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SETTLEMENT AGREEMENT AND GENERAL RELEASE <br /> <br /> This Settlement Agreement and General Release is made and entered into by and <br />between Don-is D. Wright ("Employee") and Cabarrus County Department of Social Services <br />and Cabarrus County (collectively, "County") in order to settle and compromise all claims <br />arising out of the cases described in Recitals A and B below. <br /> <br />RECITALS <br /> <br /> A. There is a pending legal action brought by Employee against County in the <br />North Carolina Office of Administrative Hearings captioned Dorris D. Wright v. Cabarrus <br />County Department of Social Services, 00 OSP 1506 (the "Contested Case"); <br /> <br /> B. There is a pending legal action brought by County in the Cabarms County. <br />Superior Court of North Carolina captioned Cabrrus County v. Dorris D. Wright, 03 CVS 01923 <br />(the "Judicial Review Action"), in which County seeks judicial review of the State Personnel <br />Commission's ("Commission") final decision regarding the issue of racial discrimination against <br />Employee; <br /> <br /> C. On October 22 and November 24, 2003, Employee and County <br />participated in a mediated settlement conference pertaining to the Contested Case and the <br />Judicial Review Action (collectively, the "Actions"). During the course of this mediation, <br />Employee and County reached agreement for settlement of all pending issues between them in <br />this matter, and desire to reduce the terms of this settlement agreement to writing, as reflected in <br />this document. <br /> <br /> D. The execution of this Agreement does not constitute an admission of error <br />or liability by any party. <br /> <br /> E. No other parties have sought to intervene in the Actions and neither <br />Employee nor County knows of any person who is interested in intervening. <br /> <br /> F. Pursuant to N.C. Gen. Stat. §§ 150B-22 and -31(b), Employee and County <br />wish to completely and forever resolve, by the terms of this Agreement, any and all claims, <br />liabilities and causes of action arising out of or related to any of the factual circumstances, <br />matters, procedures and allegations at issue in the Actions. <br /> <br />AGREEMENT AND GENERAL RELEASE <br /> <br /> In consideration of the mutual promises contained in this Agreement, and for other good <br />and valuable consideration, the receipt and sufficiency of which is hereby acknowledged, <br />Employee and County agree as follows: <br /> <br /> <br />