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FLORIDA

DIVISION OF ADMINISTRATIVE HEARINGS

[plfName]	)	Case No (LT)
Petitioner	)	[caseNo]
)
v.	)
)
[defName]	)
Respondent	)

SETTLEMENT OFFER

Laws	[§768 FS], [42 USC §1981], [42 USC §1983], [ADA], [ADEA], [EPA], [FCRA], [FFHA], [FHA], [Title VI], [Title VII], [WBL]
From:	[plfName]
To:	[defName]

Full Resolution?	[Yes/No]
Conditional?	[Yes/No]

Waivers Received	[wvNum]
Non-Monetary Stipulations	[stipNum]

Compensatory Damages	$[cmpDmg]
Punitive Damages	$[punDmg]

Attorney’s Fees Included?	[Yes/No]

(I) Terms & Abbreviations

ADA	Americans with Disabilities Act 42 USC §12101, et. seq.
ADEA	Age Discrimination in Employment Act 29 USC §621, et. seq.
EPA	Equal Pay Act 29 USC §206, et. seq.
FCRA	Florida Civil Rights Act of 1992 §760.01-§760.11 FS
FFHA	Florida Fair Housing Act of 1992 §760.20-§760.37 FS
FHA	Fair Housing Act 42 USC §3601, et. seq.
GINA	Genetic Information Nondiscrimination Act 42 USC §2000ff, et. seq.
Title VI	Title VI of the Civil Rights Act of 1964 42 USC §2000d, et. seq.
Title VII	Title VII of the Civil Rights Act of 1964; 42 USC §2000e, et. seq.
WBL	Florida’s Whistleblower’s Act §112.3144-§112.31895 FS

(II) Defendant Receives:

Full & Complete Release on all claims

Plaintiff’s [unconditional/conditional] waiver of [his/her] right to:

[initiate an ADA charge (42 USC §12101, et. seq.)];

[initiate an ADEA charge (29 USC §621, et. seq.)];

[initiate an EPA charge (29 USC §206, et. seq.)];

[initiate an FCRA charge (§760.01-§760.11 FS)];

[initiate an FFHA charge (§760.20-§760.37 FS)];

[initiate an FHA charge (42 USC §3601, et. seq.)];

[initiate a GINA charge (42 USC §2000ff, et. seq.)];

[initiate a Title VI charge (42 USC §2000d, et. seq.)];

[initiate a Title VII charge (42 USC §2000e, et. seq.)]; and

[initiate a WBL charge (§112.3144-§112.31895 FS)];

Plaintiff’s [unconditional/conditional] abstinence from participation in any legal proceeding which may implicate any wrongdoing from [defName] – with regards to the instant matter.

(III) Defendant Submits:

$[backPay] in back pay

Calculation:

[backpay] = [annSal] x [mthsSince] ÷ 12

$[retBen] in retirement benefits

Calculation:

[retBen] = [cntrPrptn] x [annSal] x (1+[grwthRate])

$[punDmg] punitive damages

mental anguish; distress; pain; inconvenience; professional damage

$[frontPay] in front pay

Note: front pay will be reduced by Plaintiff’s future income

a written apology

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on this [D] day of [MMM] [YYYY], I delivered a true and correct copy of the foregoing to the following (via email):

/s/ [plfName]

[plfName], Plaintiff

[plfAddy]

P: [plfPhn]

E: [plfEml]

W: TextBookDiscrimination.com

Get Booked Up on Justice!

Endnotes:

How-To Guide: (interactive)

TextBookDiscrimination.com/Guides/Settlement.html

SERVICE LIST

[defAtt], Esquire ([barNum]) E: [defEml] P: [defPhn] (defendant’s trial lawyers)
[clerkName], Agency Clerk Florida Commission on Human Relations Room 110 4075 Esplanade Way Tallahassee, Florida 32399-7020 (agency)

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