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In the Matter o£ <br />MDHR File No. 71166 <br />EEOC File No. 26e202000060 <br />MIKE ZAPPA, <br />Charging Party, <br />SETTLEMENT AGREEMENT <br />AND RELEASE OF CLAIMS <br />vs. <br />CITY OF ELK RIVER, <br />Respondent. <br />This Settlement Agreement and Release of Claims ("Agreement") is made by and <br />between Mike Zappa ("Employee") and the City of Elk River ("City"). <br />WHEREAS, on or about December 31, 2019, Mike Zappa filed an employment- <br />related charge of discrimination against the City with the Minnesota Department of <br />Human Rights; <br />WHEREAS, on or about July 19, 2022, MDHR found probable cause to believe <br />that Respondent violated the MHRA; and <br />WHEREAS, the City has denied any liability or wrongdoing whatsoever relating <br />to the allegations in Mike Zappa's claim; <br />WHEREAS, in order to avoid the expense and uncertainty of litigation, the parties <br />desire to mutually resolve and settle all disputes among them, known and unknown, in <br />accordance with the terms and conditions hereinafter set forth; and <br />