HomeMy WebLinkAboutMichele Wilson-4/4/2016SETTLEMENT AGREEMENT
THIS AGREEMENT made on the date below between Michele Wilson and her
attorney, Erin P. Lyons, and the City of Waterloo Iowa, and its City Attorney, David R.
Zellhoefer. As a result of negotiations, the parties have reached the following agreement:
1. That Michele Wilson worked as a part-time kennel cleaner for the City of
Waterloo Animal Control between the dates of April 5, 2014 and February 13, 2015.
2. A dispute has arisen concerning the amount of hours worked by Michele
Wilson and the amount of pay she should receive as a result of said work.
3. That the parties have agreed that Michele Wilson worked 133.14 hours for
which she was not paid between April and August of 2014. Her rate of pay was $10.00
per hour. These wages would total $1,331.40 pursuant to Iowa Code Section 91A.8, this
amount would be doubled. Ms. Wilson would also be entitled to attorney fees in the sum
of $2,296.00 with advanced costs of $9.49. The City's copying costs in preparing the
municipal records for Ms. Wilson's attorney were $15.75, and that amount shall be
deducted from any payment.
$1,331.40
$1,331.40
$2,662.80 (wages)
$2,296.00 (attorney fees)
$4,958.80
$ 9.49 (advanced costs)
$4,968.29
$ 15.75 (City's copying fees to be deducted)
$4,952.54
4. That in exchange for the consideration described above, Ms. Wilson forever
releases the City of Waterloo, Iowa, and any of its current or former employees or other
agents or representatives, from any liability to her whatsoever, arising out of any claim or
potential claim for unpaid wages as defined by Iowa Code Section 91A.2(7).
Dated this 3�day of
coI(h ,2016.
lson, Individually
Erin Lyons Attorney for Michele Wilson
-2 -
APPROVED AS TO FORM:
CILLQ_,rist ram
Quentin Hart, Mayor
ATTEST:
Suzy Sch.. res, City Clerk