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agreement) on August 22, 1991. The agreement provided that the
parties,
having agreed to compromise and settle any and all
claims, as set forth below, including, without
limitation, claims for injunctive relief, back pay,
damages, retroactive promotions, attorneys' fees, and
costs, that the said plaintiff may have against the
defendant, and/or the United States Postal Service,
and/or any former or current officers, employees and/or
agents of the United States Postal Service, it is
agreed by the parties as follows:
1. The United States Postal Service agrees to
pay to plaintiff Beverly T. Rutt-Hahn the sum of
$75,000. It is understood and agreed that plaintiff
will be responsible for the payment of any taxes with
respect to this sum.
2. The United States Postal Service agrees to
adjust the records of plaintiff Beverly T. Rutt-Hahn to
reflect a promotion to the maximum of an EAS-20 as of
January 10, 1981 through the effective date of her
retirement. This information will be transmitted by
the Postal Service to the Office of Personnel
Management (OPM) which will then be responsible for
recalculating and paying to plaintiff whatever
additional monies may be due and owing to her, and any
adjustments to her retirement, as a result of the EAS-
20 promotion information supplied by the Postal Service
adjusting plaintiff's records. * * * In addition, the
Postal Service agrees to pay to OPM the requisite
retirement contributions to the Civil Service
Retirement and Disability Fund on its behalf and on
behalf of plaintiff, necessary for OPM to process the
necessary adjustments described above. The parties
agree that the adjustment of plaintiff's records is not
intended to entitle plaintiff to any benefit other than
those monies and retirement adjustments described above
to be determined by OPM. The actions of the United
States Postal Service as set forth in paragraphs one
(1) and two (2) above are accepted by plaintiff and her
counsel as fully discharging, without limitation, all
claims of plaintiff and her counsel including but not
limited to backpay, damages, attorneys' fees and costs.
3. Upon completion by the Postal Service of the
step set forth in paragraph one (1), above, and the
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