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269692 WHITE - CITV CLERK jJINK - FINANCE GITY OF SAINT PAITL Council ��i,'��9� � CANAi�,- DEPARTMENT BLUE - fv1AYOR Flle NO. 0rd • nf, Ordinance N 0. �� n � Presented By ` Referred To Committee: Date Out of Committee By Date An ordinance granting compensation to certain applicants for the position of fire- fighter who were legally deemed to have been unlawfully discriminated against by. the City of Saint Paul, in accordance with agreed stipulation between the applicants and the City. • THE COUNCIL OF THE CITY OF SAINT PAUL DOES ORDAIN: Section l. � Action was brought against the City of 5aint Paul by five applicants for the position of firefighter: Thomas Nelson, John Hoffman, Gregory r4unson, Gregory Mayen and PZark Conway, claiming that they were unlawfully discriminated against because of physical disability. The City has reached agreement with these applicants whereby they were appointed to the position of firefighter and were , grante�. certain rights and compensation as settlement for damages. The agreements of Thomas Nelson, John Hoffman, Gregory D4unson, Gregory P�ayen and Mark Conway are attached hereto and made a part hereof. Section 2. The Council hereby approves said agreements and approves the financial settlements and payments contained therein. Section 3. Doctors' bills and wage cash settlements are to be paic� as shown in said agreements from appropriation Account 05120, titled . Fire Fighting in the following amounts: COUNCILMEN Requested by Department of: Yeas Nays Butler Hozza In Favor — Hunt Levine Against BY Roedler Sylvester Tedesco Form A rov d by 'ty Attorney. Adopted by Council: Date � Certified Passed by Council Secretary BY 1 � By Approved by Mayor: Date Appr by Mayor for Sub io to Coun�il � � By By / WHITE - CITV�CLERK �71NK - FINANCE GITY OF SAINT PATTL Council . ��i<9�� CANAF2`�-- DEPARTMENT E � � BLUE - MAVOR Fll@ NO. � � � Ordindnce Ordinance N�. I�� / � Presented By Referred To Committee: Date Out of Committee By Date Mr. Thomas G. Nelson Doctors' bills $595. 60 _Wage cash settlement 8,390. 00 P�Ir. John W. Ho f fman Doctors' bills 240. 00 P�Ir. Gregory Munson � Doctors' bills 197.00 Wage Cash settlement 13,179. 09 Mr. Gregory J. Mayen Doctors' bills 40. 00 Wage cash settlement 11, 750. 00 � Section 4. This ordinance shall take effect thirty (30) days after its passage, approval and publication. -2- Appr d as to nding: �` D rector of inance & Mgmt. Services COUl�1CILMEN Requested by Department of: Yeas Nays • Butler Hozza In Favor Hunt Levine a Against BY Roedler Sylvester �� s�P 2�� 9�� Form prove by Ci ttorney . Adopted by ncil: Date . Certi ' d Pa s y Cou Secretary • .BY Appr ved by Mayor: I�a SEP 2'� �`97T. App ve by Mayor for S i ion,,to Council By By P_UBI.fSHED SEP 2 4 1977 � � " CITY OF SAINT l�gUL � � �,'� . . ' �� . .1� _ vt� �� ( O�'FICE OF THE.CZTY COUNCZL �a,�>�-'' — „;,:•a„�';� � ..,tis�:,- .a�; �o�� ► August 29, 1977 COMMITTEE REPOR�` TO : Saint Paul City Councii F R O M � C o m m i t t e e 0 Cl FINANCE, MANAGEMENT AND PERSONNEL ROSALIE BUTLER , choirman, makes the fai�ovring . report on - C. F. X� fsrdinance (� Resolution [� 4ther � T I T LE � An ordinance granting compensation to certain applicants for the position of firefighter who were legally deemed to have been unlawfully discrimina�ed against by the City of Saint Paul , in accordance with agreed stipulation . between the applicants and the City. . The Committee today considered the above ordinance and recomnended approval . . r � � •l• _. _ � . . .. . -� �. . CITY HALL SEVENTH FLOOR SAINT PAUL, MINNESOTA 55102 �:� �-� ``:;�..r,`j , . . ` ¢ � �� . ��, • y . _ .� 1C�� SETTLEP�IENT AND RELEASE Mr. Thomas G. Nelson having read this codument com- pletely agrees that the provisions contained in this document shall constitute full, complete, and final settlement of his claim of discrimination agains t the City of Saint Paul for failure to appoint him to the _ - position of firefighter. 1. Date that Mr. Nelsori cari commerice actual employment is April 25, 1977. 2. Seniority date he will have - For the purpose of seniority, Mr. Nelson will be considered to be appointed to the Fire Depar tment as of March 24, 1975. - This is the date that he would have been appointed, had he not been rejected. 3. Sick Leave - Mr. Nelsan wi11 accumulate sick leave from March 24, 1975, at th e usual rate set � forth in the Civil Service rules and the collec- tive bargaining contract for the Firefighters' unit. 4. Vacation - He will start earning vacation from April 25, 1977, the date that he actually commences er.�tployment. He will receive no vaca- tion time from .that time prior to April 22, 1977. However, for the purpose of determining how much vacation per year he will receive for any particular year, we will use the date of seniority, March 24, 1975. 5. Insurance - He will be eligible for coverage immedi- ately but must pay for th e first six months of such coverage himself. After that, the City will pay for the insurance pursuant to the pro- visions of the collective bargaining contract for his unit. _ � .. . . . • ; � • 6. Clothing Allowance - Will receive such allowance be- ginning April 22, 1977 . He must buy one uniform himself, as all other firefighters must do. 7. Doctors' Bills - The City will pay jointly to. Mr. Nelson and doctors for the following: � �� TJ r. (.J P!v�J�C�/)-7�°s7 a K o�,y {ec' l<<n � /'irt{�5�,7e r-pc=7�7i.-�.c'.ri� _ �.S U. CTZ� Dr. McCain . . . . . . . . . . . . . . $ 15. 00 Dr. : Clemens . . . . . . . . . . 36.67 _ Dr. Wengler . . . . . . . . . . . . 113. 33 U of Minn. Orthopedic Surgery . . . . . . . . . . . . . . 20 .00 U of Minn. Hospital . . . . . 60. 60 8. Wage Cash Settlement - The City will pay to Mr. Nelson the sum of $8, 390. 00 as full settle- ment for back wages. The City shall notify the Internal Revenue Service of such payment as it is based upon wages. 9. Pension Benefits - The City agrees to make the necessary back payments for pension benefit � G as allowed by law and as would have been made had Mr. Nelson been appointed on March 24, 1975. Mr. Nelson agrees to make the necessary baek payments as allowed by law and that he would have made if he had been appointed on March 24, 1975. Neither party need comply with this pro- vision if the other party does not comply with this provision. � ; 10. Additional Wages Received - Mr. Nelson affirms and states by his signature hereon that he has re- ceived no compensation, wages, weltaxe assis- tance, or aid of any type, during the period from March 24, 1975, to April 25, 1977, other than the salaries, ��ages, or aid made known to the City. � -2- i , , _ _ _ �'\ � • e` ,� �`� • - .4 This agreement is full and final settlement of al is es in dispute. • I {�. . . lo Te ry Sul ivan Thomas G. Nel n �,,o S �� ^l� - dat ate � Georg Latimer Mayor, C ty of Saint Paul date � -3- _ "� a::� � � ' i,� • � . � V .P��V'�V ,•` � ? SETTLEMENT AND RELEASE P�r. John W. Hoffman having read this document completely agrees that the provisians contained in this document shall constitute- full, somplete, and final settlement of his clair.l of discrimination against the City of Saint Paul for failure to appoint him to the position of firefighter. ' 1. Date that Mr. Hoffman can commence actual empZoyment is April 25, 1977. 2. Seniorit� date he will have - For the purpose of seniority, Mr. Hoffman will be considered to be appointed to the Fire Department as of P4arch 24, 1975. This is the date that he would have been appointed, had he not been rejected. 3. Sick Leave - Mr. Hoffman will accumulate sick leave from March 24, 1975, at the usual rate set � forth in the Civil Service rules and the collec- � tive bargaining contract for the Firefighters' unit. 4. Vacation - He will start earning.vacation from April 25, 1977, the date that he actually commences employemnt. He will receive no vaca- � �.ion time from that time prior to April 22, 1977. However, for the purpose of determining how much vacation per year he will receive for any particular year, we will use the date of seniority, March 24, 1975. 5. Insurance - He will be eligib�e for coverage iminedi- ately but must pay for the first six months of sucY�� coverage himseif. After that, the City will pay for the insurance purusant to the pro- visions of the collective bargaining contract : for his unit. \ �... �. � . • , i 6. Clothing Allowance - Will receive such allowance be- ginning April 22, 1977. He must buy one uniform himself, as all other firefighters must do. 7. Doctors' Bills - The City will pay. jointly to ,� Mr. Hoffman and doctors for the following: . � __ � p r. j,v c'a�I��-les7�,�on� �ec'� �zC'%' r,-rP E;f6i>e� �P7�7��-��- 35 � �� Dr. Wengler . . . . . . . . . . . . . $ 83.33 Dr. Thompson . . . . . . . . . . . . 10.00 ` Dr. Clemens . . . . . . . . . . . . . 36.67 University Hospital . . . . . 10. 00 Orthopedic Assn. . . . . . . . . 1QQ. 00 8: Pension Benefits - The City agrees to make the necessary back payments for pension benefit as allowed by law and as would have been made had Mr. Hoffman been appointed on March 24, 1975. Mr. Hoffman agrees to make th e necessary back payments as allowed by law and that he would have made if he had been appointed on March 24, 1975. Nei ther party need comply wi th � this provision if the other party does not com- ply with this provision. 9. Additional Wages Received - Mr. Hoffman affirms and states by his signature hereon that he has re- ceived no compensation, wages, welfare assis- tance, or aid of any type, during the pe 'riod from March 24, 1975, to April 25, 1977, other than the salaries, wages, or aid made known to the City. This agreement is full and final settlement of all issues in dispute. C Te Sullivan John� fman '� ..�- // -.7� da e date n Geo e Latimer P�iayor, ity of Saint Paul date �-2- F � i _ � � � . � _ __._ .__ _. _ . _ _. _---- ___ .__.__- - .� , ___ -- � 8 _ ______ _--,- �st 9/, . - p . /7 2nd O 3rd � /�3 Adopted (� Yeas Nays BUTLER HOZZA {�, HUNT !C L�Q�J� �/ LEVINE � ROEDLER TEDESCO PRESIDENT (SYLVESTER) � _ � __.. � \ �-'.__" - ! . . . � +* �1 _ . .�� ` �� ..��.. , SETTLEMENT AND RELEASE Mr. Gregory Munson having read this document completely agrees that the provisions contained in this document shall constitute full, complete, and final settlement of his claim of discrimination against the City of Saint Paul for failure to appoint him to the position of firefighter. 1. Date that r4r. Munson can commence actual employment is April 25, 1977. 2. Seniority date he will have - For the purpose of seniority, Mr. P4unson will b� considered to be appointed to the Fire De- partment as of r�arch 24 , 1975 . This is the date that he would have been appointed, had he not been rejected. i 3. Sick Leave - Mr. rlunson will acctunulate sick leave from P4arch 24, 1975, at .the usual rate set forth in the Civil Service rules and the collective bargaining contract for the fire- tignters ' unit. i 1 . 4 . Vaction - He will� start earning vaca�ion from April 25, 1977 , the date that. he actually commences employment. He will receive no vacation time from that time prior to April 25 , � 1977. However, for the purnose of determining how much vacation per year he will receive for any particular year , we will use t�e date of seniority, March ?_4, 1975 . He will be eligible to take vacation in accordance with the pro- visions of the collective bargaining contract for his u��it. 5. Insurance - He will be eligible for coverage immediately but must pay for �the first six months of such coverage himself. After that, the City will pay for the insurance pursuant to the provisions of the collective bargaining contract for his unit. He will receive credit for the two monthly pay- ments that he made while employed as a groundskeeper for the City of St. Paul , thus obligating him to make four additional monthly payments nrior to commencement of pay- ment by the City. 6. Clothing Allowance - Will receive such allowance beginning April 25 , 1977. He must buy one uniform himself, as all other firefighters must do. 7. noctors ' Bills - The City will pay $197. 00 to r4r. Munson to reim- burse him for payments previously made to various doctors. The list found below contains the names of the doctors who have been paid and the amount that each has received. Dr. Thom�son. . . . . . . . $25. 00 Dr. Hlenc�ler . . . . . . . . . 85. 00 i',r. Schlof f . . . . . . . . . 52 . 00 Dr. Clemens . . . . . . . . . 35 . 00 , . i . � . , �. . � . : , 8. Wa e Cash Settlement - The City will pay to Mr. P�unson the sum of $1 , 179. 09: The City shall natify the Internal Revenue Service of such payment as it is based upon wages. 9. Pension Benefits - The City agrees to make the ne<�essary back payments for pension benefits as allowed by l��w and as would have been made had Mr. Munson been appointed on March 24 , 1975. Mr. N'unson agrees to make the necessary back pay- ments as allowed by law and that he would hav�s made if he had been appointed on PRarch 24 , 1975. Neither party need. comply with this provision if the other party does not comply with this provision. 10. Insurance Claim B�nefit - The City ac�rees to pay �the speoific medical claims of Hazel Park t�Iedi�cal Center for $46. 50 and West r^.edical Qlinic for $14. 06 as specifically provided for unner the provisions of the r�edical and Hospitalization Insurance Contract presently in e�ffect between the City and Blue Cross and Blue Shield, including the 3edu�tiL- Ie und scheduled provisions contained therein. 11. Veterans Benefits - It is the responsibility of M:r. t•'Iunson to negotiate the benefits that he may receive from Veterans Administration for On Job Training. If Mr. Munson receives less benefits than he would have received dir�ctly because of the fact he was not appointed to firefight�ar on March 24 , 1975 , the City agrees to fully compensate Mr. Munson for the �oss. 12. Additional P)ages Received - Mr. Munson affirms and states by his signature hereon that he has received no compensation, wages, welfare assistance, or aid of any type, durin� the period from March 24, 1975, to April 25, 1977, other than the salaries, wages , or aid made known to the City. This Agreement is full and final settlement of all issues in dis t . � G Terry S 1 ivan Greg M nson Dated: � Dated:��q=�") George Latimer, Mayor C�*yo uf �aint Paul Dated: -2- ... � .. • • • • , ��g��►� SriA':'�: OF MINNESOTA DISTRTCT CO�;�tT C�ii;�\TY OF RAMSEY SECOND JUDICIAL DIS�iR��'i ---------------------------------------- ;Vlark T. Conway, Pl aintif;, File No. 418737 vs, STIPLLATIO:�; AND r:i;orr:as D. Gleason, Director of DISMISSAL ,'e:�sunnel, Civil Service Comrr.ission �: �.:e C ity of Sair�Paul, and A Ibe rt ';. L::�.�s, Dr, �reurge C�_ Berry, �.:c: :Vldry:�iri 1�eneen, �V��:�r.bers ,, ��_e ;�iv��. S�•r•vice Conirr:i5s'.or� �f �:.� C��;: :,� Sa,:t:� t�aul, anc; Steve C:�i�.roy, S�. Paul Fire Cr.iei, Defendants. WHEREAS i� is the desire of the parties herein to amicably settic ali matt�rs pertaining to this Iawsuit; NOW, THEREFORE, IT IS HER EBY STIPL LA TED A ND A GR'r;E ll b,y and between the parties hereto, through their respective counsei: 1. Appointment. Mr. Conway will commence work for the St. ��aal r ire Department on June 20, 1977. 2. Seniority Date. For the purpose of seniority, Mr. Conway w�i« be considered to be appointed to the Fire Department as of March 2�, 197�. 3. Sick Leave. �Vir. Conway w•ill accumulate sick leave from �,��arc:. Z4, 1975 at t:�e usual rate set for�i� in the Civil Service Rules and the collective bargaining contract of �he Firefighters' Lnit. 4, Vacation. Mr. Conway will begin earning vacation frorri June 20, 1977, the date that he actually commences employment. He wi12 receive no vacation time for any time prior to June 20, 1977. , � • � • However, for the purpose of determining the amount of vacation per year that he will receive in any particular year, the date of seniority of March 24, 1975 will govern. 5. Insurance. Mr. Conway will be eligible for coverage immedi- ately, but he must pay for the first six months of coverage himself. Thereaft er, the City will pay a portion' of the insurance cos�s pursuant to the provisions of the collective bargaining contract of the Firefighters' Unit. 6. Clothing Allowance. Mr, Conway will receive the usual c lothing allowance commencing June 20, 1977, but must purchase one complete uniform himself, 7. Pension Benefits. The City agrees to make the necessary back payments farthe pension benefit as allowed by law and as would have been made had Mr. Conway been appointed on March 24, 1975. Mr. Conway agrees to make the necessary back payments as are allowed by law and that he would have made if he had been appointed on March 24, 1975. Neither party need comply with this provision if the other party does not comply with this provision. 8. Cash Settlement. It is the understanding of both parties that there will be absolutely no cash settlement involved in this agreement. The provisions set forth herein shall constitute a full and final agreement to any and all claims Mr. Conway may have against any or all Defendants named herein inregard to his appointment or rejection of appointment as a firefighter. It is further stipulated and�reed that this action may be and the same hereby is dismissed with prejudice and on the merits, but without . „ � - r . • • . , • '� � . further costs to either of the parties. Dated this ?�"��day of 19 77. _��`�� - MARK I. CONWAY � LLIA M M. KR ONSCH A BE L TER RY ULLIVA N Attorney for Plaintiff Attorney for Defendants 1004 Degree of Hon�r Building City Hall St. Paul, Minnesota 55101 St. Paul, Minnesota 55102 224-7683 298-5'121 . , � . :: � , � � � ��a� . v,d 1Cr�3� � B.F,FORF THF Nttr.q.Ar7 RT�HTS T)FPA.?tT*9F'rTT OF THF STA'!'F OF }RI*ar1FS�TA ------------------------------- In the Matter of „ �reqory J. *4ayen, , Charqing Party, : vs. . SF'T'!'LF?�!FNT RGRF'F*'fENT Thomas n. Gleason, nirector . Case rto. E2714-*�f�DPS-2 of Personnel, Civil Service . Commissian, Citv of Saint . naul , and its members , "Rrs . . �tuth n. Schwarz��al�er, "Rr. . Harry H. Gaston and *!►r. A. . R. 7angs, Steve Conroy, St. . Paul Fir� Chief, , '�espon�ents . . . ------------------------------- A ch�rc�P havinq hPen fi_le� hv �reqor_v ,7. *Ra.vPr. (her.Pinaf_tPr_ "charc�inq partv") , under *�+innesota Statutes, Char.ter 363 (1474) ; prohahlc� cause having heen foixnd to c-re�Iit the alleqation of an un- fair discriminatory practice hy Glilliam L. t^�ilson, Commissioner of_ the �"innesota nepartment of Human Rights (hereinaf_ter "nenartr►ent") ; an� the matter havinq heen settle�?, thP siqnators �+eloio aareP to an� do settlA this matter in t�±e fo11o�,Ti.nc� MannPr: 1. This agreement does not c�nstitute an adrlission hv Thomas n. �leason, nirector of Pers�nnel , Civil Service �ommission, City of Saint Paul , an�? its memhers , ^irs . Ruth n. Schc,��rzwalc?er, "�r. Flarrv T�. �aston an� "Rr. ?�. ??. ?anc�s, �teve ��nr�v, �t. Paul Fire Chief (hereinaf_ter. "resnondents") of a violation of_ *�innesota Statutes, Chanter 3ti3 (1974) or of. any 1a�1�s of the iTnited States �r regulations issued thereunder by any fPderal agency anc� is entered into voluntarily. 2 . Respondents agree that all recruiting, hirinq, em- plo_yment conditions, and dismissals shall he maintai_nec� an� con�ucted in a manner iti�hich c�oes not discriminate on the hasis of race, creed, color, religion, national origin, sex, rnarital status, status with regard to public assistance or disahility in violat�on of r�innesota Statutes, �hapter 3F3 (1Q74) . L , • • • 'i . °.�'.�nnr�ri�!'�fiG �ti.a'.?_ a*��nt c'�?�.r.�irn n�r_t�, ±� t-!,A nositi�n �f_ �'ir_� ri_ghter. '!'hn fi.rGt dav of em�Zovr�ant ,^�h.-�11 t» �1pr_il 25 , 1977 . 4 . '?��nondents srall r_est�re c�arqinq na.rtv' s senior_it�� te to the �3ate he �.•,o!_tic� havA b��n at�nointed had he nnt �'?P_P11 r.e- ject�d. 7?cco.rciincrlv, ch�rqincr nart��' s �nnior.it�� ate sh��1__l. },e r�troact�_v� to nct�her 1_4 , I�75 . 5 . C�:ar.�xin�r nartv sh_all accumulatP sici- 1_�a.v� �r_om �rtoher. 14 , i�?5 at the usi_xal rate sPt ��rth �n the �i.tv' s �ivi?. �ervi.�Q rules and the collectivP r�r.ga�_ninc? c�ntr.act o� the ?'ir.c� rirthter5 � TTY?]_'t. F . �har�xi.nc� �art�� shall ?-�e�rin earninn vacati_�z� Fr.o•� r.,nri_l. ?5 , ]_�►77 , thA �?at� he �.ct?ial?.�� co?�M�nces his ?mnlpVm�?nt. r�� .�i11 r��Pive n� vacati�n ti_r�� t�T'1.n2' to Tnr; 1 ?5 , 1_�77. ??��.•n.��r, fnr t�� rnir��P �f deter_*�;nincr t},e arloi.int of vacati�n �er ��e�r that he t��ill Y'C'_CP1V? in anv nar��c�il�r vPar, r�sn�n�ents G�"t71� �1SP the date o� sAr.ior.;t��, nct�'�er_ i Q , ?_�75 , 7 . �har�i.na nartv �h�ll he eli�rihlP for insttr.ancP !:ov�ra.RC� i_r�Me�?i_�t�1v, h�.1t �P Muct nav .f.or the f_�.rst six. ?�ont'�s cov�r.a.cr� t?i^?s�lf, a� is rPniiir��? of �th�r ('itv �r�.nl�veP^ , mh�r_e- aft�r thP �itv ��ill nay a n�rtion �f th? insur�nce costs niir.suant to the x�rovisi�n o� the annlicable c�1l�ctiv� haraainincr confir�ct. ° . c'harcrinq nart�r sh�li r.�cPive the �i�ua] �l.othin� �1�_n�,,�a.rtC� Cnrl�`?�1�r'?.nc7 A.n.r_�.1 '?5 , 1_�7? , �t�t r`?u�t rn1rr4+�SR? c�n.A rn*nnl�ta �inifor?n hirt�elf �s is rec�uirec� of all t�ectinnincr rirP I']_�'t�'ltP_T'S. 9 . Resnondents sha1Z x�ay t� c:�arcrinq �artv f_orty dollars (�?��) for nhysi�ian' s fPe� incurrec� hy ch�raing n�rtv an.c? eJ.evPn thnit��n�? ��ven '��in�'.r_er? F;_�t�, c��'l��rG (ci1. ,?Sn) �nr ]_.�s±: �.,�r��. ?�sn�n�?ents sh�l? noti�� t�?e T_nternal nPVP.rit�� c�r_v�_ce of th� na��- ment f�r lnst ��an�� . 1.� , T?esr�nclents ac�rAP to m.�.ke t?�e n�cPSSarv hack navm?nts f�r nensi.on henefi.t aG all_��,•�r? �v lao� anc? as �a,�il.lc�. �av? �P�r �a�.e _�_ t, ' • � � � • � � _ � � c�f�r �� '�ac? c�ar_ginr� �arty heen ar�n�i_nte�? on T"== ^�--�d , 1�175. Charctin� �artv agr.ee� to malce the nec�ssarv �act� �ay?nents as all��•�e� ?�� 1a�ti� c�aber /µ �� and t�at !�e ��•oulc� have m��?e if he ha� reer. cip1�07.I1t.P.r1. nn *+�----,.�� r 1Q75. ResP�n�?er_ts neec� not cor?nl�� ith t'zis nr�vi si.�n �f th� charqir.R n�rt�► ri.o�s nc�t com»?�► �.�yth t�is n?"OV7_5101'1.. 11 . ��+a.rginct narty a.f,fir!�� anc� state� �� ri� sicrnat�trQ hereon that he has receive�. no cor!nensati_on, w�q�s , ��elf_arP assi..stance, or aia of �nv tynQ, c?.l.irinc� t�e nerio�? `r�M October 14, 1975, to .Anril ?5 , 1977 , othar than the salaries, �aac�es, or ai�? mac�A �n�i�•n to th? Ci.tv. 12, m}'?P charging partv an�. thP n�naztm�nt h�re!�� t��a�v�, r�lPase, anc? covenant not to si.ie th� reGnonc�.ents 4•�it'�. re�necfi to any *�atters u�hich �.»re filed ��•ith the *ti�nesota nPnart�?ent of I?u*nan '?i_c�hts hy the charqine� nartv suh�ect to nerf_orMance h�� th.e resx�on.�- E'?lt� (7f t}'1P nZ'O?�?_l_GF?� c'�.I?l� reorA�Pntat�ClhS containP�� h.�.r.ei� . �'h� nec�artment shall �eterMine t•rhether the respon�?ents have c�m*�li�� ith the tArMS of this aqreement. 1'� . Thi.s aqreAMent is �. final �?ecision of the �enartment 3n� SQttl Ps �11 +�attP.r_s containP�' �r. t�.� ahove-ent�.tl��' �h<�.rqe of ��_scriminatian. 14 . This agreement incor�orates all oromises, ter_ms , an� conc�itions nec1otiated anc� aareP�? to h�� the narties an� is to he consi�ierec� a com�?lete an�i final exz�ression of. the ri�rhts an�? �uties un�'erfiaken hv th.e narties. �ate�1 this ?.6thA da�� of _�.x�ril , 7 . � . � . �t. _ ��.11iaM L. �°1i �on, C'omrtis��_oner n ., a tmPnt of ?ruman T'i.c�ht� Terry Su an , Assis ant Citv Attornev � �re�orv *� v �harc�inc� •arty