Free Statement - District Court of Colorado - Colorado

Case 1:03-cv-02435-PSF-PAC

Document 249-2

Filed 09/06/2006

Page 1 of 2

SETTLEMENT AGREEMENT In exchange for those things set forth below, the undersigned parties to this agreement resolve to settle the complaint of ~illian Faye Sandle, identified by complaint number 89-440, 89-441, 93-1785, 93-1790, 93-1821, and 94-0858, .and all pending administrative procedures and filings which are or may be filed in relation to the above identified case, and any pending informal complaints. 1. The Complainant agrees to withdraw the above-identified complaints and all other related issues in their entirety, in exchange for the promises set forth in section 2 below. By doing so, the Complainant waives all rights to further administrative processing and all rights to file a civil action in connection with the above-identified complaints.

2. The Department of Veterans ~ffairs and the Denver VAMC agree to the following:
a. Compensate you in the amount of $50,000.

b. Destroy all negative documents in agency files relating to conduct or performance issues. c. Priority placement within six months from the date of this agreement into a position (from the list of positions provided by the complainant) that is to be filled by VAMC Denver. She must meet the minimum qualifications and physical requirements of the position. d. That complainant will be terminated for only just cause. e. That the complainant will provide VAMC Denver with updated medical documentation identifying any and all physical restrictions. f. The complainant will provide VAMC Denver with a list of positions that she requested to be considered for. g. That the complainant will provide VAMC Denver with an updated employment application, i.e, SF 171 or resume. h.
3.

Attorney fees $16,600.

Both parties also stipulate that: This agreement has been entered into freely by both

a. parties ;

b. This agreement does not constitute an admission of guilt, fault, or wrongdoing by either

Case 1:03-cv-02435-PSF-PAC

Document 249-2

Filed 09/06/2006

Page 2 of 2

L i l l i a n F a y e Sanae, S e t t l e m e n t Agreement

c. This agreement shall be kept confidential and the terms herein shall not be disclosed by either party, except to authorized EEO officials or to other officials responsible for implementing the agreement;

d. This agreement shall not serve as a precedent for resolving any other complaints, which have been or may be filed by the complainant or any other person; and e. This agreement constitutes the entire agreement and no those specified herein. other terms to this agreement except. f. The wording meaning, and terms of each of the above paragraphs and subparagraphs set forth in this agreement is , understood by all. Additionally, the Department of Veterans Affairs agrees that, should it fail to comply with any of the terms set forth herein for reasons not attributable to acts or conduct of the Complainant, it will reopen this complaint for further processing at that point in the process where processing ceased as a result of this agreement, provided that the Complainant brings any allegation of breach of this Settlement Agreement to the attention of the Deputy Assistant Secretary for Equal Opportunity (06), Department of Veterans Affairs, 810 Vermont Avenue, NW, Washington, D.C. 20420, and within 30-calendar days of discovery of the breach. have affixed their signature this
1997.

X L i l l i a n Faye

Y / @ Y A. 2& sangle J 9
., Medical
4

X

E Thorsland, Jr .

Center Director