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THE BOARD OF SUPERVISORS OF CONTRA COSTA COUNTY, CALIFORNIA
Adopted this Order on May 20, 1986 , by the following vote:
AYES: Supervisors Fanden, Schroder, McPeak, Torlakson, Powers
NOES: None
ABSENT: None
ABSTAIN: None
SUBJECT: Settlement of Litigation )
Donald Day v. Contra Costa )
County Employees' Retirement )
Association, et al'. ) .
1. The County Administrator and District Attorney concur with the County
Counsel in recommending the Board accept the settlement of all claims of Donald
Day, a copy of which is attached hereto.
2'. The settlement has been approved by the Contra Costa County Retirement
Association.
3. Donald Day has executed the settlement agreement and general release as
to the County of Contra Costa and the Retirement Association.
4. Accordingly THE CONTRA COSTA COUNTY BOARD OF SUPERVISORS ORDERS
that said settlement is approved and that the County Administrator is authorized
to execute the settlement agreement on behalf of the County of Contra Costa.
I hereby Certify ti:r .tris Ig a true and Correct copy of
ars actior�is'3ker.t:ne-ontered or the aninv!es of the
Board of Supervisors on the data shown.
ATTESTED: rc ._ao� gG,
PHIL DATCHEL8111, Claris of the Board
of Supervisors and County Administrator
n
By , Deputy
Orig. Dept.:
cc: Donald Day
County Counsel
District Attorney
Retirement Administrator
County Administrator
Settlement Agreement and Release of All Claims MAY 12 1986
Martinez, CA 94553
1. Parties. Effective May 13, 1986, this agreement is made by and between
Donald Day DAY), Contra Costa County (COUNTY), Gary Yancey, District
Attorney (DISTRICT ATTORNEY) and the Contra Costa County Employees' Retirement
Association and its Board (RETIREMENT) .
2. Subject. This agreement is a settlement of all existing and possible
differences between the parties concerning DAY's classification as a general
member of the Retirement Association during his employment by the COUNTY
through the DISTRICT ATTORNEY, his appointing authority, and during his
retirement.
3. No Admission. This agreement is not and shall never be considered to be
an admission of any fault, error, wrongdoing, liability or violation of any right
of DAY by the COUNTY, the DISTRICT ATTORNEY, RETIREMENT or by any agent,
officer, servant or employee of any of them .
4. RETIREMENT and COUNTY agree to allow DAY to be classified as a safety
member and receive a safety member's retirement allowance. RETIREMENT will
pay DAY the difference in the amount he would have received since his retirement
as a safety member and the amount received to date as a general member following
Mr. Day's deposit of contributions as set forth below in paragraph 5.
5. DAY agrees:
A. DAY will pay to RETIREMENT the difference between the contributions
he made as a general member and those which would have been due if he had been a
safety member. His payment shall be a condition precedent to the obligations of
Retirement and the County set forth in paragraph 4.
B. DAY agrees to withdraw his appeals to the Contra Costa County Merit
Board against the County of Contra Costa and further promises not to take any
action to perfect or recover on his claims or to sue with respect to these
claims. A copy of this settlement agreement shall be sent to the Merit Board
and constitute a withdrawal of his appeals.
C. DAY agrees to withdraw his complaints to the California Fair
Employment and Housing Department and the U. S. Equal Employment Opportunity
Commission and further promises not to take any action to perfect or recover on
these claims or to sue with respect to these claims. A copy of this settlement
agreement shall be sent to each above-mentioned agency and shall constitute a
withdrawal of his complaints.
D. DAY agrees and acknowledges that he has freely and voluntarily
entered into this settlement agreement and that no promises or threats were made
to him to induce him to sign this agreement, other than the promises set forth
herein.
6. Release. DAY hereby on behalf of himself, his descendents, dependents,
heirs, executors, administrators and assigns, releases and discharges the County
of Contra Costa, Gary Yancey, Contra Costa County District Attorney, William
O' Malley, former District Attorney, the Contra Costa County Employees'
Retirement Association and its Board, and each and every officer, agent, ser-
vant, or employee of the COUNTY and RETIREMENT individually and in their
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capacities as such agents, servants and employees, and their successors, descen-
dents, dependents, heirs, administrators and executors, from all causes of
action, claims, demands, damages and liabilities of any kind whether known or
unknown and including but not limited to claims for attorneys fees, for viola-
tions of civil rights under federal, state, county, or departmental law, regula-
tion, or contract, including unlawful age discrimination, now existing or
hereafter :arising from the matters described in part 2. Subject, above, or
without limitation from any other cause whatsoever prior to the effective date
of this settlement agreement. DAY further covenants not to sue with respect to
his employment with Contra Costa County or his retirement from employment.
7. C.C. 51542 WAIVED. DAY agrees that this settlement shall act as a
release of future claims that may arise from the matters which are its subject
whether such claims are currently known, unknown, foreseen, or unforeseen, not-
withstanding 51542 of the California Civil Code which provides that a "general
release does not extend to claims which a creditor does not know or suspect to
exist in his favor at the time of executing the release which if known by him
must have materially affected his settlement of the debtor" and shall be in full
settlement of every above- escribed dispute, claim, or cause of action.
Donald y ate
COUNTY OF CONTRA COSTA CONTRA COSTA COUNTY EMPLOYEES'
RETIREMENT ASSOCIATION
Date Date
Gary Yancey, District Attorney
Date
Approved as to form
Victor J. Westman
County Counsel
By: Elizabeth B. Hearey, Deputy
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