above referenced cell phone within 5 days
of execution of the Agreement by all parties. EMPLOYEE represents and
warrants that EMPLOYEE did not intentionally: delete any documents that would
Agreement No. 6294
be considered Public Records of the CITY under Government Code Section
6250 et seq.: copy or retain or cause or allow others to copy and/or retain
documents that are considered confidential records of the CITY, including without
limitation confidential personnel records of the City or attorney -client privileged
records for which the CITY was considered the holder of the privilege; from these
electronic devices or any other devices or means.
3.3 CITY shall pay EMPLOYEE for unused vacation and sick leave (353.27 hours)
and vacation time (79.17 hours) in accordance with the provisions of the
EMPLOYMENT AGREEMENT.
3.4 Respecting the SEVERANCE PAYMENT referenced in paragraph 3.1 above,
laptop payment referenced in paragraph 3.2 above, and the sick leave time
payment referenced in Section 3.3 above, EMPLOYEE understands and agrees
that the EMPLOYEE's portion of any federal, state or local taxes, if any, that may
be owed or payable on the sums caused to be paid hereunder by the CITY are
the sole and exclusive responsibility of EMPLOYEE and will be deducted from
such payments to the extent required by law. The CITY shall make these three
payments within 15 days of the Effective Date to EMPLOYEE which shall be in
the form of a check or checks made payable to Scott Mitnick.
3.5 EMPLOYEE and the CITY shall otherwise each bear their own attorney fees and
costs incurred in connection with any disputes and this AGREEMENT.
3.6 CITY and EMPLOYEE agree that as of the EFFECTIVE DATE EMPLOYEE shall
be deemed to have resigned on February 2, 2022.
3.7 Except as set forth in this Paragraph 3, the parties agree that no other monies or
benefits are due, owing or unpaid by reason of EMPLOYEE's employment or
association with CITY and that no other monies or benefits will be paid or
maintained by CITY to/for EMPLOYEE, in EMPLOYEE's name, or on
EMPLOYEE's behalf. EMPLOYEE expressly agrees that the SEVERANCE
PAYMENT and other payments described in Paragraph 3 supersedes and is in
substitution for any payments or benefits under any employment agreement(s),
business agreement(s) or arrangement(s), oral or written promises, or severance
policy or plan respecting or regarding his employment or association with CITY.
4. SPECIFIC ACKNOWLEDGEMENT OF WAIVER OF CLAIMS UNDER ADEA AND
OWBPA
The Age Discrimination in Employment Act of 1967, (29 U.S.C. Section 626 et. seq;"
ADEX) makes it illegal for an employer to discharge any individual or otherwise
discriminate with respect to the nature and privileges of an individual' s employment on
the basis that the individual is age forty (40) or older. The Older Workers Benefit
Protection Act ("OWBPA", 29 U. S. C. sections 626, et. seq., Pub. L. 101- 433, 104 Stat.
Agreement No. 6294
978 (1990)) further augments the ADEA and prohibits the waiver of any right or claim
under the ADEA, unless the waiver is knowing and voluntary. By entering into this
AGREEMENT, EMPLOYEE acknowledges that he knowingly and voluntarily, for just
compensation, waives and releases any rights he may have under the ADEA and/ or
OWBPA. EMPLOYEE further acknowledges that he has been advised and
understands, pursuant to the provisions of the ADEA and/or OWBPA, that:
4.1 This waiver/ release is written in a manner understood by EMPLOYEE;
4.2 EMPLOYEE is aware of, and/ or has been advised of, his rights under the ADEA
and OWBPA, and of the legal significance of his waiver of any possible claims he
currently may have under the ADEA, OWBPA and/ or similar age discrimination
laws;
4.3 EMPLOYEE is entitled to a reasonable time of at least twenty-one (21) days
within which to review and consider this AGREEMENT and the waiver and
release of any rights he may have under the ADEA, the OWBPA and similar age
discrimination laws; but may, in the exercise of his own discretion, sign or reject
this AGREEMENT at any time before the expiration of the twenty-one (21) days;
4.4 The waivers and releases set forth in this AGREEMENT shall not apply to any
rights or claims that may arise under the ADEA and/ or OWBPA after the
EFFECTIVE DATE of this AGREEMENT,
4.5 EMPLOYEE has been advised by this writing that he should consult with an
attorney prior to executing this AGREEMENT,
4.6 EMPLOYEE has discussed, or had the opportunity to discuss, this waiver and
release with, and been advised with respect thereto by, his counsel of choice,
and that he does not need any additional time within which to review and
consider this AGREEMENT;
4.7 EMPLOYEE has seven (7) days following his execution of this AGREEMENT
to revoke the AGREEMENT;
4.8 Notice of revocation within the seven ( 7) day revocation period must be
provided, in writing, to the CITY pursuant to this paragraph and must state, "I
hereby revoke my acceptance of our' Separation and Release Agreement," and
4.9 This AGREEMENT shall not be effective until all parties have signed the
AGREEMENT and ten (10) days have passed since EMPLOYEE's execution of
the AGREEMENT (the "EFFECTIVE DATE").
Agreement No. 6294
5. RELEASE
5.1 In exchange for the SEVERANCE PAYMENT, representations and covenants
made herein, and except only as to such rights or claims as may be created by
this AGREEMENT, EMPLOYEE hereby, and for his heirs, representatives,
successors, and assigns, releases, acquits, and forever discharges the CITY,
and all of its agents, officers, current and former elected and appointed officials,
current and former employees, representatives, insurers, attorneys, and all
persons acting by, through, under, or in concert with any of them, and each of
them, from any and all claims, charges, complaints, liabilities, obligations,
promises, benefits, agreements, controversies, costs, losses, debts, expenses,
damages, actions, causes of action, suits, rights, and demands of any nature
whatsoever, known or unknown, suspected or unsuspected, which EMPLOYEE
now has or may acquire in the future, which relate to or arise out of any act,
omission, occurrence, condition, event, transaction, or thing which was done,
omitted to be done, occurred ( including without limitation any circumstance(s)
giving rise to liability for workers compensation benefits) or was in effect at any
time from the beginning of time up to and including the EFFECTIVE DATE of this
AGREEMENT ("CLAIMS"), without regard to whether such CLAIMS arise under
the federal, state or local constitutions, statutes, rules, ordinances or regulations,
workers compensation statutes or the common law. EMPLOYEE expressly
acknowledges that the CLAIMS forever barred by this AGREEMENT specifically
include, but are not limited to, claims related to the DISPUTES, his employment
with the CITY and its cessation, any claims for wages, overtime or benefits, any
alleged breach of any duty, any alleged employment discrimination, harassment,
retaliation or unlawful discriminatory act, any alleged breach of any express or
implied employment contract, breach of any duty arising out of contract, statute,
regulation, ordinance or tort, constructive discharge, wrongful termination or
constructive discharge in violation of public policy, or any claim or cause of action
including, but not limited to, any and all claims whether arising under any federal,
state or local law prohibiting or respecting wrongful termination, breach of
employment contract, or employment discrimination, employee injury, death,
wrongful hiring, harassment or retaliation based upon sex, race, age, color,
religion, handicap or disability, national origin or any other protected category or
characteristic, including but not limited to the Federal Fair Labor Standards Act,
the California Fair Employment and Housing Act, the Americans With Disabilities
Act, Title VII of the Civil Rights Act of 1964, and any other federal, state, or local
human rights, civil rights, or employment discrimination or employee rights
statute, rule, regulation, ordinance or decisional law.
5.2 Additionally, the CITY hereby agrees not to initiate, or proceed with any actions,
causes of action, or claims, etc., that could be or that have been asserted against
EMPLOYEE arising out of EMPLOYEE's employment with the CITY, in any
forum, whatsoever. To the extent that any such actions, causes of action, or
claims, etc., are, or become pending in any forum whatsoever, the CITY agrees
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to execute all documents necessary for the withdrawal of such actions, causes of
action, claims, with prejudice, forthwith.
6. UNKNOWN CLAIMS
6.1 EMPLOYEE on the one hand, and the CITY, on the other hand, each hereby
waive and release any rights which the other and its successors, heirs,
executives, administrators, may have directly or indirectly, if any, jointly or
severally, directly or indirectly, under the provisions of California Civil Code
section 1542, and any similar state or federal statute, which reads in sum,
substance or substantial part as follows:
A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS WHICH THE
CREDITOR OR RELEASING PARTY DOES NOT KNOW OR SUSPECT
TO EXIST IN HIS OR HER FAVOR AT THE TIME OF EXECUTING THE
RELEASE, WHICH IF KNOWN BY HIM OR HER WOULD HAVE
MATERIALLY AFFECTED HIS OR HER SETTLEMENT WITH THE
DEBTOR OR RELEASED PARTY.
A general release does not extend to claims that the creditor or releasing party does not know or
suspect to exist in his or her favor at the time of executing the release and that, if known by him
or her, would have materially affected his or her settlement with the debtor or released parry.
6.2 EMPLOYEE and the CITY acknowledge that the facts with respect to which each
gives this GENERAL RELEASE may turn out to be different from the facts they
now believe to be true. EMPLOYEE and the CITY hereby assume the risk of the
facts turning out to be different, and agree that this AGREEMENT shall in all
respects be effective and not subject to termination or rescission because of any
such difference in facts.
7. WAIVER OF ADDITIONAL CLAIMS
EMPLOYEE and the CITY hereby waive any provisions of state or federal law that
might require a more detailed specification of the claims being released pursuant
hereto.
8. REPRESENTATIONS AND WARRANTIES
Each of the parties to this AGREEMENT represent and warrant and agree with each
other party as follows:
8.1 No Other Claims: EMPLOYEE and the CITY hereby represent and warrant that
neither EMPLOYEE nor the CITY has filed, nor will they file in the future, any
complaint, charge, claim, legal action, or proceeding arising out of EMPLOYEE's
employment with the CITY, the DISPUTES or the CLAIMS released hereby or in
Agreement No. 6294
any way related to his employment with the CITY or separation therefrom with
any court, agency, board, hearing officer or tribunal against the CITY or any of its
agents, officers, current and former elected or appointed officials, current and
former employees, representatives, insurers, attorneys, and all persons acting
by, through, under, or in concert with any of them. EMPLOYEE retains his right to
request indemnification from the City pursuant to California Government Code
Section 825 et seq. with respect to any action brought against EMPLOYEE in his
capacity as an employee.
8.2 Advice of Counsel: Each party has received, or has had the opportunity to
receive, independent legal advice from their respective attorney(s) with respect to
the advisability of making the settlement and releases provided herein, with
respect to the advisability of executing this AGREEMENT, and with respect to the
meaning of California Civil Code section 1542.
8.3 No Fraud in Inducement: No party ( nor any officer, agent, employee,
representative, or attorney of or for any party) has made any statement or
representation or failed to make any statement or representation to any other
party regarding any fact relied upon in entering into this AGREEMENT, and
neither party relies upon any statement, representation, omission or promise of
any other party ( or of any officer, agent, employee, representative, or attorney of
or for any party) in executing this AGREEMENT, or in making the settlement
provided for herein, except as expressly stated in this AGREEMENT.
8.4 Independent Investigation: Each party to this AGREEMENT has made such
investigation of the facts pertaining to this severance and settlement and this
AGREEMENT and all the mailers pertaining hereto as it deems necessary.
8.5 Comprehension and Authority: Each party or responsible officer thereof has read
this AGREEMENT and understands the contents hereof. Any of the officers
executing this AGREEMENT on behalf of the CITY are empowered to do so and
thereby bind the entity.
8.6 Mistake Waived: In entering into this AGREEMENT and the severance and
settlement provided for herein, each party assumes the risk of any
misrepresentation, concealment or mistake. If any party should subsequently
discover that any fact relied upon by it in entering into this AGREEMENT was
untrue, or that any fact was concealed from it, or that its understanding of the
facts or of the law was incorrect, such party shall not be entitled to rescind or set
aside the AGREEMENT. This AGREEMENT is intended to be and is final and
binding between the parties, regardless of any claims of misrepresentation,
promise made without the intent to perform, concealment of fact, mistake of fact
or law, or any other circumstance whatsoever.
8.7 Later Discovery: EMPLOYEE and the CITY are aware that they may hereafter
discover claims or facts in addition to or different from those they now know or
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believe to be true with respect to the matters related herein. Nevertheless, it is
both parties intention to fully, finally and forever settle and release all such
matters, and all claims relative hereto, which do now exist, may exist or have
previously existed between both parties. In furtherance of such intention, the
releases given here shall be and remain in effect as full and complete releases of
all such matters, notwithstanding the discovery or existence of any additional or
different claims or facts relative thereto.
8.8 Ownership of Claims: EMPLOYEE represents and warrants as a material term of
this AGREEMENT that he has not heretofore assigned, transferred, released or
granted, or purported to assign, transfer, release or grant, any of the CLAIMS
disposed of by this AGREEMENT. In executing this AGREEMENT, EMPLOYEE
further represents and warrants that none of the CLAIMS released by his
hereunder will in the future be assigned, conveyed, or transferred in any fashion
to any other person and/ or entity.
8.9 Future Cooperation: The parties will execute all such further and additional
documents as shall be reasonable or necessary to carry out the provisions of this
AGREEMENT.
9. MISCELLANEOUS
9.1 No Admission: Nothing contained herein shall be construed as an admission by
the parties of any liability of any kind. The parties each deny any liability in
connection with any claim or wrongdoing. Each party also intends hereby solely
to amicably resolve all matters between the parties.
9.2 Governing Law: This AGREEMENT and the rights and obligations of the parties
shall be construed and enforced in accordance with, and governed by, the laws
of the State of California. The venue for any dispute arising out of or relating to
this AGREEMENT shall be the Los Angeles Superior Court.
9.3 Full Integration: This AGREEMENT is the entire agreement between the parties
with respect to the subject matter hereof and supersedes all prior and
contemporaneous oral and written agreements and discussions. This
AGREEMENT may be amended only by a further agreement in writing, signed by
the parties hereto.
9.4 Continuing Benefit: This AGREEMENT is binding upon and shall inure to the
benefit of the parties hereto, their respective agents, employees, representatives,
officers, and officials.
9.5 Joint Drafting: Each party has cooperated in the drafting and preparation of this
AGREEMENT. Hence, in any construction to be made of this AGREEMENT, the
same shall not be construed against any party.
Agreement No. 6294
9.6 Severability: In the event that any term, covenant, condition, provision or
agreement contained in this AGREEMENT is held to be invalid or void by any
court of competent jurisdiction, the invalidity of any such term, covenant,
condition, provision or agreement shall in no way affect any other term, covenant,
condition, provision or agreement and the remainder of this AGREEMENT shall
still be in full force and effect.
9.7 Titles: The titles included in this AGREEMENT are for reference only and are not
part of the terms of this AGREEMENT, nor do they in any way modify the terms
of this AGREEMENT.
9.8 Counterparts: This AGREEMENT may be executed in counterparts, and by
facsimile and when each party has signed and delivered at least one such
counterpart, each counterpart shall be deemed an original, and, when taken
together with other signed counterparts, shall constitute one AGREEMENT,
which shall be binding upon and effective as to all parties.
9.9 Executed Copy: All parties shall receive a fully executed copy of this
AGREEMENT.
9. 10 Notice: Any and all notices given to any party under this AGREEMENT shall be
given as provided in this paragraph. All notices given to either party shall be
made by certified or registered United States mail, overnight delivery by Fed Ex,
UPS or other reliable overnight service, or personal delivery, at the noticing
party's discretion, and addressed to the parties as set forth below. Notices shall
be deemed, for all purposes, to have been given on the date of personal service,
on the date that delivery was made by overnight mail, or three consecutive
calendar days following deposit of the same in the United States mail.
As to EMPLOYEE:
Scot Mitnick
2772 Westham Circle
Thousand Oaks, California 91362
Agreement No. 6294
As to the CITY:
Attn: City Clerk
City of El Segundo
350 Main Street
El Segundo, California 90245
WHEREFORE, the parties hereto have read all of the foregoing, understand the same,
and agree to all of the provisions contained herein.
DATED: 6 -Z CITY OF El SEGUNDO
By:
Drew Boyl ayor
EMPLOYEE
dull � d
Scott Mitnick
ATTEST:
Tracy aver, City Clerk
APP D AS T FO
_.... ram/
Mark H nsley, City Attorney