- 8 -
of that employment, or eligibility for other
severance payments or his eligibility or
participation in the Retirement Bridge Leave of
Absence or CTP.
* * * * * * *
c. This Agreement releases, but
is not limited to, claims for physical and
mental injury, claims arising under the Age
Discrimination in Employment Act of 1967, as
amended, the National Labor Relations Act of
1935, as amended ("NLRA"), Title VII of the
Civil Rights Act of 1964, as amended, the
Employee Retirement Income Security Act of
1974, as amended or any other federal, state,
or local law pertaining to employment,
including but not limited to, discrimination or
retaliation in employment based on sex, race,
national origin, religion, disability, veteran
status, age and the filing of an unfair labor
practice charge with or supplying an affidavit
to the National Labor Relations Board. This
Agreement also releases any and all claims
based on theories of contract or tort, whether
grounded in common law or otherwise.
d. This Agreement releases all
claims including those that Mr. Sherman knows
about and those that he may not know about
which have accrued at the time he executed this
Agreement.
* * * * * * *
18. Nothing in this Agreement shall be
construed as or constitute an admission with
respect to the validity of any claims or
allegations which Mr. Sherman has made or could
have made concerning his employment with IBM or
with respect to any other matter.
The settlement agreement did not apportion the $207,000 payment
among the various potential claims.
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Last modified: May 25, 2011