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g. Payment of a Special Compensation Award of
$5,000 for the fiscal year ended June 1,
1985.
h. Payments of any amounts from the termination
of the Partner/Director’s retirement fund
which would be paid to me if I were not
terminating my employment with DH&S.
i. Payment of any unpaid installments of Net
Supplemental Compensation Award and Special
Compensation Award at any time I request
after June 1, 1985.
j. Reimbursement for my personal legal expenses
incurred to date (maximum of $8,000) in
connection with the termination of my
employment with DH&S.
* * * * * * *
5. In consideration of our mutual acceptance of the
terms set forth above and when DH&S accepts these
terms, DH&S and its predecessors, successors and
assigns will forever release me and my heirs,
executors, administrators and assigns, and I and
my heirs, executors, administrators and assigns
will forever release DH&S and its predecessors,
successors, assigns, and present or former
partners, directors or employees from all rights,
claims or causes of action which we have or may
have against each other relating to, arising out
of, or based upon my employment by DH&S, my tenure
as a director of DH&S, services performed by me in
my capacity as an employee or director of DH&S, or
the termination of my employment by or tenure as a
director of DH&S, except the right to enforce the
mutual obligations provided by this agreement.
The agreement was entered into in an adversarial context, at
arm’s length, and in good faith. At no time during the
negotiations leading up to this agreement did Mr. Forste submit
any documents to DHS to substantiate any specific amount for
personal injuries. Mr. Forste never informed DHS that he was
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