HomeMy WebLinkAboutR-1994-145A RESOLUTION OF THE CITY OF DANIA, FLORIDA,
APPROVING THAT CERTAIN SEPARATION AGREEMENT
BETWEEN THE CIry OF DANIA AND TIMOTHY G. TAPP;
AND PROVIDING FOR AN EFFECTIVE DATE.
BE IT RESOLVED BY THE CITY COMMISSION OF THE CIry OF DANIA,
FLORIDA;
Section 1. That that certain Separation Agreement between The City of Dania
and Timothy G. Tapp, a copy of which is attached hereto as Exhibit "A", be and the same
is hereby approved, and the appropriate city officials are hereby directed to execute same.
Section 2. That this resolution shall be in force and take effect immediately upon
its passage and adoption.
PASSED and ADOPTED on 15;s 2 7 t h flsy of Sept. ,1994
ATTEST:
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City Clerk - Auditor
APPROVED FOR FORM & CORRECTNESS
By:e,.*z c. cl-4^
Frank C. Adler, City Attorney
Mayo r - Comm loner
Resolution No. 745-94
RESOLUTTON NO. 145-e4
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CITY OF DANIA
INTERoFFTcEMEMoRANDUM A R B.tMerNbeITeA
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Date September 26, 1994
To:Bobert F. Flatley, City Manager
From:Michael W. Smith, Personnel Director
SUBJECT: SEVERANCE 0PT|ON- TIM TAPP AND CLIFF TAYL0R
Following are amounts that would be required to provide Tim Tapp and Cliff Taylor a severance
package in exchange for their voluntary resignations and signing legal releases. Without such a
release,each would be entitled to $250 per week in unemployment benefits ( $6500 each over six
months ) and should either decide to challenge the City's action we could expend tens of thousands of
dollars in legal defense fees. Although I believe we are likely to prevail in any court action , we would
have to delend any possible suits to reach a successful outcome.
SALARY TO 12130/54 HEALTH INSURANCE TOTAL
Clifl Taylor
Tim Tapp
TOTALS
$9,885.20
$10,322
$20,207.20
$2,100
$2,1 00
$4,200
$11,985.20
$12,422
$24,407.20
Muller, Mint, our labor counsel will provide us by tomorrow morning with the necessary language to
incorporate into the releases that we will ask Cliff and Tim to sign . I believe that this option represents
the best course of action with respect to these management employees.
Severance 0ption Costs:
EMPLOYEE
SEPARATION AGREEMENT
THE Clry OF DANIA, its successors and assigns and the employees, officers,
directors anc agents thereof (collectively referred to as the 'City") and Timothy G. Tapp,
his heirs, executors, administrators, successors, and assigns (collectively referred to as
"Employee). agree to enter into this SEPARATION AGREEMENT ("Agreement") as
follows:
1, RESIGNATION
Subject to the terms and conditions set forth in this Agreement, Employee
herebv agrees to resign his employment with the City effective September 30,
1994.
2. CONSIDERATION.
ln consideration for Employee's waiver of all clams against the City (based on
any act or event occuning on or before the date of execution of this Agreement)
and lne promises made by Employee in this Agreement, the City agrees to
provice the following to Employee:
As severance compensation, Employee will receive the sum of
S10,322.00 no laterthan October 14,'1994, with said sum to be subjectto
federal withholding, social security, and Medicare deductions.
City shall pay all premiums for individual, family accident, health and life
insurance coverage through December 31, 1994 at which time employee
shall have the option to continue any insurance coverage at his own
expense.
Employee shall receive compensation for all accrued sick leave, vacation
Ieave and any other benefits accrued by Employee through September
30, 1994; said compensation to be paid to Employee no later than
October 14, 1994.
Employee's personnel records shall reflect that he was in good standing
with the City at the time of his separation.
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EXHIBIT'A"
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1.
A Within thirty (30) days from October 1, 1994, Employee shall receive all
pension fund contributions, including any accrued interest thereon, and
shall have the option of investing such funds in another qualified plan if he
shall so choose.
Employee agrees not to file any civil claim(s) against the City of Dania,
subject. however, to the City's full compliance with the terms of this
Agreement including timely payment of all funds due him.
Employee understands and acknowledges that he will not receive the benefits
provided pursuant to this Section 2 except for his waiver of clams against the City and
the fulfillment of the promises contained in this Agreement. The City understands and
acknowledges it will not receive waiver without benefits.
3. WAIVER OF RIGHTS AND CLAIMS AGAINST THE CITY
Employee knowingly and voluntarily waives any and all known and
unknourn rights and claims which he has or may have against the City as
of the date of execution of this Agreement, including but not limited to any
claim ansing under:
The Public Employee Relations Act;
Title Vll of the Civil Rights Act of 1964 and the Civil Rights Act of 1991
Sections 1981 through 1 988 of Title 42 of the United States Code
The Errployee Retirement Income Security Act of 1974
The immigration Reform and Control Act of 1986
The Americans with Disabilities Act of 1990
The Age Discrimination in Employment Act of 1967
The Older Workers Benefit Protection Act
The Fair Labor Standards Act
The Equal Pay Act of 1963
a
a
a
a
a
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. The Occupational Safety and Health Act
. The Family and Medical leave Act of .1993
. The Florida Civil Rights Act
. The Florida Wage Discrimination Law
. The Florida Equai pay Law
. The Florida Wage and Hour Laws
o The Florida Occupational Safety and Health Laws
. Any other federar, state or rocar civil or human\rights raw or any otherfederal, state or local law, regulation or ordinance; or
. Any claim under the federal or state constitution; and
. Any public policy, contract, or common law claim, including any tortclaims.
This waiver also bars any claim or demand for costs, fees, or other expenses incrudingattomeys' fees incurred in connection with any of the above-referenced craims but onryby virtue of full compliance of the city with all of the terms of this separation agieement.
Employee acknowledges and agrees that this Agreement constitutes a full and final barto any and all craims of any type that he may now or in the future nave againstlne city.
4. NO L.AWSUITS.
Employee promises not to institute or have instituted on his beharf any
lawsuit against the city based upon any craim he is waiving in section 3
above. Employee agrees that with respect to the claims he is waiving
herein, he is waiving not onry his right to recover money or other rerief in
any action that he might institute but arso that he is waiving his right to
recover money or other rerief in any action that might be brought on his
behalf by any other person or entity, incruding but not rimited to the United
States Equal Employment Opportunity Commission the United States
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Department of Justice or any other federal, state or local governmentai
agency or department.
NO RE-EMPLOYMENT.
Employee agrees that he will not apply for re-employment at the City in
the future.
6. COOPERATION.
Employee agrees to cooperate with the City in effecting a smooth
transition of the management of the City with respect to the duties and
responsibilities which Employee performed for the City. Employee further
agrees to make himself reasonably available in connection with any
request by the City regarding prior business arrangements or pending
Iitigation or litigation which may arise in the future concerning matters of
which employee has personal knowledge or which were within the
purview of Employee's management responsibilities. The City agrees to
reimburse Employee for all reasonable fees and expenses incurred by
Employee in assisting the City with any such litigation including per diem
compensation.
7, BREACH OFAGREEMENT.
Employee agrees that if he breaches any of the promises set forth
in this Agreement, the City shall have the right to terminate the
benefits payable under this Agreement and to require Employee to
return all monies paid to him pursuant to this Agreement.
ln addition, Employee agrees that if he breaches the promises set
forth in Sections 3 and 4 of this Agreement and institutes a lawsuit
or causes a lawsuit to be instituted against the City based upon any
claims that he has waived in this Agreement or if he institutes a
lawsuit to challenge this Agreement, he will pay all costs and
A
B
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attorneys'fees incurred by the City in defending against any such
claim or challenge to this Agreement if the court having iurisdiction
determines that the City is the prevailing party in such litigation.
8. ADEQUATECONSIDERATION/ADDITIONALCONSIDERATION.
Employee agrees that payment to him ofthe money and benefits pursuant
to Section 2 of this Agreement constitutes adequate and ample
consideration for the rights and claims he is waiving under this
Agreement and for the obligations imposed upon him by virtue of this
Agreement. Further, Employee agrees that this Agreement provides
him with additional or extra consideration to waive any clam of age
discrimination that he might now have against the City.
10.
A.
B.
TIME
A.
B.
The City hereby encourages Employee to consult with an attorney
before signing this Agreement.
Employee acknowledges that he has consulted his attorney before
signing this Agreement.
TO CONSIDER SIGNING AGREEMENT.
Employee acknowledges that he has been given twenty-one (21)
days after receipt of this Agreement to decide whether to sign this
Agreement.
Employee understands that he may revoke this Agreement within
seven (7) days following the day he executes this Agreement. Any
revocation within that period must be submitted, in writing, to
Michael Smith, Personnei Director, City of Dania, 100 West Dania
Beach Boulevard, Dania. Florida 33004, and state, ,,1 hereby
revoke the Separation Agreement." The revocation must be
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9. ENCOURAGEMENTTOCONSULTATTORNEY.
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postmarked and mailed or personally delivered to, Michael Smith
within seven (7) days of execution of this Agreement.
11. EFFECTIVE DATE.
This agreement shall not become effective or enforceable until Michael
Smith receives a letter from Employee in the form attached to this
Agreement as Attachment A. Such letter shall not be valid or accepted
unless it is mailed to and postmarked, or personally delivered to, Michael
Smith at the address set forth in Section 10 above after the expiration of
the seven day revocation period described in Section 10 above.
12. WAIVER OF RIGHTS AN CLAIMS AGAINST EMPLOYEE.
The City knowingly and voluntarily waives any and all known and
unknown rights and claims which the City has or may have against
Employee as of the date of execution of this Agreement based upon any
act or event occuning before the date ofthe execution of this Agreement.
13. NON-ADMISSION OF WRONGDOING.
Employee agrees that neither this Agreement nor the furnishing of any
consideration under this Agreement shall be construed as an admission
by the City of any liability or unlavvful conduct.
14, GOVERNING LAW AND INTERPRETATION.
This Agreement shall be governed and construed in accordance with the
laws of the State of Florida. lf any provision of this Agreement is declared
illegal or unenforceable by any court of competent jurisdiction and if it
cannot be modified to be enforceable, such provision shall immediately
become null and void, leaving the remainder of this Agreement in full force
and effect. However, if any of the promises contained in Sections 3 or 4
of this Agreement are declared unenforceable because of actions taken
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by Employee or on his behalf, Employee shall return to the City all monies
paid to him under this Agreement.
15. ENTIREAGREEMENT.
This Agreement sets forth the entire agreement between the City and
Employee and shall supersede any and all prior agreements or
understandings, whether written or oral, between the parties, except as
otherwise specified in this Agreement. Employee acknowledges that he
has not relied on any representations, promises, or agreements of any
kind made to him in connection with his decision to sign this Agreement
except for those set forth in this Agreement.
16. AMENDMENT.
This Agreement may not be amended except by written agreement signed
by both parties.
17. HEADINGS.
Section headings are used herein for convenience of reference only and
shall not affect the meaning of any provisions of this Agreement.
lN WITNESS WHEREOF, the parties hereto knowingly and voluntarily executed
this Separation Agreement as of the date set forth below:
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HAVING ELECTED TO EXECUTE THIS AGREEMENT AND TO FULFILL THE
PROMISES SEJ FORTH HEREIN, EMPLOYEE FREELY AND KNOWINGLY, AND
AFTER DUE REFLECTION, ENTERS INTO THIS AGREEMENT INTENDING TO
WAIVE, SETTLE AND RELEASE ALL CLAIMS HE HAS OR MIGHT NOW HAVE
AGAINST THE CITY, AS SET FORTH ABOVE.
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ATTEST:
CITY CLERK. AUDITOR
\v
THE CITY OF DANIA
By:
- Commissioner
By:
ity Man er
STATE OF FLORIDA
COUNTY OF BROWARD
The foregoing instrument was executed before me tnis /# day of
1994, by Robert A. Mikes, Robert F. Flatley and Wanda Mullikin as
Mayor, City Manager and City Clerk-Auditor, respectively, of the City of Dania,
personally known to me.
Notary Public
State of Florida at Large
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Type or Print Name of Notary
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I{Y CC]
STATE OF FLORIDA
COUNW OF BROWARD
Timothy G. Tapp
Date
Notary Public
State of Florida at Larg
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The foregoing instrument was executed before me by Timothy G. Tapp,
personally known to me, this iD aay ot ) o '+. ,'tsgc
cler0t*
Type or Print Name of Notary
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My commission expires:
APPROVED AS TO FORM AND CORRECTNESS
BY:.&bL. a&-
Frank C. Adler, City Attomey
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