4.13. SR 11-21-2016Request for Action
To Item Number
Mayor and City Council 4.13
Agenda Section Meeting Date Prepared by
Consent November 21, 2016 Cal Portner, City Administrator
Item Description Reviewed by
Separation Agreement Lauren Wipper, HR Representative
Reviewed by
Roger Knutson, City Attorney
Action Requested
Approve, by motion, a separation agreement with Park Maintenance Worker Amy Borst.
Background/Discussion
Park Maintenance Worker Amy Borst has requested to leave city service on short notice with recognition
of her service with severance.
The City Council discussed her performance with regard to severance and the variation from policy in a
closed session on November 17, 2016.
Financial Impact
Severance payout in accordance with agreement. The position is fully funded for 2016.
Attachments
Separation Agreement
SEPARATION AGREEMENT AND RELEASE OF CLAIMS
THIS SEPARATION AGREEMENT AND RELEASE OF CLAIMS
is entered into by the CITY OF ELK RIVER),
AMY BORST ) and LOCAL 49, INTERNATIONAL UNION OF
OPERATING ENGINEERS Employee, Union and the City are collectively
referred to as the parties.
WHEREAS, the City currently employs Employee; and
WHEREAS, employee is a member of the Union and the terms and conditions of
employment are governed by a Labor Agreement; and
WHEREAS, the parties are entering into this Agreement because Employee and the City
mutually desire to conclude their employment relationship in an amicable manner and to ensure
that no potential claims or conflicts arise.
NOW THEREFORE, IN CONSIDERATION OF the mutual promises contained in
this Agreement, the relinquishment of certain legal rights, and other valuable consideration, the
sufficiency of which is acknowledged, the parties agree as follows:
1. Irrevocable Resignation. Employee hereby resigns from all employment with the City
effective November 21, 2016. The Parties agree that employee is ineligible for future
employment with the City.
2. Severance. Within twenty five (25) calendar days after her resignation, the City will pay
Employee the equivalent of four weeks of salary at her current rate of compensation, less
applicable withholding for federal and state taxes but not PERA.
3. Unused Vacation Leave. Within twenty five (25) calendar days after her resignation,
the City will pay Employee for all accrued and unused vacation at her current rate of
compensation, less applicable withholding for federal and state taxes but not PERA.
4. Employment Letter. City shall provide Employee with an employment letter.
5. No Further Claim to Compensation. This Agreement fully and completely satisfies
any and all obligations between Employee and the City that arise out of or relate to her
employment and resignation. Employee has no claim to any compensation from the City,
in any form, beyond the compensation that is specifically described in this Agreement.
6. Release of Claims by Employee. In consideration of the terms and benefits described in
this Agreement, and as an inducement for the City to enter into this Agreement,
Employee hereby fully and completely releases, acquits, and forever discharges the City,
its current and former Council members, its current and former officers, its current and
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former employees, and its current and former agents, representatives, insurers, attorneys,
and other affiliates from any and all liability for any and all damages, actions, or claims,
regardless of whether they are known or unknown, direct or indirect, asserted or
unasserted, that arise out of or relate to any action, decision, event, fact, or circumstance
occurring before Employee signs this Agreement. Employee understands and agrees that
by signing this Agreement she is waiving and releasing any and all claims, complaints,
causes of action, and demands of any kind that are based on or arise under any federal or
state law, including but not limited to the federal constitution, the state constitution, and
any federal or state statute, regulation, rule, or common law.
7. Claims Not Waived. By signing this Agreement, neither the City nor Employee is
releasing or waiving any rights or claims that are based solely on events that occur after
this Agreement is signed, or any right to institute legal action for the purpose of enforcing
this Agreement. Additionally, Employee does not waive the following: (a) any right to
apply for unemployment compensation benefits; (b) any claims arising under the
r (c) any right to file a charge with a governmental
agency, including the Equal Employment Opportunity Commission, although Employee
agrees that she will not be able to recover any award of compensation, damages, or any
other monies if she files a charge or complaint or has a charge or complaint filed on her
behalf with any federal, state, or local government agency.
8. Revocation Under the ADEA. Employee recognizes that by signing this Agreement she
is waiving and releasing any employment discrimination, retaliation, or other claims that
she might have under the
Employee signs this Agreement, she will have twenty one (21) calendar days to revoke
her waiver and release of any claims arising under the ADEA. This right of revocation
applies only to claims arising under the ADEA. For a revocation of claims under the
ADEA to be effective, it must be delivered to City Administrator Cal Portner, either
personally or by United States mail within the twenty one-day period. If delivered by
mail, the revocation must be postmarked within the twenty one-day period, properly
addressed to Cal Portner, City Administrator, Elk River City Hall, 13065 Orono Parkway
NW, Elk River MN 55330-5600 and sent by certified mail, return receipt requested.
9. Rescission Under the MHRA. Employee recognizes that by signing this Agreement she
is waiving and releasing any employment discrimination and retaliation claims that she
might have under the the MHRA
(Minnesota Statutes §363A.31), Employee has the right to rescind her release of claims in
writing within fifteen (15) calendar days after signing it. This right of rescission applies
only to any claims arising under the MHRA. For a rescission of claims arising under the
MHRA to be effective, it must be delivered to City Administrator Cal Portner, either
personally or by United States mail within the fifteen-day period. If delivered by mail,
the rescission must be postmarked within the fifteen-day period, properly addressed to
Cal Portner, City Administrator, Elk River City Hall, 13065 Orono Parkway NW, Elk
River MN 55330-5600 and sent by certified mail, return receipt requested.
Agreement and Release of Claims
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10. Effect of Rescission of Release of Claims. If Employee revokes or rescinds any part of
the Release of All Claims in this Agreement, paragraphs 2, 3 and 4 of this Agreement
will automatically be rescinded without further action by either party but the rest of this
agreement shall remain in place.
11. Return of Property. Employee agrees to immediately return all City property that is in
her possession. The City will provide Employee with a reasonable opportunity to remove
her personal effects from her office in a manner that is not embarrassing and at a time
when other City staff are not present.
12. Representation by Union. Employee acknowledges that she has been represented by
her Union Representative with respect to this Agreement and all matters covered by and
relating to it. Employee further agrees and represents that she has not received or relied
upon any advice or representations by the City or the
Agreement. The parties acknowledge that they have consulted with their own legal
counsel, that they have thoroughly read and understand the terms of this Agreement, and
that they are voluntarily entering into this Agreement.
13. Responsibility for Costs. Each party is responsible for its own costs, expenses, and any
attorney fees associated with this Agreement.
14. No Admission of Wrongdoing. Nothing in this Agreement may be construed to be an
admission of liability or wrongdoing by, against, or on behalf of the City, Union or
Employee. Any form of wrongdoing or liability is expressly denied by the City and its
representatives and by Employee and her representatives and the Union and its
representatives.
15. Choice of Law, Forum and Severability. This Agreement is governed by the laws of
the ent of
Minnesota or any other state. The parties agree that the Minnesota state and federal
courts will have exclusive jurisdiction over any dispute arising out of this Agreement. If
a court determines that any part of this Agreement is unlawful or unenforceable, the
remaining portions of the Agreement will remain in full force and effect.
16. Entire Agreement. This Agreement constitutes the entire agreement between the parties
No
party has relied upon any statements, promises, or representations that are not stated in
this document. No changes to this Agreement are valid unless they are in writing and
signed by all parties. A copy of this Agreement will have the same legal effect as the
original.
17. Data Practices. The Parties agree that this Separation Agreement and Release of Claims
Agreement and Release of Claims
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IN WITNESS WHEREOF, the parties have approved and executed this Agreement on the
dates shown by their signatures.
EMPLOYEE
Date:
Amy Borst
IUOE LOCAL NO. 49
Date: BY:
Its
CITY OF ELK RIVER
Date: BY:
John J. Dietz, Mayor
BY:
Tina Allard, City Clerk
Agreement and Release of Claims
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