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It addresses the underlying government claim and related complaints, sets payment obligations within specified timelines, and allocates tax responsibilities. The agreement includes check amounts for the parties and attorneys’ fees, provides dismissal and withdrawal requirements, and grants broad mutual releases, including waiver of California Civil Code section 1542.",{"@graph":63,"@context":119},[64,80,102],{"@type":65,"itemListElement":66},"BreadcrumbList",[67,71,74,77],{"item":68,"name":69,"@type":70,"position":9},"https://docshare.wps.com","Home","ListItem",{"item":72,"name":10,"@type":70,"position":73},"https://docshare.wps.com/template/",2,{"item":75,"name":41,"@type":70,"position":76},"https://docshare.wps.com/template/letters/",3,{"item":78,"name":59,"@type":70,"position":79},"https://docshare.wps.com/template/settlement-agreement-and-general-release-of-all-claims-execution/281663/",4,{"url":78,"name":59,"@type":81,"image":82,"author":87,"headline":59,"publisher":90,"fileFormat":93,"inLanguage":57,"description":61,"dateModified":94,"datePublished":95,"encodingFormat":93,"isAccessibleForFree":96,"interactionStatistic":97},"DigitalDocument",{"url":83,"@type":84,"width":85,"height":86},"https://docshare.wps.com/thumbnails/settlement-agreement-and-general-release-of-all-claims-execution/281663.png","ImageObject",442,249,{"name":88,"@type":89},"4398046744996","Person",{"url":68,"name":91,"@type":92},"DocShare","Organization","application/pdf","2026-10-19","2026-09-16",true,{"@type":98,"interactionType":99,"userInteractionCount":101},"InteractionCounter",{"@type":100},"ViewAction",9,{"@type":103,"mainEntity":104},"FAQPage",[105,111,115],{"name":106,"@type":107,"acceptedAnswer":108},"Who are the parties to the Settlement Agreement?","Question",{"text":109,"@type":110},"The agreement is entered into between Stephen O’Brien (Plaintiff) and the Board of Trustees of California State University (CSU).","Answer",{"name":112,"@type":107,"acceptedAnswer":113},"What claims and actions are being resolved under the agreement?",{"text":114,"@type":110},"The agreement resolves disputes and claims arising from and/or relating to the government claim, internal complaints (including the December 15, 2020 retaliation complaint), and the related action in Santa Clara County Superior Court.",{"name":116,"@type":107,"acceptedAnswer":117},"How are taxes handled and what is CSU’s related obligation?",{"text":118,"@type":110},"Plaintiff agrees tax consequences are his responsibility if any part is determined taxable, and Plaintiff indemnifies CSU regarding tax authority claims. CSU also will issue appropriate tax forms in connection with the payments.","https://schema.org",{"og:url":78,"og:type":121,"og:title":59,"og:site_name":91,"og:description":61},"article",{"robots":123,"canonical":78},"index,follow",{"doc_id":125,"site_id":56},281663,1790714818,{"code":4,"msg":5,"data":128},{"doc_id":125,"user_id":129,"nickname":88,"user_avatar":60,"doc_module":9,"category_id":40,"category_name":41,"doc_title":59,"doc_description":61,"doc_content":130,"file_id":131,"file_url":132,"file_type":133,"file_size":134,"view_count":101,"is_deleted":4,"is_public":9,"is_downloadable":9,"audit_status":9,"page_count":79,"language":135,"language_code":57,"site_id":56,"html_lang":57,"table_of_contents":136,"faqs":137,"seo_title":138,"seo_description":61,"update_tm":139,"read_time":73},4398046744996,"DocuSign Envelope ID: EE930571-20AA-473F-AA97-08518AE44D14  \nSETTLEMENT AGREEMENT AND GENERAL RELEASE OF ALL CLAIMS  \n1.  Parties:  \nThis Settlement Agreement and General Release (the “Agreement”) is entered into between Stephen O’Brien (“Plaintiff”) and the Board of Trustees of the California State University (“CSU”) . Plaintiff and CSU may be referred to as a “Party” or the “Parties.”  \n2.  Claims:  \n2.1 Plaintiff submitted a government claim against CSU on or around August 26, 2020 and various internal complaints on and after December 15, 2020, including a retaliation complaint dated December 15, 2020 (together, the “Claims”) .  \n2.2 Plaintiff filed an action in the Superior Court of California, City and County of Santa Clara, Case No. 21CV379038, entitled Stephen O’Brien v. Board of Trustees of the California State University et al. (the “Action”) .  \n2.3 The Parties wish to resolve all disputes and claims between them, including those arising from and/or relating to the Claims and the Action, through the date of this Agreement.  \n3.  Settlement Terms:  \n3.1 This settlement is a compromise of disputed claims and is not an admission by any Party of any liability. CSU specifically denies any wrongdoing of any kind whatsoever and enters into this Agreement to avoid the further costs of litigation.  \n3.2 Within 30 calendar days following the later of (1) receipt by undersigned counsel for CSU of this Agreement executed by Plaintiff and Plaintiff’s counsel; (2) receipt by undersigned counsel for CSU of requested tax-related forms for Plaintiff’s counsel and Plaintiff; and  \n(3) Plaintiff’s withdrawal of all Claims by execution of this Agreement pursuant to Section 3.7, CSU shall issue the following checks:  \ni) One check payable to Stephen O’Brien in the amount of $225,000.00, in full, final, and complete settlement of all disputes, including but not limited to those arising from or relating to the Action and the Claims for which CSU will issue a 1099;  \nii) One check payable to Cotchett, Pitre & McCarthy in the amount of $190,857.06 for attorneys’ fees; and  \niii) One check payable to Stephen O’Brien in the amount of $144,142.94, less standard withholdings and authorized deductions, for alleged lost wages and other employment benefits.  \n3.3 Plaintiff agrees that neither Plaintiff nor his attorneys have relied on any representations as to the tax consequences of this Settlement Agreement and General Release. Plaintiff further agrees that if any taxing authority determines that any part of the settlement is taxable, Plaintiff will be solely responsible for all such taxes, and that Plaintiff shall  \nDocuSign Envelope ID: EE930571-20AA-473F-AA97-08518AE44D14  \nindemnify and hold harmless CSU from liability to any tax authority, and from any claims made in any administrative or judicial action to collect taxes from CSU. Ifa proceeding is instituted against CSU, CSU will give Plaintiff notice of the proceedings at his last known address and Plaintiff will be obligated to defend and indemnify CSU. In connection with the payments identified in Section 3.2, CSU will issue the appropriate tax forms.  \n3.4 Plaintiff hereby releases and forever discharges the State of California and CSU, and each of their agents, attorneys, current and former employees, officers, directors, trustees, auxiliary organizations, insurers, representatives and all persons acting by, through, under or in concert with any of them, including but not limited to Marie Tuite and San José State University,(collectively referred to as “CSU Released Parties”) from any and all manner of claims, actions, obligations, attorneys’ fees, damages or liabilities of any kind whatsoever, whether known or unknown, fixed or contingent, which plaintiff may have or claim against CSU Released Parties, or any of them, including, without limiting the generality of the foregoing, any claims in any way arising out of, based upon, or related to Plaintiff’s hiring, employment with CSU, the","cbCaikogCLCQpBSj","https://ap.wps.com/l/cbCaikogCLCQpBSj","pdf",499989,"English","# Settlement Agreement and General Release of All Claims - Execution\n## Parties\n## Claims\n## Settlement Terms\n## Release and Waiver","[{\"question\":\"Who are the parties to the Settlement Agreement?\",\"answer\":\"The agreement is entered into between Stephen O’Brien (Plaintiff) and the Board of Trustees of California State University (CSU).\"},{\"question\":\"What claims and actions are being resolved under the agreement?\",\"answer\":\"The agreement resolves disputes and claims arising from and/or relating to the government claim, internal complaints (including the December 15, 2020 retaliation complaint), and the related action in Santa Clara County Superior Court.\"},{\"question\":\"How are taxes handled and what is CSU’s related obligation?\",\"answer\":\"Plaintiff agrees tax consequences are his responsibility if any part is determined taxable, and Plaintiff indemnifies CSU regarding tax authority claims. CSU also will issue appropriate tax forms in connection with the payments.\"}]","Settlement Agreement and General Release of All Claims - Execution | PDF",1789567307]