Resolution 2019-17 Resolution No.2019-17
A RESOLUTION APPROVING A TRANSITION AGREEMENT
AND MUTUAL RELEASE
BE IT RESOLVED, by the Mayor and City Council of the United City of
Yorkville, Kendall County, Illinois, as follows:
Section 1. That the TRANSITION AGREEMENT AND MUTUAL RELEASE
attached hereto and made a part hereof by reference as Exhibit A, is hereby approved,
and John Purcell, Mayor, and Lisa Pickering, City Clerk, be and are hereby authorized to
execute said agreement on behalf of the United City of Yorkville.
Section Z. This Resolution shall be in full force and effect upon its passage and
approval as provided by law.
Passed by the City Council of the United City of Yorkville, Kendall County, Illinois this
28th day of May, 2019.
CITY CLERKU
KEN KOCH ABSENT DAN TRANSIER AYE
JACKIE MILSCHEWSKI AYE ARDEN JOE PLOCHER AYE
CHRIS FUNKHOUSER AYE JOEL FRIEDERS AYE
SEAVER TARULIS ABSENT JASON PETERSON AYE
Approved by me, as Mayor of the United City of Yorkville, Kendall County, Illinois,this
'31 sf day of M4Y , 2019.
MA
Resolution No.2019-17
Page 1
TRANSITION AGREEMENT AND MUTUAL RELEASE
This TRANSITION AGREEMENT AND MUTUAL RELEASE(Agreement") is entered
into by and between POLICE CHIEF RICHART T.HART("Employee")and the UNITED CITY
OF YORKVILLE, a municipal corporation (the "City"). Employee and the City are sometimes
collectively referred to as the("Parties")and each is individually referred to as a"Party".
AGREEMENT
NOW, THEREFORE, for and in consideration of the provisions, covenants and mutual
promises contained herein,the Parties hereby agree as follows:
1. Employment Status.
a. Employee and the City entered into an "Employment Agreement" that
covered the period from May 12,2015 through and including May 13,2019
which is the date that the then-sitting Mayor's term expired.
b. On May 14, 2019 the Employee's employment with the City and its Police
Department was continued on a temporary, "at will" basis while the City
searches for Employee's successor in the role of Chief of Police. There is
nothing in this Agreement that alters Employee's status as an "at,will
employee"of the City.
C. Employee will continue to perform services as Police Chief to the City
during the period from May 14,2019 through the date that the City's Mayor
provides written notice to the Employee informing him of his desire to end
their employment relationship for any or no reason, but in no event later
than November 30, 2019. This period is referred to in this Agreement as
the"Transition Period".
d. The day that immediately follows the end of the Transition Period will be
referred to as Employee's voluntary "Retirement Date". As of the
Employee's Retirement Date,Employee will be permanently relieved of all
authority and responsibility to perform services for the City except as
provided in Section#3(b)and(c)below.
2. Consideration/Payment for Services During the Transition Period:
a. Throughout the Transition Period, Employee will receive his normal base
pay (including the longevity payment available to him pursuant to City
policy)that was in effect as of the start of the Transition Period(5/14/19).
b. Throughout the Transition Period,Employee will continue to participate in
the City's benefit programs(including but not limited to health, life,dental
and vision insurance for Employee and his eligible dependents)on the same
basis as other similarly situated employees who are employed as a
Department Head with the City.
1
C. As of the Employee's Retirement Date, Employee and his eligible
dependents will continue to be eligible to participate in the City's group
health insurance program pursuant to the COBRA provisions of federal law.
Employee will receive a letter at his home address from the City that sets
forth the manner in which Employee may obtain COBRA covered for
Employee and his eligible dependents through the City's benefit portals.
d. As consideration for Employee's promises in this Agreement,the City will
reimburse Employee for the premium costs he incurs to obtain health
insurance coverage for Employee and his eligible dependents during the
period from his Retirement Date through the earlier o£ (i) the date that is
six (6) months after the Employee's Retirement Date, or (ii) the date that
Employee obtains health insurance coverage for Employee and his eligible
dependents from another employer (the "Health Insurance Payments").
Provided, however, Employee is required to do all of the following: (i)
remain in compliance with his obligations under this Agreement and the
Addendum,(ii)pay his share of the premium costs as if he were still actively
working, and(iii)comply with the applicable laws to be eligible to receive
the Health Insurance Payments.
e. Throughout the Transition Period, Employee will continue to have access
to a City owned take home vehicle for his work and personal use subject to
Employee's compliance with the terms of City's published Take Home
Vehicle Policy and all applicable laws related to the use of said vehicle.
3. Employee Obligations. In return for the promises of the City as set forth
herein including the City's willingness to provide the Health Insurance Payments and other
privileges in this Agreement to Employee:
a. During the Transition Period, the Employee will perform such services as
directed from time to time by the Mayor of the City. Employee agrees to
perform such services in good faith and he will report directly to the Mayor
throughout the Transition Period.
b. After his Retirement Date,Employee agrees to make himself available from
time to time upon reasonable prior request of either the Mayor (or his
designee)and/or the Employee's successor in the role of Chief of Police(or
his/her designee)to answer questions or assist with brief discussions related
to matters that were within Employee's knowledge about the City and/or its
Police Department.
C. Among the specific forms of cooperation that Employee will provide to the
City (and its Police Department) after his Retirement Date pursuant to this
Paragraph#3 includes Employee's promise to fully cooperate with the City
in the preparation and defense of any claims,grievances, lawsuits or causes
of action that were pending against the City(and/or the Police Department)
related to matters that arose during the period in which Employee served as
2
Police Chief. Employee acknowledges that the Health Insurance Payments
and other consideration set forth in this Agreement are sufficient
consideration to support Employee's promises in this Agreement (and the
Addendum) and adequate compensation for any services provided by
Employee after his Retirement Date pursuant to this Paragraph#3.
d. Employee agrees and acknowledges that the benefits and other privileges made
available to him by virtue of this Agreement constitute adequate and sufficient
consideration to support all of Employee's promises in this Agreement and the
separate Addendum referenced in Section#14 below.
4. Additional Consideration.In addition to the Health Insurance Payments and other
privileges referenced above:
a. As of the date of execution of this Agreement by Employee, the Parties
agree and acknowledge that Employee had earned and unused paid vacation
and/or sick time available for his use pursuant to the City's published
personnel policies (the "Paid Time Off'). On the first full payroll period
that is at least one full month after the effective date of Employee's
Retirement,Employee will receive a payment equal to the full value(100%
payment) of any remaining hours of Paid Time Off that Employee accrued
prior to his Retirement Date. Upon Employee's receipt of this Paid Time
Off payment,Employee acknowledges that he will have been fully paid and
at all applicable rates for all earned benefit time available to him arising out
of his employment relationship with the City. All such payments will be
subject to normal and legally required payroll and other deductions.
b. The City will issue Employee a retirement I.D. card, and badge in
accordance with the terms and policies applicable to other similarly situated
employees who retire from the Department. The items referenced in this
Section #4 will be made available to Employee within seven (7) calendar
days of the effective date of the Addendum referenced in Section#14 below,
provided Employee timely executes that document (and this Agreement)
and does not revoke his acceptance pursuant to its/their terms.
5. Mutual Releases.
a. Except for a claim based upon a breach of this Agreement, Employee does
hereby fully, finally, and unconditionally release and forever discharge the
City's Released Parties (defined below) from any and all actions or claims
accruing through the time of execution of this Agreement by Employee. By
way of explanation,this release by Employee resolves all claims,liabilities,
suits, discrimination or other charges, workers' compensation cases,
demands,debts,liens.damages,costs,grievances,injuries,actions or rights
of action of any nature whatsoever, known or unknown,whether related or
unrelated to his employment, the separation of his employment, any
statements made by or alleged to have been made by or on behalf of any of
3
the City's Released Parties regarding Employee's employment or prior to
Employee's execution of this Agreement. Employee further waives the
reasons for Employee's separation, and/or any other matter accruing any
right to any form of recovery, compensation or other remedy in any action
brought by him or on his behalf against any of the City's Released Parties.
b. Except for a claim based upon a breach of this Agreement, the City, for
itself, and on behalf of its respective parents, subsidiaries, divisions,
partners,joint venturers, and/or affiliated businesses or entities of the City
on behalf of its past and present directors, officers,board members, agents,
attorneys, employees, representatives, trustees, administrators, and
fiduciaries, acting in their official capacities as representatives of the City
does hereby fully,finally,and unconditionally release and forever discharge
Employee and his respective agents. attorneys, heirs, executors,
administrators and legal representatives ("Employee Released Parties"),
from any and all actions or claims accruing prior to the City's execution of
this Agreement. By way of explanation,this release by the City resolves all
claims, liabilities, suits or other charges,personal injuries, demands, debts,
liens,damages,costs,grievances, injuries,actions or rights of action of any
nature whatsoever, known or unknown, whether related or unrelated to
Employee's employment or separation of employment, occurring and/or
accruing prior to the City's execution of this Agreement. The City further
waives any right to any form of recovery,compensation or other remedy in
any action brought by it or on its behalf.
C. Without limiting the foregoing terms,this Agreement specifically includes
all claims arising from any federal, state or local constitution, statute,
regulation, rule, ordinance, order, public policy, contract or common law,
including but not limited to any claim of privacy, defamation or wrongful
termination, all claims under 42 U.S.C. 1983, the Age Discrimination in
Employment Act as amended ("ADEA"), the Family and Medical Leave
Act as amended, the Illinois Human Rights Act (such as discrimination
claims based on Employee's marital status, alleged or perceived disability
or any other legally protected category), and the Americans with
Disabilities Act as amended.
d. In addition to releasing the causes of action set forth above,this Agreement
releases all claims for equitable and legal relief,attorneys'fees and costs.In
particular, this Agreement is intended to be a resolution of any possible
claims to the fullest extent of the law through the time of execution of this
Agreement by Employee and the Parties agree that neither party is a
"prevailing party." Moreover,the Parties specifically intend and agree that
this Agreement fully contemplates all claims for attorneys' fees and costs,
and hereby waives,compromises,releases and discharges any such claims.
e. Employee agrees that this release includes all claims and potential claims
against the City, all Departments of the City and all members of the City
4
Council, including its/their predecessors, successors,heirs, and assigns,and
its/their past, present and future directors, officers, elected or appointed
officials, members, agents, attorneys, employees (including without
limitation the City's present and former Chiefs of Police and the City's
current and previously elected Mayors) and all of the committee members,
commissioners, administrators, fiduciaries and insurers, jointly and
severally,in their individual,fiduciary and corporate capacities(collectively
referred to as the "the City's Released Parties").
f. Specifically exempt from the releases under this Section#5,however,is any
requirement or obligation that the City and/or Employee has to cooperate
under any statute, regulation, or funding agreement, including, but not
limited to,the Illinois Governmental Ethics Act or otherwise.
g. This Section#5 does not restrict Employee from pursuing a claim under the
tender back provisions of the ADEA in the event he alleges and that he did
not knowingly and/or voluntarily enter into this Agreement, except as
provided by law.
6. Non-disparagement.
a. To the best of their knowledge,the Parties agree Employee is not the subject
of any internal or external investigation of misconduct as of the "Effective"
date of this Agreement,as defined in Section#12 below.
b. Employee agrees not to make any disparaging or defamatory remarks
regarding the City's Released Parties whether orally, in writing, or via
electronic means (e.g., social media or blogging). This paragraph shall not
apply to any communications between Employee and his spouse,immediate
family, accountants and attorneys, or as expressly authorized by law or
lawful process.
C. The City likewise agrees that the City's Administrator and the City's Mayor
will not make any disparaging or defamatory remarks regarding Employee's
employment history with the City.
7. Representation & Warranties. Except as provided above, the Parties represent
and warrant that neither has filed nor will they file any claims against the other Party (including
the Employee Released Parties and the City Released Parties), and that each Party's obligations
under this Agreement, including the payment of monies, are conditioned upon this representation.
Employee represents that in negotiating the terms of this potential agreement, he has not already
disclosed the proposed terms to any third-parties(except to his attorneys(s)),nor has he disclosed
any confidential information that he was obligated to maintain while a City employee. Employee
represents and warrants further that there are no unreported work-related injuries or illnesses and
that he has been allowed to take all medical leaves of absence that he has sought.
8. Confidentiality Oblieations:
5
a. Employee understands and agrees that while he was employed by the City,
he had an obligation to maintain certain confidential information,including
but not limited to,information that is subject to the attorney-client privilege.
As a further inducement for the City to enter into this Agreement,Employee
agrees to continue to maintain all such confidential information as
confidential, and agrees not to use, reveal, report, publish, post on the
internet or Intranet, disclose or transfer, directly or indirectly, any of the
City's confidential information for any purpose except as expressly
authorized by the then appointed City Administrator (or designee).
Employee also agrees to take all reasonable measures to prevent the
unauthorized use, misappropriation and/or disclosure of the City's
confidential information and to prevent unauthorized persons or entities
from obtaining, misappropriating or using the City's confidential
information(in any form).
b. Upon his Retirement Date, Employee shall promptly return all the City
information and materials and tangible information or property owned by
the City,including any and all manuals,notes,plans,credit cards,keys,pass
cards, computer files, lists, reports, proposals, technical information, and
reproductions thereof which relate in any way to the City's operations,
business assets, employee files or records, or any of the foregoing items
covered by this paragraph. Employee shall also promptly provide the City
with the passcode to any cellphone, laptop computer I-pad or other
computerized device to which he has been assigned (hereinafter, the
"Yorkville Computerized Devices"). Upon request of the Mayor (or
designee), Employee will provide the City with the passcodes to all
Yorkville Computerized Devices and he will answer questions presented to
him about the types and extent of which he obtained access to information
of the City following his Retirement Date.
C. Upon the Retirement Date, Employee will no longer have access to or
privileges to use any City vehicle for any purpose.
9. Complete Agreement. Employee understands this Agreement (and the
Addendum) sets forth all of the terms and conditions of the agreement between the Parties and
that, in signing this Agreement. Employee cannot rely and has not relied upon any prior verbal
statement regarding the subject matter,basis or effect of this Agreement,and that all clarifications
and/or modifications of this Agreement must be in writing and signed by both parties to be
effective as to Employee.
10. Neutral Construction. The language of all parts of this Agreement shall in all
cases be construed as a whole, according to its fair meaning, and not strictly for or against either
of the parties regardless of the drafter. This Agreement supersedes any and all prior agreements,
understandings and communications between the Parties.
11. Non-Admission. This Agreement shall not be construed as: (a) an admission by
the Employee Released Parties or the City Released Parties of any: (i) liability or wrongdoing,(ii)
6
breach of any agreement, or (iii) violation of a statute, law or regulation; or (b) a waiver of any
defenses as to those matters within the scope of this Agreement.
12. Time to Consider Agreement. Employee understands that he been given twenty
one (21) days from the date this Revised Agreement was presented to consider and sign this
Agreement(the "Consideration Period'), and Employee agrees that this Consideration Period has
been reasonable and adequate. Employee hereby waives the right to any remaining days in the
Consideration Period, and agrees the Consideration Period is expired as of his execution of this
Agreement. Following his execution of this Agreement, Employee will have seven(7) days from
the date he signs this Agreement to revoke it if he so desires (the "Revocation Period'). This
Agreement shall not become effective or enforceable until the Revocation Period has expired(the
"Effective Date"). If Employee has not communicated his acceptance of this offer to the City
before the expiration of this Consideration Period,this offer automatically expires at that time,and
the City is not required to take any further action to rescind or otherwise withdraw the terms of
this Agreement.
13. Release Addendum. As a material condition of this Agreement, Employee also
agrees to timely execute and comply with the terms of a separate Release Addendum that includes
a release and waiver of claims and causes of action rights that is identical to the language contained
in Section#5 of this Agreement to cover the period from the date of Employee's execution of this
Agreement through and including Employee's Retirement Date.
14. Right to Counsel.Employee understands that he was informed of this right and he
acknowledges that he has been advised by competent legal counsel of his own choosing in
connection with the review and execution of this Agreement. Employee also agrees that had the
opportunity to be represented by counsel of his choice respect to all matters arising out of his
employment that arose through the time of execution of this Agreement by Employee. Employee
also acknowledges and agrees that he has had an opportunity to and did negotiate over the teens
of this Agreement through his attorneys)and the attorney(s)for the City.
15. Employee's Acknowledgments.Employee states that he has completely read this
Agreement and acknowledges that it has been written in a manner that Employee has understood
its contents. Employee freely, voluntarily and without coercion enters into this Agreement.
Further, Employee agrees and acknowledges that he has had the opportunity to investigate all
matters pertaining to any claims he might have and that the waiver and release of all rights or
claims he may have under any local, state or federal law, and under any contract or other
agreement, is knowing and voluntary.
7
16. City Council Approval. The City's obligations under this Agreement are subject
to the approval of the authorized representatives of the City Council.
READ CAREFULLY. THIS DOCUMENT CONTAINS
A FULL RELEASE OF ALL KNOWN AND UNKNOWN CLAIMS TO THE FULLEST
EXTENT OF THE LAW
RICHA T UNITED CITY RKVILLE
Date: 'S f 5 Date: J ,�
8
RELEASE ADDENDUM
This Release Addendum ("Addendum") is entered into by and between RICHARD T.
HART ("Employee") and the UNITED CITY OF YORKVILLE ("Yorkville"). In consideration
of the mutual promises and obligations contained herein,the Parties agree as follows:
1. The Parties entered into an Agreement and Mutual Release ("Agreement") that is
attached to this document whereby the City agreed to provide specific consideration to
Employee in exchange for his promises reflected in both that Agreement and this
Addendum. Employee acknowledges and agrees that the Health Insurance Payments
as set forth in the Agreement constitute adequate legal consideration for Employee's
promises contained in this Addendum as well as the Agreement.
2. Pursuant to Section #13 of the Agreement, Employee promised to execute this
Addendum which constitutes a full and complete waiver of any and all claims which
Employee may have against any of the Released Parties (as defined in Section #6 of
the Agreement) and which may relate to or arise out of any act or omission of any of
the Released Parties that arose from the time of Employee's execution of the Agreement
through and including Employee's actual last day of active employment with the City
(which will be no later than November 30,2019).
3. This waiver includes,without limitation, a complete waiver of any and all claims that
were or could have been raised by Employee and/or on his behalf, including (without
limitation)any claim or cause of action based upon or arising out of any of the laws or
causes of action identified in Section#5 of the Agreement.
4. Further, in the event of an Employee breach of this Addendum(and/or the Agreement),
the Parties agree that Employee will not have truly earned any of the consideration,
further consideration or other privileges referenced in the Agreement (and/or this
Addendum).
5. It is expressly understood and agreed that, by entering into this Addendum, the
Released Parties do not in any way,either directly or indirectly,admit to any violation
of or liability under any law, regulation, policy or contract, and Employee
acknowledges that no such violation has occurred.
6. Employee declares that: (a) he has read and understands all the terms of this
Addendum; (b)Employee,having received this Addendum at the time he received the
Agreement; (c)Employee cannot execute this Addendum prior to his Retirement Date
after which he can sign and return it to the City; (d) no promise, inducement or
agreement has been made except as expressly provided herein (and/or in the
Agreement); (e) it contains the entire agreement between the parties (including the
Agreement and all other agreements incorporated therein);(f)Employee acknowledges
that he was given at least 21-days to consider the terms of this
Addendum and at least 7 days after he signed this Addendum (but not prior to his
Retirement Date) during which he may revoke his acceptance of this Addendum if he
9
so desires;and(f)Employee entered into this Addendum fully,voluntarily,knowingly
and without coercion.
RIC T. T UNITED CITY OF VILLE
Date: t3(7 arc) I cl Date: J
V
10