The settlement agreement outlines the terms agreed upon between Alice Bennett and Rikards-Hayley to resolve Bennett's employment discrimination lawsuit against Rikards-Hayley. Rikards-Hayley agrees to pay Bennett $882,000, with $162,000 paid up front and the remaining $720,000 paid in monthly installments of $6,000 over 10 years. In exchange, Bennett agrees to dismiss the complaint with prejudice and provide full releases of all wrongful discharge and discrimination claims against Rikards-Hayley. Both parties agree the payment fully settles all claims between them.

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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
____________________________________
Alice Bennett, )
)
Plaintiff, ) Civil Action, 11 Civ. 9568
)
) SETTLEMENT AGREEMENT
v. )
)
)
Rikards-Hayley, )
)
Defendant. )
)
____________________________________)
THIS ACTION, Bennett v. Rikards-Hayley, Case No. 11 Civ. 9568, was brought in the
United States District Court of the Southern District of New York by Alice Bennett, hereinafter
called “plaintiff,” against Rikards-Hayley, hereinafter called “defendants.” The plaintiff brought
this action to recover damages for injuries received as a result of employment discrimination
against her.
THIS AGREEMENT has been made and entered into at New York, New York on this the
25th day of March, 2014.
WITNESSETH
WHEREAS, the parties desire to settle and adjust all matters relating to this action, all
property rights, all payments in the nature of damages, or other allowances that each might be
entitled to, and
WHEREAS, each of the parties is fully advised as to the extent of the injuries, the value of
employment, and the prospects of the other,
NOW, THEREFORE, in consideration of the mutual covenants and agreements herein
contained, the parties hereby acknowledge and agree as follows:
a. The plaintiff agrees to accept the sum of Eight Hundred Eighty-Two Thousand
Dollars ($882,000) in full satisfaction of all claims in the complaint filed against the
defendant in Case No. 11 Civ. 9568 in the United States District Court of the
Southern District of New York.
b. The defendant agrees to pay the sum of Eight Hundred Eighty-Two Thousand Dollars
($882,000) payable as follows: the sum of $162,000 payable in cash when the
settlement agreement is final and signed, the sum of $720,000 payable over a ten year
period, with the first payment of $6,000 beginning on the first day of the month

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following the signing and finalizing of this agreement and continuing at a rate of
$6,000 per month on the first day of every month thereafter until paid in full.
c. The plaintiff agrees that there will be no prepayment penalty should the defendants
decide to pay the balance early.
d. Contemporaneous with the signing of this agreement, the defendants shall execute a
note payable to the order of the plaintiff, providing for the payment of the $882,000
as indicated above.
e. The parties agree that with the signing and execution of this agreement and of the
aforementioned note, the parties shall cause the complaint in the action to be
dismissed with prejudice.
f. The plaintiff agrees that the payment of the sum of $882,000 is also in full
satisfaction for all wrongful discharge claims that the plaintiff may have against the
defendant.
g. The plaintiff agrees that the payment of the sum of $882,000 is also in full
satisfaction for all sexual discrimination claims that the plaintiff may have against the
defendant.
h. The plaintiff shall sign and execute all releases prepared by the attorney for the
defendants, provided that those releases are consistent with the provisions of this
agreement.
i. The defendants are to pay court costs of the action.
It is further agreed that the foregoing provisions are in full settlement of all claims that
either party might assert against the other.
IN WITNESS WHEREOF, the parties hereto have executed this agreement on the day and
the year first above written.
SIGNED AND ACKNOWLEDGED
IN THE PRESENCE OF
____________________________________
Alice Bennett, Plaintiff
____________________________________
President and CEO
Rikards-Hayley