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<br />. <br /> <br />SETTLEMENT AGREEMENT AND RELEASE <br /> <br />This Settlemcnt Agreement and Release ("Agreement") is made and entered into by and <br /> <br />bet\yeen Bruce A. Kessel ("Kessel"), the City of Mounds View ("the City"). <br /> <br />WHEREAS, Kessel was employed by the City as a Finance Director from 1995 to July 7, <br /> <br />2001; and <br /> <br />\VHEREAS, Kesscl petitioned the Bureau of Mediation Services for reVIew of his <br /> <br />termination from the City, in an administrative proceeding docketed as Ci(v of Alounds' Vie}t', <br /> <br />Afinnesota - and - Bruce Kessel, Falcon Heights, AIinnesota, BMS Case Number 02-PIR-128; and <br /> <br />\VHEREAS, the City denies the legitimacy and validity of all claims made by Kessel in his <br /> <br />action; and <br /> <br />\VHEREAS, in the interest and compromise of the claims, charges and causes of action <br /> <br />. alleged by Kessel, in order to avoid the costs and expenses of arbitration, and without any admission <br /> <br />relating to liabiIity or to damages, it is the mutual desire of Kessel and the City to settle amicably any <br /> <br />and all claims, charges and causes of aetion that have been raised or that could have been raised by <br /> <br />Kessel in regard to his employment or"' termination from employment with the City, except as <br /> <br />expressly stated herein. <br /> <br />NOW, THEREFORE, IN CONSIDERATION OF THE FOREGOING, THE PARTIES <br />MUTL'ALL Y AGREE: <br /> <br />I. In full and complete settlement of all claims, counterclaims, charges and causes of <br /> <br />action related in any way to his employment and his termination from employment, or otherwise <br /> <br />alleged by Kessel. including but not limited to any and all claims asserted in his Petition for Review <br /> <br />and any claims for attorneys fees or eosts, without any admission as to liability or damages, and in <br /> <br />. <br /> <br />Page 1 of3 <br />