HomeMy WebLinkAboutResolution - 2013-R0267 - Agreement - Lee Ann Dumbauld - Termination And Severance Agreement - 08/08/2013Resolution No. 2013-0267
August 8, 2013
Item No. 6.14
RESOLUTION
BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF LUBBOCK:
THAT the Mayor of the City of Lubbock is hereby authorized and directed to
execute for and on behalf of the City of Lubbock, an Agreement by and between the City
of Lubbock and Lee Ann Dumbauld, former City Manager, pertaining to her termination
from employment with the City of Lubbock and her Severance Agreement, and related
documents. Said Agreement is attached hereto and incorporated in this Resolution as if
fully set forth herein and shall be included in the minutes of the Council.
Passed by the City Council on
ATTEST:
Rebec a Garza, City Secretary
OVED AS TO
August 8, 201_1
Loomis, Acting City Manager
APPROVED AS TO FORM:
Sam Medina, City ttorney
2013.
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GLEN . OB TSON, MAYOR
AGREEMENT
This Agreement is entered into by and between the City of Lubbock, Texas ("City") and
Lee Ann Dumbauld ("Dumbauld").
WHEREAS, the City Council terminated Dumbauld's employment as City Manager on
July 15, 2013; and
WHEREAS, there is a Severance Agreement between the City and Dumbauld dated
September 21, 2005, that was approved by the City Council on that same date, that provides for
the payment of certain benefits at the termination, of Dumbauld's employment and obligates
Dumbauld to waive any rights to bring suit against the City; and
WHEREAS, the parties desire to resolve any disputes that may exist between them;
NOW THEREFORE, it is agreed as follows:
Based upon the mutual covenants expressed herein, the City and Dumbauld agree as
follows:
1. Payments.
1.1 Severance Payment: On the eighth day following Dumbauld's execution of this
Agreement, the City shall pay Dumbauld the gross sum of $350,981.19 (the "Severance
Payment"), as long as Dumbauld has not revoked this Agreement pursuant to Paragraph 6.2 of
this Agreement. Dumbauld acknowledges and agrees that this Severance Payment does not
constitute monies to which she would otherwise be entitled as a result of her prior employment
with the City, and that these monies and the release by the City in Paragraph 5 constitute fair and
adequate compensation for the promises and covenants of Dumbauld set forth in this Agreement.
1.2 Final Pay and Other Benefit Pay: On or before August 2, 2013, the City will pay to
Dumbauld a final paycheck in the amount of $865.38 for the gross amount of salary due
Dumbauld for the period prior to her termination. Dumbauld agrees the amount represents all
accrued and unpaid salary and other compensation owed to her prior to her termination and that
there is no other unpaid accrued salary or other owed to Dumbauld as of the date of this agreement.
1.3 Withholding for Taxes: All payments made under this Agreement will be subject to
payroll tax and other mandatory withholding according to law. Such amount shall be withheld
for the Severance Payment and paid by City according to law. The portion of the Severance
AGREEMENT -PAGE 1 129383v1
Payment representing the City's contribution to the Texas Municipal Retirement System of
$24,218.84 shall be paid by the City directly to the Texas Municipal Retirement System.
2. Release by Lee Ann Dumbauld. IN CONSIDERATION of the severance payment by
the City to Dumbauld, as referenced in paragraph 1, Dumbauld does hereto enter into this
Agreement and does hereby release, acquit, and forever discharge the City, its respective
predecessors, successors, assigns, owners, City Council members, partners, members, managers,
employees, directors, legal representatives, insurers, independent contractors, agents and
attorneys (the "Releasees"), of and from any and all liability, claims, demands, damages,
attorney's fees, costs, liens, expenses, services, actions, causes of action, or suit in equity, of
whatsoever kind or nature, which Dumbauld now has, whether known or unknown, arising out or
relating to her employment with the City. This release specifically includes, but is not limited to,
the following:
2.1 Anti -discrimination statutes, such as the Age Discrimination in Employment Act
("ADEA") (which prohibits age discrimination in employment); Title VII of the Civil Rights Act
of 1964 (which prohibits discrimination or harassment based on race, color, national origin,
religion, or sex); the Equal Pay Act (which prohibits paying men and women unequal pay for
equal work); the Americans With Disabilities Act, and the Rehabilitation Act of 1973 (which
prohibit discrimination based disability); 42 USC Section 1981 (which prohibits discrimination
based on race); Pregnancy Discrimination Act (if applicable); the Texas Commission on Human
Rights Act (which prohibits employment discrimination in the State of Texas based on race,
color, disability, religion, sex, national origin or age); Vietnam Era Veterans Readjustment
Assistance Act; the Rehabilitation Act of 1973; the National Labor Relations Act and any other
federal, state, or local law prohibiting employment discrimination, harassment, or retaliation of
any kind.
2.2 Other laws, such as the Family and Medical Leave Act of 1993 ("FMLA"), which
requires employers to provide leaves of absence under certain circumstances; the Worker
Adjustment and Retraining Notification Act ("WARN"), which requires that advance notice be
given of certain work force reductions; any federal, state, or local laws restricting an employer's
right to terminate employees, or otherwise regulating employment; whistleblowing laws, the
Sarbanes-Oxley Act (which prohibits retaliation against employees/whistleblowers including
those who report or caused to be reported and those who assist in investigations concerning
alleged violations pertaining to certain types of fraud, including securities fraud, involving public
companies); the Texas Labor Code, including but not limited to claims for compensation under
the Texas Payday Act and payment of benefits for on the job injuries; the Texas Whistleblower
Act (which prohibits retaliation against public employees who report suspected violations of
law); retaliation for filing any claim under federal, state or local laws; any federal, state, or local
laws enforcing express or implied employment contracts or requiring employers to deal with
AGREEMENT - PAGE 2 129383v1
employees fairly or in good faith; promissory estoppel; discharge in violation of public policy for
refusal to commit an illegal act; and any wage payment and collection law.
2.3 Tort and contract claims, such as claims for wrongful or constructive discharge,
retaliatory discharge, negligence, physical or personal injury, claims for worker's compensation
or any on the job injury or illness, emotional distress, fraud, fraud in the inducement, negligent
misrepresentation, defamation, libel, slander, invasion of privacy, interference with contract or
with prospective economic advantage, breach of oral, express or implied contract, breach of
covenants of good faith and fair dealing, and similar or related claims.
2.4 Other released claims, include, without limitation, claims: (i) under the Employee
Retirement Income Security Act of 1974; (ii) for compensation, stock options, bonuses, or lost
wages; (iii) in any way related to design or administration of any employee benefit programs;
(iv) for severance or similar benefits or for post -employment health or group insurance benefits
other than her rights under the federal continuation rights of COBRA or the Texas Continuation
option; (v) vacation pay, pension or profit sharing benefits, health or welfare benefits, bonus
compensation, commissions, deferred compensation or other remuneration (vi) for fees, costs, or
expenses of any attorneys who represent or have represented Dumbauld; or (vii) any other state,
federal or local laws relating to employment.
2.5 Unknown claims: Dumbauld understands that she is releasing the Released Parties
from claims that have accrued prior to execution of this Agreement but that she may not know
about as of the date hereof and that this is her knowing and voluntary intent even though
someday she might learn that some or all of the facts she currently believes to be true are untrue
and even though she might then regret having signed this Agreement. Dumbauld is expressly
assuming that risk and agrees that this Agreement shall remain effective in all respects in any
such case. Dumbauld expressly waives all rights she might have under any law that is intended
to protect her from waiving unknown claims, and Dumbauld understands the significance of
doing so.
3. FMLA and FLSA Rights Honored. Dumbauld acknowledges that she has received all
of the leave from work for family and/or personal medical reasons and/or other benefits to which
she believes she is entitled under the City's policy and the FMLA; that she has no pending
request for FMLA leave; that the City has not failed to accommodate or grant leave to Dumbauld
in any way because of any illness or injury to Dumbauld or any member of her family; and that
she has received all monetary compensation, including hourly wages, salary and/or overtime
compensation, to which she believes she is entitled under the Fair Labor Standards Act
("FLSA") or any state's wage payment law.
AGREEMENT - PAGE 3 129383 v 1
4. ADEA Release Requirements Satisfied. Dumbauld understands that this Agreement
has to meet certain requirements to validly release any ADEA (age discrimination) claims she
might have, and Dumbauld represents and warrants that all such requirements have been
satisfied. The City hereby advises Dumbauld that before signing this Agreement, she may take
twenty-one (21) days to consider this Agreement. Dumbauld acknowledges that: (i) she took
advantage of as much of this period to consider this Agreement as she wished before signing; (ii)
she carefully read this Agreement; (iii) she fully understands it; (iv) she entered into this
Agreement knowingly and voluntarily (free from fraud, duress, coercion, or mistake of fact); (v)
this Agreement is in writing and is understandable; (vi) in this Agreement, she waives current
age discrimination claims; and (vi) City hereby advises Dumbauld to discuss this Agreement
with her attorney (at her own expense) prior to execution and she has done so to the extent she
deemed appropriate.
5. City's Release of Dumbauld. The City hereby releases, acquits, and forever discharges
Dumbauld, her heirs, executors, administrators, successors and assigns, legal representatives,
insurers, agents and attorneys, of and from any and all liability, claims, demands, damages,
attorney's fees, costs, liens, expenses, services, actions, causes of action, or suit in equity, of
whatsoever kind or nature, which the City now has, whether known or unknown, arising out or
relating to her actions during her employment with the City. The City acknowledges that this is
a general release of known and unknown claims.
6. Review & Revocation.
6.1 Review: Before executing this Agreement, Dumbauld may take 21 days to
consider this Agreement. Dumbauld acknowledges and agrees that her waiver of rights under
this Agreement is knowing and voluntary and complies in full with all criteria of the regulations
promulgated under the Age Discrimination in Employment Act, the Older Workers Benefit
Protection Act, Title VII of the Civil Rights Act of 1964, and any and all federal, state and local
laws, regulations, and orders. The City hereby advises Employee in writing to consult with an
attorney prior to executing this Agreement. In the event that Dumbauld executes this Agreement
prior to the expiration of the 21 -day period, she acknowledges that her execution was knowing
and voluntary and not induced in any way by the City or any other person.
6.2 Revocation: For a period of 7 days following her execution of this Agreement,
Dumbauld may revoke this Agreement. If she wishes to revoke this Agreement, she must revoke
in writing delivered by hand or confirmed facsimile prior to the end of the 7`h day of the
revocation period to Thomas C. Riney, 320 South Polk Street, Amarillo, Texas 79101-1426,
fax number (806) 376-4509, or the revocation will not be effective. If Dumbauld timely revokes
this Agreement, all provisions hereof will be null and void, including the payment in paragraph 1
above. If Dumbauld does not advise Mr. Riney in writing that she revokes this Agreement
AGREEMENT - PAGE 4 129383 v 1
within 7 days of her execution of it, this Agreement shall be forever enforceable. The 8I' day
following Dumbauld's execution of this Agreement shall be the Effective Date of this
Agreement. This Agreement is not effective or enforceable until the revocation period has
expired.
Dumbauld acknowledges that she carefully read this Agreement, she understands completely its
contents, she understands the significance and consequences of signing it, and she intends to be
legally bound by its terms. Dumbauld acknowledges that she was given twenty-one (21) days to
consider executing this Agreement and that she has been advised in writing to review this
Agreement with legal counsel prior to signing it. She understands that, by entering into this
Agreement, she does not waive rights or claims that may arise after the date of her execution of
this Agreement, including without limitation any rights or claims that she may have to secure
enforcement of the terms and conditions of this Agreement. Dumbauld certifies that she has
agreed to and signed this Agreement voluntarily and of her own free will, act, and deed, and for
full and sufficient consideration, which consideration is in addition to anything of value to which
she is already entitled.
7. City acknowledges and agrees that Dumbauld, under the terms of the Severance
Agreement, is entitled to make an irrevocable decision to accept or deny retiree insurance as
described in the City's employee benefit plan, at the time of her termination of employment of
the City. Dumbauld, by her signature below, has made an irrevocable election to accept retiree
insurance and as such is eligible to obtain retiree insurance as afforded by the City employee
benefit plan.
8. The Parties will report, as may be required by law for income tax purposes, their
respective payment and receipt of the Severance Payment. Dumbauld will bear her tax liability,
if any, arising from this Agreement. Dumbauld acknowledges that the City has made no
representations to her regarding the tax consequences of any amount received by her pursuant to
the terms of this Agreement.
9. Dumbauld acknowledges and agrees that nothing in this Agreement shall be construed as
an admission of any liability for any claim in connection with Dumbauld's prior employment
with the City, any violation of federal, state or local law, ordinance, regulation or statute, actual
or implied breach of contract, commission of any tort or any other civil wrong.
10. This Agreement may not be modified or changed orally and shall be construed in
accordance with the laws of the State of Texas.
AGREEMENT -PAGE 5 129383v1
Dated: 7- 2 0/ — L3__
LEE ANN DUMBAULD
SUBSCRIBED AND SWORN TO before me, the undersigned authority on thig�c4_v
day of July, 2013.
KED Notary ublic- State of xas
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STATE OF TOM
MY Cmnmrrmm 0 o-mma /
My Commission Expires:
AGREEMENT—PAGE 6 129383v1
Dated: 08-07-1013 CITY OF LUBBOCK
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GL . RO ERTSON, MAYOR
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SUBSCRIBED AND SWORN TO before me, the undersigned authority on this q -
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day of ,2013.
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CELIAWEBB Notary ublic- State of Texas
Notary Public, State of Texas
My Conib& on E)Ores MI.2014
My Commission Expires: 13-01. 2 D l
AGREEMENT- PAGE 7 129383V1