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135-US Equal Employment Opportunity Commission ,l,t n , .. :.~"~'"'''' ,< .. ,~."lo . . . . , . . - . . , , . .'Of' t.... '. ,,~,...'" Miami District OffIce EQUAL EMPLOYMENT OPPORTUNITY COMMISSION DuPont Plaza Center. SUite 414 300 Biscayne Boulevard Way Miami, Florida 33131 Phone (305) 350-4491 IN THE ~mTTER OF: U. S. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION and Tony Leonard Brooks John C. Moore Seminole Community Action, Inc. CHARGING PARTY (S) CHARGE NOS. TMt16-3190 TMM6-3189 THM6:"'2710 and City of Sanford Sanford, Florida PRE-DETERMINATION SETTLEMENT RESPONDENT * * * * * * Charges having been filed under Title VII of the Civil Rights Act of 1964, as amended, with the U. S. Equal EmploY,ffient Opportunity Commis- sion, for the Charging Party against the Respondent, there having been a preliminary investigation, the parties do resolve and settle this matter as follows: 1i 1\ ,) , , ~1. Page 1 Charge No. TMM6-3l90 TMM6-3l89 TMM6-27l0 PARTIES On this 24 day of June, 1977, The City of Sanford, The Mayor and his successor, The City Officials/Officers and their successors, all of its Departments, Divisions, Sub-Divisions; hereinafter called the Respondent or the City; the Equal Employment Opportunity Com- mission, hereinafter called the Commission; the Charging Parties listed in Appendix 'A' agree as follows: Page 2 Charge Nos. TMM6-3l90 TMM6-3l89 TMM6-2710 PURPOSE OF THIS AGREEMENT AND GENERAL PROVISIONS 1. The purpose of this Agreement is four-fqld: a. To resolve any and all issues raised by the allegations in charges involved in alleged act of discrimination which are and will be appended to this Agreement. b. To resolve any and alleged acts of discrimination by the City of Sanford against the black and hispanic employees defined herein as Affected Class and Charging Parties' under Title VII of the Civil Rights Act of 1964, as amended. c. To emphasize the intent of the City to comply in all re- spects with Title VII and to demonstrate its good faith, by consent- ing to and signing this Agreement. The City of Sanford is not ad- mitting any violation of Title VII, as amended. d. To initiate and implement the City's Equal Employment Opport- unity Program providing non-discriminatory employment opportunity be- cause of race, color, religion, sex or national origin to all present and prospective employees of the City. When the Equal Employment Op- portunity Plan for the City of Sanford has been completed, a copy of said Plan will be submitted to the Miami District Office of the Equal Employment Opportunity Commission for review. 2. The provisions of this Agreement shall supersede any and all con- flicting terms or provisions of Respondent's Personnel Rules and Page 3 Charge Nos.: T~16-3l90 T~16-2l89 T~lli6-27l0 Regulations and its amendments. Respondent agrees to take steps to negotiate and resolve any changes in the Collective Bargaining Agreement with the responsible representatives of those Agreements. 3. The City agrees that it will take such appropriate measures as necessary to prevent or restrict actions which in any way inhibit, impede or delay the effective implementation of this Agreement. More- over, the City will inform all employees, that anyone intimidating or otherwise interferring with the free exercise of their (blacks and hispanics) rights provided by this Agreement or as guaranteed by Title Vii, shall be subject to appropriate disciplinary action, up to and in- eluding discharge. AFFECTED CLASS DEFINITION 4. The Affected Class listed in Appendix 'B', shall be defined as all black and hispanic employees at the City of Sanford Departments, Divisions, Sub-Divisions, etc., that have not attained the pay grade level of similarly situated non-affected employees hired during the same period; including those black employees who have retired, resigned, were discharged or terminated, as of June 7,' 1974; those hispanic em- ployees that have not attained pay grade level comparable to Anglo em- ployees hired during the same period; (statement applicable to hispanic employees in the same manner as of the black Affected Class members); and those who have filed charges against the City of Sanford with Equal Employment Opportunity Commission as of the date of this Agreement. Page 4 Charge Nos.: T~16-3190 Tl-r.!6-2189 Tl>~'16-2710 ADVERTISING, RECRUITMENT AND HIRING 5. Respondent affirms that any solicitation or recruitment is made on a non-discriminatory basis, and that it will advertise employment op- portunities in communication media (such as newspaper, radio and T.V. stations) which especially appeal to blacks and hispanics. 6. Respondent agrees not to mail copies (word-of-mouL~) of job an- nouncements to identified persons with the purpose of soliciting certain applicants. If such recruitment practice is necessary for the operation of the Respondent, the same will be applied to all groups without pre- ference and will be free of discrimination because of race, color, sex and religion. EXPECTANCIES 7. The City will, upon the effective date of this Agreement and regularly every six (6) months, conduct an employment expectancy review for the Commission. This review is to determine and establish the number and types of job vacancies available due to newly established jobs, opportunities, jobs available because of attrition, transfers or vacancies or existing by other means. 8. The City will also review on the same basis and report the number Page 5 Charge Nos.: TMM6-3190 TMM6-2189 TH116-2710 through the use of approved and recognized non-discriminatory merit of qualified applicants available in the relevant job market selection system and recruitment procedure. 9. The City agrees to increase the hispanic and black distribution on all municipal jobs. APPOINTMENTS 10. The City of Sanford, the Mayor, Officials/Officers of the City of Sanford agree that: a. Blacks and hispanics (currently) employed in provisional or temporary status and who have remained on said status twelve (12) months or more but at the present time have not attained permanency, will be upon effective date of this Agreement made permanent and credit will be given for the time of service. b. All new hires shall attain permanent status after twelve (12) months of satisfactory performance. c. Above (a) and (b) will not apply to work help programs such as CETA and anti-recession funded positions which are temp- orary positions depending on federal funding. MERIT SYSTEM 11. The City affirms it has established, implemented and utilized a Merit Selective System. To this end, the City affirms that it Page 6 Charge Nos.: ~16-3190 TMH6-3189 TMH6-2710 utilizes selection procedures which are in fact non-discriminatory and validly measure or predict job success. Such selection procedures are agreed to be a valid basis for ranking applicants objectively in order of the probabilities of success on the job. 12. To accomplish this, the City agrees that it will discontinue any selection system which does not purport to be valid. 13. Any system which requires the selection on the bases which are discriminatory under the terms of this Agreement and requires that consideration of relative ability and qualifications be subordinated to considerations of race, color, sex, religion or national origin are void. 14. The City affirms that corrective actions prescribed in other portions of this Agreement are now being implemented. 15. The immediate corrective action, selection process will be based on the individuals relative ability to perform the job. 16. The present selection process, if they do not meet Equal Ernploy- Page 7 Charge Nos.: TMM6-3l90 TMM6-3l89 TMI16-2710 ment Opportunity Commission's guidelines is agreed to be suspended and the new selection devices should be developed and validated immediately with the U.S. Civil Service Commission. 17. Respondent now provides all equipment and material to all appli- cants and employees where testing is a pre-employment requisite, i.e., typists, stenographers, clerks, etc., equivalent to that expected to be used on the job and will continue to do so. 18. Affected Class member applicants will be given adequate time to acquaint themselves with test and equipment prior to the taking of tests. TRAINING 19. The City of Sanford affirms that it does: (a) Subsidize formal job related training necessary to prepare all employees for promotions, upgrading and/ or transfers. (b) Post and advertise to all employees of the availability of such trainings. (c) Train all new employees. 20. Respondent further affirms that all job.related training for Police Officers, etc. . . . is made available to all employees at "no cost" on the part of ,the employee. Page 8 Charge Nos. THM6-3190 TMM6-3189 TMM6-2710 APPLICATION FORM AND PRE-EHPLOYMENT INQUIRIES 21. The City of Sanford agrees to review its employment application form and to eliminate those non-job related inquiries, i.e., l1arital status, State Citizenship Requirement, Arrest Information, Age, Family Background, etc. . . . 22. Respondent further agrees to eliminate pre-employment inquiries, pre-employment information such as family background, motor vehicle background, etc. . . 23. Respondent further agrees to revise its oral examination/evaluation form and to eliminate all information except "reconunend", "do not reconunend"* and "employment". PRE-EMPLOYMENT INQUIRIES 24. Respondent agrees to review and/or revise the background check and pre-employment inquiries which are discriminatory and which adversely and disproportionately affect members of the affected class and to eliminate, but not be limited to, pre-employment inquiries which are used and have an adverse effect such as: * Reasons for not recommending. Page 9 Charge Nos.: Tl1!'16-3190 TMi'16-3189 TMM6-2710 (a) Arrest Record (b) Garnishment (c) Credit Checks 25. Respondent agrees to recanvass back to January 1, 1975 all black and hispanic applicants/employees who were rejected/discharged by Respondent based on information gathered by Respondent on applica- tion forms; background checkout or subjective oral examination/evaluation recommendations; re-interview them and offer the next available position for which they qualified. 26. In addition, the Respondent agrees to notify the affected parties that the applicants rejected or employees discharged will be re-inter- viewed for possible employment. EQUAL EMPLOYMENT OFFICER 27. The City of Sanford agrees to appoint a full time Equal Em- ployment Officer for the City of Sanford who will be directly respon- sible to the City Managers. 28. The Equal Employment Officer will be held responsible for the following: a. Developing policy statement, a written Equal Employment Opportunity Program, internal and external communication procedures by such program. Page 10 Charge Nos.: T:1!'16-3190 TH!.16-3189 THM6-2710 b. Assisting line management in collecting and analyzing employment data, identifying problem areas, setting expectancies programs to achieve goals. Programs should include specific remedies to eliminate any discriminatory practices discovered in the employment system. c. Designing, implementing and monitoring internal audit and reporting systems to measure Equal Opportunity effective- ness and to determine whereprogress has been made and where further action is needed. Assuring that such action is taken. d. Reporting, at least quarterly, to the Chief Executive on progress of each City Department in relation to City expectan- cies. e. Serving as liaison for EEO purposes between City Departments, government regulatory agencies, minority and women's organiza- tions and other community groups. f. Assuring that current legal information affecting Equal Employ- ment Opportunity is disseminated to responsible officials. g. Reviewing final adverse personnel actions when such actions are made against affected class members after department~ have made information available. DISCIPLINARY ACTION/SUSPENSION 29. The City of Sanford agrees that no black or hispanic employees will be discharged, suspended, reprimanded, disciplined, demoted or downgraded in situations when non-black and Anglo employees have not been subjected to the same disciplinary actions for the same of- fenses. 30. Respondent further affirms that it makes the following factual determinations, based on written documented evidence, when any em- F~ge 11 Charge Nos.: TMM6-3190 TMM6-3189 TMM6-2710 ployee is subjected to the aforementioned actions: (a) Written statement of specific charge (for action) including factors to support charge. (b) Whether sufficient cause for the action exists. (c) Whether the employee's improper conduct was in any way caused by misconduct on the part of the foreperson or other supervisor. (d) Whether other non-black or hispanic employees have been affected for similar conduct. (e) Whether mitigating circumstances or the employee's previous record indicate that discharge, downgrade, demotion, etc., was overly harsh. 31. The Respondent further agrees that in disciplinary actions after the investigation of the factual incidents and before taking any action or making any determination, the result of the investigation as well as the recommendations will be turned over to the Equal Employment Officer for his/her comments and these comments shall be part of the official city records. 32. Respondent further agrees to review all personnel records of hispanics and black employees of the Police Department that have been subjected to any of the disciplinary actions described above, and to eliminate all adverse notations from said files/records and give these employees ? \ the same opportunities afforded to non-black and Anglo employees. ~~ 33. Furthermore, Respondent will implement the above-mentioned prov- ision immediately upon effectiveness of this Agreement in its Police Page 12 Charge Nos.: Tl1M6-3190 Tl1M6-3189 TM..lI16-2710 Department and all recrods of all black and hispanic employees employed at the Police Department. WAGES 34. The City of Sanford affirms that whenever same positions with same job titles are assigned to hispanic and black employees, the rate of pay (grade) of said employees is equalized to the rate of pay of their non-black and Anglo counterparts. 35. This rate is adjusted to the highest pay step attained by both Anglo and/or non-black employees, whichever is applicable. This pay adjustment applies with those employees named and identified as Affect- ed Class Members. MASTER AGREEMENT 36. This agreement is entered into between the Commission and The City of Sanford/State of Florida as a Master Agreement for the re- solution of national origin and race complainst brought and future national origin and race complaints received under Title VII of the Civil Rights Act of 1964, as amended. This Section is for the duration of this Conciliation Agreement. \ Page 13 Charge Nos.: TMM6-3190 TMM6-3189 TMM6-2710 (a) It is understood that other sections relevant to new charges may be annexed to the Master Agreement when neces- sary to remedy future complaints alleging national origin and racial discrimination. (b) It is further understood that upon receipt of any complaints brought under Title VII of the c~vil Rights Act of 1964, as amended, the Miami District Office of the Commission will forward to the Respondent prior to making a formal investiga- tion, a copy of the charge and receipt for service. Receipt of such charges will constitute Notice of the Charge and Ser- vice of the Charge upon the Respondent. 1. It is understood that this procedure will permit ninety (90) calendar days for the Respondent to institute an internal process of establishing a finding, a recommend- ation of corrective action and a proposed settlement for the consideration of the Miami District Office of the Commission. 2. It is understood that the Commission, if it finds the re- solution to be appropriate will confer with the Charging Party for settlement. 3. It is further understood that should such a proposal of the Respondent not meet Commission Standards, the District Office will work with the Respondent to adapt a remedy to the Title VII Standards. 4. It is further understood that should the above efforts fail, the charge will revert to normal EEOC Procedures. (c) Should the District Office decide that this serve the best interest of the Commission, may terminate the arrangement of Section procedure does not the Distric~ Office upon notice. (d) Not withstanding the commitments made in any part of this agreement, it is understood that where an individual person has been found to be the victim of an unlawful employment practice, he or she should be given priority consideration for that job opportunity denied, regardless of his or her relative "ability" at the time the denied,job opportunity occurs. PROMOTIONS 37. The City of Sanford agrees that whenever promotional opportunities Page 14 Charge Nos.: TMM6-3190 TMM6-3189 TMM6-2710 occur, these jobs will be filled on the basis of an approved merit system. Where an individual has been found to be a victim of unlawful employment practices, he or she will be given priority consideration for that promotional job opportunity, regardless of his or her relative "ability ranking" at the time the denied job promotion occurs. 38. The Respondent agrees to subsidize job related training necessary to prepare the Affected Class Members (black and hispanic) for promo- tion. An inventory of current black and hispanic personnel will be made to determine academic skills, update application and interview to obtain training and experiences in an effort to upgrade black and hispanic employees. This will be accomplished within ninety (90) days and there- after on a yearly basis for the life of this Agreement. 39. No Affected Class employee should be required to go through initial employment process, but should be given first opportunity to be consider- ed for vacant positions prior to outside recruitment and/or appoint- ments until such time as an equitable level of black and hispanic em- ployees has been reached with non-blacks and non-hispanics. No Affect- ed Class member will compete for job promotions or vacancies on the basis of qualifications and standards more severe than those utilized in the past by the City in selecting from non-affected class members, unless the increased standards are required by business necessity. Page 15 Charge Nos.: T~~6-3190 ~ll16-3189 T~16-2710 40. The City of Sanford agrees to issue, within thirty (30) days, a bulletin board notice, throughout all the departments, to be posted in conspicuous places, informing the employees that they should submit a written request to be considered for current/future supervisory or management positions. 41. Respondent affirms that it has to eliminate non-job related educa- tional requirements for entry level/department positions. 42. Respondent affirms it has established uniform policy to govern step increases and/or advancement. Respondent further affirms it does not require members of the Affected Class to spend any period of resi- dence in any step (job) which exceeds the period factually necessary to qualify for movement to the next step in the grade and/or higher related job. Furthermore, the Respondent will not require such employees to spend any residence period longer than that spent by non-minority em- ployees who spend the shortest period of time in residence. 43. Respondent agrees that for every non-black or Anglo promoted to supervisory/management positions, Respondent will promote one of the Affected Class as the openings occur until the percentage of blacks and hispanics has reached a percentage comparable to their white and anglo counterparts. Page 16 Charge Nos.: THH6-3190 THH6-3189 THM.6-2710 NOTICE 44. The Respondent shall give Notice of this Agreement to all of Respondent's employees by posting copies of it in all normal posting locations. The Respondent shall cooperate in taking all necessary steps to explain this Agreement and its operation to all affected em- ployees and non-affected employees. INDIVIDUAL CASE AGREEM.ENTS AND CASH SETTLEM.ENTS 45. In consideration for signing the "Release" form attached hereto as Exhibit 1, parties identified as "Affected Class Members" listed in 'Appendix B' shall receive the amount therein shown. EFFECT 46. This agreement resolves all issues raised by all EEOC charges filed by all members of the Affected Class, individually and as a Class, and all other charges filed with the commission by a member of the Commission prior to the date of this Agreement and compliance with this Agreement shall be deemed to be compliance with Title VII of the Civil Rights Act of 1964, as amended. Page 17 Charge Nos.: Tl1l16-3190 TMM6-3189 TM..'16-2710 REPORTING PROVISIONS 47. Respondent agrees to report in writing to the District Dir- ector, Miami District Office, Equal Employment Opportunity Commission, DuPont Plaza Center, Suite 414, 300 Biscayne Boulevard Way, Miami, Florida, 33132, when it has completed the undertakings outlined in this Agreement. The initial report shall be submitted ninety (90) days from the date of receipt of a fully executed copy of this Agreement. Sup- plemental reports shall be submitted annually thereafter for a period not to exceed three (3) years. 48. Respondent agrees to furnish this Commission with a copy of its EEO-4 Report for the same period indicated above, with a list of all members of the Affected Class hired, promoted, transferred or dis- charged, showing date of hire, job classification, date of transfer and job classification, date of discharge and reason. The aforementioned will indicate the race and the national origin of each person listed. Page 18 Charge Nos.: TMM6-3190 TMM6-3189 Tr~~16-2710 SIGNATURES I ' 2 Ifjt '__At Nb <:1. DATE I have read the foregoing Pre-Determination Settlement Agreement and I accept and agree to the provisions therei~ .Tllne 23. ,g77 DATE FOR: CITY OF SA FORD ~ RESPONDENT ) \ ~ /// /2,,/ ! ( :'// .11: 'Ix:_- /~~ , r tu.:p ,/'J/:'/:.L'~"" ' _' :;::., TONY LbOtIARD BROOKS t' CHARGING PARTY 1'1'77 I recommend approval of this Pre-Determination Settlement Agreement: ~u-;2q-?7 DATE x~~~~y- JpHN OTERO 1tQUAL OPPORTUNITY SPECIALIST I concur in the above recommendation for approval of this Pre-Determina- tion Settlement Agreement: (t~~ DAbQ 2rt /C:;7) ( ./':? .' /,/~/ ~' . // / // _ __-<<,-~/2~ /~9c---c-~--f:/ ~BE EDICT E. VOIVEDICH SUPERVISOR .~ \ .~ Charge Nos.; TMM6-3190 TMM6-3189 TMt~6- 2710 SIGNATURES I have read the foregoing Pre-Determination Settlement Agreement and I a::::: ::d a:::: to the provisions there;n:~~ DATE FOR: CITY OF SANFORD RESPONDENT DATE ?J"~ J. j /1 7 7 M EL MARTINEZ CHARGING PARTY I recommend approval of this Pre-Determination Settlement Agreement: ()6-;;;~-77 DATE ~~-vL O~$ ~OI'lN 0 RO EQUAL OPPORTUNITY SPECIALIST I concur in the above recommendation for approval of this Pre-Determina- tion Settlement Agreement: 7 ,# l./ t-C'Y~ DpYfE // y; /07 ~k/utLd2j BENEDICT E. VOIVEDICH SUPERVISOR CJ~ zy) \C{'11 ~.~ ~~~ ~ THEOOORE~. BU~OWSKI -, DISTRICT DIRECTOR APPROVED ON BEHALF OF THE COMMISSION: Charge Nos.: H1r16-3190 Tfv'J~6- 3189 TMM6- 271 0 SIGNATURES I have read the foregoing Pre-Determination Sett1em nt Agreement and I accept June 23, 1977 DATE FOR: CITY OF SANFORD RESPONDENT 6-:Lr(~ ?? DATE ~ C' ~~, 6J HN . MOOR~ CHARGING PARTY I recommend approval of this Pre-Determination Settlement Agreement: CJ(, -- ;;2y~ 77 DATE .' (/V[ B~p- JO OT RO UAL OPPORTUNITY SPECIALIST I concur in the above recommendation for approval of this Pre-Determina- tion Settlement Agreement: /) i < - . / <~~;A:~c&?~/{( BENEDICT E. VOIVEDICH SUPERVISOR (~~ "2~( /)7 J DAlY , APPROVED ON BEHALF OF THE cm'1MISSION~~. ~ (), W'Nl- 21{ I c(11 I' r:I~f' ~u!4 D~ U ) q;Ol'""THEOOORE. . BUKOWSKI V DISTRICT DIRECTOR INDIVIDUAL RELIEF Page 19 CHARGE NUMBER TMM6-3190 Respondent agrees that it will offer immediate reinstatement to Charging Party, Tony L. Brooks, with the Drug Enforcement Agency. Respondent agrees to notify the Charging Party of the offer of reinsta- tement by certified Mail, Return Receipt Requested, allowing Charging Party ten (10) days to reply, by mail, in person or via telephone; failure on the part of the Charging Party to respond within that time will relieve Respondent of further obligation. Respondent agrees that it will pay Charging Party, Tony L. Brooks $2,844.27 backpay, which represents earnings lost, less his earnings in other jobs while he was not employed by the City of Sanford Police Department, in full settlement of the case. Respondent agrees to remove from the Charging Party's personnel file, all documents, entries, statements, comments, references to grammatical ability, attitude, disciplinary notices and appraisals, which lead to the filing of the charge. , Respondent agrees to afford the Charging Party training opportunities in each of the Police Academy classes and in service training; cost to be paid by the Department. ,I INDIVIDUAL RELIEF Page 20 CHARGE NUMBER TMM6-3l89 Respondent agrees that it will offer iromediate reinstatement to Charging Party, John C. Moore, in the job classification of Acting Sargent. Respondent agrees to notify the Charging Party of the offer of reinstate- ment by Certified Mail, Return Receipt Requested, allowing Charging Party ten (10) days to reply, by mail, in person or via telephone; failure on the part of the Charging Party to respond within that time will relieve Respondent of further obligation. Respondent agrees that it will pay the Charging Party $2,397.05 back pay, which represents earnings lost, less his earnings in other jobs while he was not employed by the City of Sanford Police Department, in full set- tlement of the case. Respondent agrees to remove from the Charging Party's personnel file, all documents, entries, statements, comments, references to grammatical ability, attitude disciplinary notices and appraisals, which lead to the filing of the charge. Respondent agrees to afford the Charging Party training opportunities in each of the Police Academy classes and in service trainings; cost to be paid by the Department. INDIVIDUAL RELIEF Page 21 CHARGE NUMBER TMM6-2710 The Respondent agrees to pay Charging Party, Manuel M. Martinez, the sum of Two Thousand and No/lOOths ($2,000.00) Dollars as consideration in full settlement of the case and Charging Party hereby waives, releases and covenants not to sue the Respondent with respect to any matters which were or might have been alleged in Charge TMM6-2710 filed with the Equal Employment Opportunity Commission, or on account of any act or admission of Respondent or any of its agents, servants, or employees or in any other way arising out of any relation between the Charging Party and Respondent existing on date of this Agreement. Respondent agrees to remove from the Charging Party's personnel records all documents and entries relating to the facts and circumstances which led to his filing a charge, and agrees that it will not disseminate, directly or indirectly, to any other employer or potential employer, any facts or circumstances relating to this charge of discrimination. EXHIBIT 1 LIST OF EMPLOYEES MONEY CONSIDERATION FOR SIGNED RELEASES AFFECTED CLASS EMPLOYEES Name Amount l. 2. Manuel Martinez, Jr. Eddye Jones Roberts $1,000.00 $1,000.00 APPENDIX A Charging Parties 1. Tony L. Brooks 2. John C. Moore 3. Seminole Community Action, Inc. (Manuel Martinez) ~ \ ~ ~l APPENDIX B List of Employees Affected Class Employees: Name Race/National 'Origin l. 2. Manuel Martinex, Jr. Eddye Jones Roberts Hispanic Negro '=- RELEASE AND RECEIPT That I, Manuel Martinez, Jr., do hereby release the City of Sanford, Sanford, Florida, of all causes of action and sums of money, growing out of or related to charges of violations of Title VII of the Civil Rights Act of 1964 as amended, stipulated in this Agreement. ,. dow~' ""1,/ ~ 77 RELEASE AND RECEIPT That I, Eddye Jones Roberts, do hereby release the City of Sanford, Sanford, Florida, of all causes of action and sums of money, growing out of or related to charges of violations of Title VII of the Civil Rights Act of 1964 as amended, stipulated in this Agreement. Date Signature