SETTLEMENT AGREEMENT AND GENERAL RELEASE

The Parties to this Agreement are RENE LAZARO and BRICK TOWNSHIP PUBLIC
SCHOOLS, BRICK TOWNSHIP BOARD OF EDUCATION collectively referred to as “the
Parties.”

The dispute being litigated between the parties:

Rene Lazaro v. Brick Township Public Schools et. al.

Superior Court of New Jersey, Law Division, Ocean County
Docket No.: OCN-L-1530-23

It is the intent of the Parties expressed in this Agreement to terminate these disputes. The
Parties will dismiss with prejudice the above Complaint.

Together with the consideration represented by these mutual dismissals, the Parties agree
to the terms that follow below.

I. CONSIDERATION

In consideration of the promises and other consideration described in this Agreement,

BRICK TOWNSHIP BOARD OF EDUCATION will deliver the gross sum of Forty Thousand
Dollars and No Cents ($40,000.00) (the “Payment”), which shall be in full and final settlement of
all claims against BRICK TOWNSHIP PUBLIC SCHOOLS and BRICK TOWNSHIP BOARD
OF EDUCATION (“Defendants”), specifically including insurers, reinsurers, and attorneys in any
capacity. On behalf of the BRICK TOWSHIP BOARD OF EDUCATION payments will be issued
as follows:

1. A check made payable to Rene Lazaro in the amount of $28,000.00 (Twenty-Eight

Thousand Dollars) to be reported on a Form 1099-MISC with box 3 “other income”
checked to be issued to Plaintiff; and

2. A check made payable to the Law Offices of John R. Tatulli in the amount of
$12,000.00 (Twelve Thousand Dollars) to be reported on a Form 1099-MISC with box
10 checked off to be issued to the Law Offices of John R. Tatulli.

Defendants, through its counsel, shall deliver the Payment to Plaintiff's counsel, John R.
Tatulli, Esq. at 125 Half Mile Road, Suite 200, Red Bank, New Jersey 07701, within 30 days of
(1) Defendant counsel’s receipt of this Confidential Settlement Agreement and Release (the
“Agreement”) executed by Plaintiff, (2) Defendant counsel’s receipt of completed Tax Forms (W-
4 and W-9) from Plaintiff, (3) Defendant counsel’s receipt of a completed Form W-9 from the Law
Offices of John R. Tatulli; and (4) a clear child support judgment search.

RENE LAZARO agrees that, but for this Settlement Agreement, she would not be entitled
to the aforesaid payment.
 BRICK TOWNSHIP PUBLIC SCHOOLS and BRICK TOWNSHIP BOARD OF
EDUCATION agree to pay the full amount of the mediation fees of Stephen Blumenthal, Esq.

II. Covenant to Not Pursue Further Legal Action

The Parties covenant and agree that the civil and administrative actions described above
will be dismissed with prejudice and without costs. The Parties will take no further action against
each other based on the matters set forth within their pleadings.

III. No Future Employment or Volunteer Organization

As other consideration for the execution of this Agreement by the Parties and to advance
the resolution of this matter, RENE LAZARO agrees to refrain from applying for, seeking
appointment to or otherwise obtaining any position with the BRICK TOWNSHIP PUBLIC
SCHOOLS and BRICK TOWNSHIP BOARD OF EDUCATION or any successor public or
governmental entity which may take over the generally accepted duties and responsibilities of the
BRICK TOWNSHIP PUBLIC SCHOOLS and BRICK TOWNSHIP BOARD OF EDUCATION.
RENE LAZARO acknowledges that the BRICK TOWNSHIP PUBLIC SCHOOLS and BRICK
TOWNSHIP BOARD OF EDUCATION has no obligation, contractual or otherwise, to respond
to any employment and/or volunteer inquiry from her, to consider her for an interview, or to
otherwise hire or employ her in any capacity, or as an independent contractor, service provider,
volunteer or vendor. RENE LAZARO also agrees to waive, release, or forego all statutory rights
she may have or had in any position with the BRICK TOWNSHIP PUBLIC SCHOOLS and
BRICK TOWNSHIP BOARD OF EDUCATION.

IV. General Release

Whereas, RENE LAZARO brought a Civil Action as identified above alleging damages
for claims as explained in his pleadings in the Civil Action, including, but not limited to,
claims for pain and suffering, embarrassment, and humiliation, as well as emotional
distress, and in consideration of the terms set forth RENE LAZARO and her heirs,
successors, and assigns, voluntarily waives, generally releases, and discharges the BRICK
TOWNSHIP PUBLIC SCHOOLS and BRICK TOWNSHIP BOARD OF EDUCATION
from all rights or claims that RENE LAZARO may have against the BRICK TOWNSHIP
PUBLIC SCHOOLS and BRICK TOWNSHIP BOARD OF EDUCATION for all reasons,
including, but not limited to, claims related to any alleged protected category, status, or
class, including, but not limited to, political affiliation, political activity, age, sex, religion,
race, disability, familial status, or national origin, intentional and negligent infliction of
emotional distress, defamation, libel, slander, personal injury, lost wages, and any other
economic and non-economic damages for anything that has happened from the beginning
of time to the date that this document is executed. RENE LAZARO forever and irrevocably
 specifically waives, unless prohibited by law, any claims which were or could have been
set forth in the Civil Action, as well as any rights that RENE LAZARO may have under:

• Title VII of the Civil Rights Act of 1964, as amended.

• The Civil Rights Act of 1991.
• Sections 1981-1988 of Title 42 of the United States Code, as amended.
• The Employment Retirement Income Security Act of 1974, as amended.
• The Immigration Reform and Control Act, as amended.
• The Americans with Disabilities Act of 1990, as amended.
• The Age Discrimination in Employment Act of 1967, as amended.
• The Workers’ Adjustment and Retraining Notification Act, as amended.
• The Occupational Safety and Health Act, as amended.
• The Older Workers Benefits Protection Act.
• The Equal Pay Act.
• The Family Medical Leave Act.
• The Fair Labor Standards Act.
• The New Jersey Law Against Discrimination.
• The New Jersey Family Leave Act.
• The New Jersey State Wage and Hour Law.
• The New Jersey and Federal Conscientious Employee Protection Acts.
• The New Jersey Equal Pay Law.
• Individuals with Disabilities Education Act.
• Any other Federal, State, or local civil or human rights law or any other local, State,
or Federal law, regulation, or ordinance.
• Any public policy, contract, tort, or common law; or
• Any allegation for costs, fees, or other expenses including attorney’s fees incurred
in the lawsuit or in any of these matters,

that her heirs, administrators, executors, personal representatives, beneficiaries, and assigns may
have against the BRICK TOWNSHIP PUBLIC SCHOOLS and BRICK TOWNSHIP BOARD OF
EDUCATION for compensatory or punitive damages or other legal or equitable relief of any type
or description. These claims will be known as “Released Claims.”

Plaintiff, RENE LAZARO, acknowledges that she has twenty-one (21) days to review and
consider this Settlement Agreement and General Release, which waives his rights and claims under
the Age Discrimination in Employment Act ("ADEA") (29 U.S.C. § 621, et seq.) and that her
execution of this Settlement Agreement and General Release prior to the expiration of that time
period constitutes an express waiver to the consideration period. Plaintiff, RENE LAZARO,
acknowledges that she has seven (7) days from the date of execution of this Agreement to rescind
this Agreement by giving clear, written notice signed by her to legal counsel for Defendants.

V. Release Includes Unknown Claims

A. The Parties understand and agree that the Released Claims are intended to and do include
all claims of every nature and kind at all (whether known, unknown, suspected, or
unsuspected and whether under any law or cause of action now in effect or which may be
 enacted or created in the future) which they have or may have against each other,
individually or collectively.

B. The Parties further acknowledge that they may later discover facts different from or
together with those which they now know or believe to be true with respect to the Released
Claims and agree that, in such event, this Agreement will still be and remain effective in
all respects, despite such different or additional facts, or the discovery of them.

C. The Parties represent and acknowledge (i) that they and their attorneys have conducted
whatever investigation was considered necessary by themselves and their attorneys to
ascertain all facts and matters related to this Agreement; (ii) that they have consulted with
and received advice from legal counsel about this Agreement; and (iii) that they are not
relying in any way on any statement or representation by anyone other than their own
judgment and the advice of their attorneys, except as expressly stated, in reaching their
decision to enter into this Agreement.

VI. No Assignment or Transfer of Released Claims

RENE LAZARO represents and warrants that as of the Effective Date of this Agreement,
RENE LAZARO has not assigned, transferred, or hypothecated, or purported to assign,
transfer, or hypothecate, to any person, firm, corporation, association, or entity any of the
Released Claims. RENE LAZARO agrees to indemnify and hold harmless Releasees
against, without limitation, any rights, claims, warranties, demands, debts, obligations,
liabilities, costs, expenses (including attorneys’ fees), causes of action, and judgments
based on, arising out of, or connected with any such transfer, assignment, or hypothecation,
or purported transfer, assignment, or hypothecation of their claims.

VII. No Admission of Liability

The Parties understand and agree that this Agreement is a release of disputed claims and
does not constitute an admission of liability by the Parties as to any matters at all and that
the Parties merely intend by this Agreement to avoid further litigation and buy their peace.

VIII. Tax Consequences

The Parties acknowledge that this settlement is not conditioned or contingent on the tax
consequences, or lack thereof, associated with RENE LAZARO’S receipt of the payment
discussed above. RENE LAZARO agrees that she will be liable for any damage, loss,
liability, or expense, including penalties, interests, and attorneys’ fees, arising out of any
actions, suits, proceedings, demands, judgments, or other loss resulting from any action, of
any nature at all to require any party to pay any such taxes or other withholdings which
arise from the payment made under this agreement.

RENE LAZARO also agrees to indemnify the BRICK TOWNSHIP PUBLIC SCHOOLS
and BRICK TOWNSHIP BOARD OF EDUCATION and hold them harmless from the
 assessment of any taxes owed (along with interest, penalties, or other liabilities, including
attorneys’ fees, related to these taxes) and for any taxes arising out of or related to the
Settlement Payment.

IX. Modification

No provision of this Agreement may be changed, altered, modified, or waived except in

writing signed by RENE LAZARO and a duly authorized representative of the BRICK
TOWNSHIP PUBLIC SCHOOLS and BRICK TOWNSHIP BOARD OF EDUCATION,
which writing must specifically reference this Agreement and the provision which the
parties intend to waive or modify.

X. Severability

If any provision of this Agreement should be held to be unenforceable, each and all the
other provisions of this Agreement will remain in effect.

XI. Attorneys’ Fees, Costs, and Expenses

RENE LAZARO understands and agrees that the payments include and encompass in there
all claims for attorneys’ fees, costs, and expenses for or by all attorneys who have
represented them or with whom they have consulted or who have done anything in
connection with the Civil Action and the Released Claims.

XII. Entire Agreement

The Parties acknowledge that this Agreement constitutes a full, final, and complete
settlement of their differences and supersedes and replaces all other written or oral
exchanges, agreements, understandings, arrangements, or negotiations between or among
them relating to the subject matter of this document, and affirmatively state that there are
no other prior or contemporaneous agreements, exchanges, representations, arrangements,
or understandings, written or oral, between or among them relating to the subject matter of
this document other than that as set forth and that this Agreement contains the sole and
entire Agreement between them about the subject matter of this document. The Parties
hereto further acknowledge and agree that language proposed for, deleted from, or
otherwise changed in the various drafts of this Agreement but not included here will not be
considered in any way in the interpretation and application of this Agreement and will not
in any way affect the rights and obligations of the parties hereto.

XIII. Understanding
 RENE LAZARO acknowledges and represents that she has read this Agreement in full
and, with advice of counsel, understands and voluntarily consents and agrees to every
provision contained here.

XIV. Applicable Law and Mutual Submission to Jurisdiction

This Agreement will be construed and enforced according to the laws of the State of New
Jersey. RENE LAZARO agrees to submit all disputes arising out of or based on this
Agreement to the jurisdiction of the Courts of the State of New Jersey.

XV. Non-Disparagement

In further consideration of this Agreement, the Parties and their Agents agree that they will
neither solicit nor make any comments, statements, or the like to others on social media or
by any other means about each other that could adversely affect their reputation, image,
goodwill, commercial, or public interests or which may be considered derogatory or
disparaging.

XVI. Confidentiality

RENE LAZARO represents that she has and will keep the terms of this Agreement and all
matters concerning or relating to the settlement in strictest confidence, including the
substance of the negotiations leading up to the settlement, and not disclose them to anyone,
except as follows: (1) if she is required to reveal such information pursuant to legal process
or by a regulatory body or agency, subject to the BRICK TOWNSHIP PUBLIC SCHOOLS
and BRICK TOWNSHIP BOARD OF EDUCATION rights detailed below; (2) RENE
LAZARO may disclose the financial terms of the Agreement to her attorney, financial
advisor/auditor/accountant, and tax authorities if necessary after first obtaining that
individual’s agreement to keep the information confidential and not disclose it to others;
and (3) RENE LAZARO may disclose the terms of the Agreement to her spouse and/or
other family members, provided she first obtains their agreement to keep the information
confidential and not disclose it to others.

RENE LAZARO will say nothing about this Agreement, the Litigation, or the Released
Claims. If RENE LAZARO is asked about the Litigation or this Agreement, she may only
respond, “The matter has been resolved.” If RENE LAZARO, or anyone to whom she has
disclosed the information protected by this paragraph, breaches this confidentiality
provision, RENE LAZARO shall be liable to Releasees for actual damages resulting from
the breach. In any action alleging a breach of this Agreement, the prevailing party shall be
entitled to costs in addition to such other relief granted. Should RENE LAZARO be
requested to disclose the confidential terms and matters addressed in the Agreement in
connection with any judicial, administrative, or other proceeding, she agrees immediately
to notify Releasees of the request by sending such notification in writing by First Class
Mail to the attention of Erin R. Thompson, Esquire at Birchmeier & Powell, LLC, 1891
State Highway 50, P.O. Box 582, Tuckahoe, NJ 08250. RENE LAZARO further agrees
that the BRICK TOWNSHIP PUBLIC SCHOOLS and BRICK TOWNSHIP BOARD OF
 EDUCATION has standing to object to the disclosure on RENE LAZARO’S behalf.
Assuming the BRICK TOWNSHIP PUBLIC SCHOOLS and BRICK TOWNSHIP
BOARD OF EDUCATION does object to the request, RENE LAZARO agrees to await
the final outcome of the objection before making any disclosures about this Agreement or
its terms.

XVII. Liens – Indemnity and Hold Harmless

RENE LAZARO agrees and represents that any and all Medicare, Social Security, hospital,
medical insurance coverage, subrogation claims and/or any and all other type of liens or
interest that is and/or could be claimed by any person and/or entity, will be fully paid,
satisfied, and released from the settlement proceeds paid herein, or that the settlement
proceeds will be held in trust, unless and until such time as said liens and/or claims have
been fully paid, satisfied or released.

In this regard, Plaintiff, RENE LAZARO, agrees to indemnify and hold harmless the
BRICK TOWNSHIP PUBLIC SCHOOLS and BRICK TOWNSHIP BOARD OF
EDUCATION, any and all of their insurance carriers, attorneys, and all others in privity
with them, from any claim by, though, and/or under Plaintiff including, but not limited to,
any direct claim by Medicare and/or Social Security for reimbursement of any funds paid
by them in any way relating to the injuries and claims arising from the incident(s)
described above.
Plaintiff further agrees to hold harmless and indemnify Defendants from any cause of
action, including, but not limited to, an action to recover or recoup welfare or related
benefits which are applicable to, or are sought to be applied to, any aspect of this
settlement.
XVIII. No Claims Permitted/Covenant Not to Sue:

Plaintiff, RENE LAZARO, waives his right to file any charge or complaint on her own
behalf and/or to participate as a complainant, a Plaintiff, or charging party in any charge or
complaint which may be made by any other person or organization on his behalf, with
respect to anything which has happened up to the execution of this Agreement before any
Federal, State or Local Court or Administrative Agency against the Defendants, or which is
being pursued or which could have been pursued internally with the BRICK TOWNSHIP
PUBLIC SCHOOLS and BRICK TOWNSHIP BOARD OF EDUCATION, except if such
waiver is prohibited by law. Should any charge, complaint, or internal claim be filed,
Plaintiff agrees that she will not accept any relief or recovery therefrom. Plaintiff confirms
that no such charge, complaint, or action exists in any forum or form other than the
Complaint bearing Docket No. OCN-L-1530-23 and covenant not to file any charge,
complaint or action in any forum or form against the Defendants based upon anything which
is encompassed by the terms of this Agreement. Except as prohibited by law, in the event that
any such charge, complaint, or action is filed by Plaintiff, it shall be dismissed with prejudice
upon presentation of this Agreement and Plaintiff shall reimburse the Defendants for the cost,
including attorney's fees, of defending any such action.
XVIII. Counterparts Acceptable

This Agreement may be executed in two or more counterparts, each of which will be an
original but all of which together will constitute the same instrument.

IN WITNESS WHEREOF, the undersigned have executed this Agreement on the date
shown below.

___________________________
RENE LAZARO

Dated:

Sworn to and subscribed to before me on

this _____ day of _____________, 2024.

________________________________
NOTARY PUBLIC