- 6 -
and (2) $15,348.84 "in the form of a discharge of * * *
[petitioner's] indebtedness to CMS". In addition, the agreement
provided that petitioner would be paid all unused vacation pay
and earned but unpaid salary. The agreement further provided:
4. In consideration for the promises referred to
herein, * * * [petitioner] * * * does hereby fully,
finally and unconditionally release and forever
discharge CMS and its affiliates and their respective
former and present officers, agents, employees,
directors and shareholders, * * * in their personal and
corporate capacities, from any and all liabilities,
claims, rights, obligations, charges, damages, costs,
expenses, attorneys' fees, suits, actions, causes of
action and demands, of any and every kind, nature and
character, known or unknown, liquidated or
unliquidated, absolute or contingent, in law or in
equity, enforceable under any local, state or federal
order, including without limitation Title VII of the
Civil Rights Act of 1964, as amended, 42 U.S.C. section
1001 et seq., and the District of Columbia Human Rights
Law, as amended, D.C. code section 1-2511 et seq.,
which * * * [petitioner] * * * may now have, [has] ever
had or may in the future have, which arise out of or
are in any way connected with * * * [petitioner's] past
employment with CMS or the termination of said
employment or which arise out of or are in any way
connected with any past actions or omissions of CMS,
its affiliates, or their former and present officers,
agents, employees, directors or shareholders, including
without limitation retaliatory discharge claims,
contract claims, tort claims and claims for wages,
compensation, benefits, compensatory damages, punitive
damages and reinstatement. * * *
* * * * * * *
6. As further consideration for the promises referred
to herein, * * * [petitioner] agrees that, without the
express written authorization of an officer of CMS,
* * * [petitioner] will not directly or indirectly
disclose to any third party, * * * any of CMS's trade
secrets or other confidential information not known to
the general public with respect to the business
operations of CMS or its affiliates, including, but not
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