Jared R. and Naylene M. Nield - Page 9




                                        - 8 -                                         
                    Q  Anything else that he said or did, that * * *                  
               [the supervisor] said or did that you thought was                      
               sexually harassing other than everything we’ve talked                  
               about so far?                                                          
                    A  Well, there’s nothing that stands out in my                    
               mind.                                                                  
                                                                                     
               On March 20, 1998, Ms. Nield and Goer executed a document              
          entitled “SETTLEMENT AGREEMENT AND GENERAL RELEASE” (settlement             
          agreement).  The settlement agreement provided in pertinent part:           
                    1.  Payment Terms.  The Company [Goer] shall pay                  
               Nield and her attorneys the amounts set forth below                    
               within fourteen (14) days after receipt by the Com-                    
               pany’s counsel of an original of this Settlement Agree-                
               ment and General Release executed and dated by Nield.                  
               The payment shall be made in the following manner:                     
               a.   The Company will pay and cause to be delivered to                 
                    Nield’s attorney, David T. Berry a check made                     
                    payable to Naylene Nield in the gross amount of                   
                    Three Thousand Dollars and No/100 ($3,000.00),                    
                    less required payroll deductions.  An IRS Form W-2                
                    will be issued to Nield by the Company.                           
               b.   In addition to the foregoing payment, the Company                 
                    will pay Nield the sum of Twenty-nine Thousand                    
                    Dollars and No/100 ($29,000.00) as non-wage con-                  
                    sideration for general compensatory damages for                   
                    pain and suffering incurred by Nield relating to                  
                    her claims of intentional discrimination and al-                  
                    leged sexually hostile working environment experi-                
                    enced by Nield while working at Goer.  This amount                
                    will be paid by separate check made payable to                    
                    Nield, and the Company will issue an IRS Form 1099                
                    reflecting this amount.                                           
                  *       *       *       *       *       *       *                   
                    2.  Mutual Release and Covenant Not To Sue.                       
                    a.  * * * Nield, hereby fully, finally and uncon-                 
               ditionally releases and forever discharges Goer from                   
               and for any and all claims, liabilities, suits, dis-                   





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