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Attorneys' Fees and Costs Settlement Agreement And ATTORNEYS' FEES AND COSTS SETTLEMENT AGREEMENT AND RELEASE This Attorneys' Fees and Costs and Settlement Agreement and Release (the "Agreement") is made and entered into by and between Legal Aid Society- Employment Law Center, California Women's Law Center and Manatt, Phelps & Phillips, LLP, counsel for VERONICA OLLIER; NAUDIA RANGEL, by her next friends Steve and Carmen Rangel; MARITZA RANGEL, by her next friends Steve and Carmen Rangel; AMANDA HERNANDEZ, by her next friend Armando Hernandez; ARIANNA HERNANDEZ, by her next friend Armando Hernandez, individually and on behalf of all those similarly situated, on the one hand ("Plaintiffs"), and SWEETWATER UNION HIGH SCHOOL DISTRICT, ARLIE N. RICASA, PEARL QUINONES, JIM CARTMELL, BERTHA LOPEZ, GREG R. SANDOVAL, JESUS M. GANDARA, EARL WEINS, and RUSSELL MOORE, in their official capacities, ("Defendants") on the other hand, jointly the "Parties." RECITALS WHEREAS, Plaintiffs filed a Title IX action on April 19, 2007, in the U.S. District Court for the Southern District of California alleging unlawful sex discrimination suffered by Plaintiffs at Castle Park High School ("CPHS"), entitled Oilier v. Sweetwater Union High School District et al., Case No. 07cv714-L (JLB) ("the Action"); WHEREAS on August 25, 2008, the District Court granted Plaintiffs' motion for class certification. WHEREAS on March 30, 2009, the District Court granted Plaintiffs' motion for summary adjudication, and found that Defendants failed to comply with Title IX's requirement for equal participation opportunities for female students. WHEREAS a trial was held in fall 2010 on Plaintiffs' claims that Defendants failed to provide equal athletic treatment and benefits and that they retaliated. Following trial, the District Court ruled in Plaintiffs' favor in 2012. 1 of 9 State Law San Diego/1017/1113/SE/S0255710.DOCX SETTLEMENT AGREEMENT AND RELEASE Oilier v. Sweetwater No. 07cv7l4-L (JLB); No. 12-56348 WHEREAS Defendants then filed an appeal to the Ninth Circuit Court of Appeals ("Ninth Circuit") in 2012, entitled Sweetwater Union High School District v. Oilier, Appeal No. 12-56349 (the "Appeal"). In 2014, the Ninth Circuit ruled in favor of Plaintiffs. As a result, in early 2015 Plaintiffs' attorneys filed a petition for reasonable attorneys' fees and costs and related papers in the Ninth Circuit. On February 27, 2015, the Ninth Circuit granted Plaintiffs' petition and held that Plaintiffs were entitled to an award of reasonable attorneys' fees and costs. The Ninth Circuit then ordered the Parties to mediate the amount of attorneys' fees and costs or else the matter would be decided by the Appellate Commissioner. WHEREAS, at the District Court's direction, the Parties submitted a Joint Compliance Plan on March 26, 2012, and amended and re-submitted the Joint Compliance Plan on February 13, 2014. The Final Joint Compliance Plan was entered by the District Court on October 22, 2014 (the "Compliance Plan"). The Compliance Plan provided for payment to Plaintiffs' counsel of reasonable attorneys' fees and costs for monitoring ("Monitoring Fees and Costs"). Plaintiffs' attorneys' submitted two invoices to Defendants' counsel for payment of reasonable monitoring fees and costs covering the period September 15, 2014 - June 30, 2015. A dispute arose over the reasonableness of certain Monitoring Fees and Costs invoices. WHEREAS on July 13, 2015, the Parties engaged in arms' length settlement negotiations during an appellate mediation conducted by Ninth Circuit mediator Roxane Ashe, during which a settlement was reached on all material terms as to the amount of attorneys' fees and costs claimed by Plaintiffs' attorneys in relation to the Action, the Appeal, and Monitoring Fees and Costs up through June 30, 2015. The Parties further agreed to a provision to limit Monitoring Fees and Costs in the future (as described further below). WHEREAS the Parties recognize and agree that it is in their mutual best interests to resolve their differences as set forth herein. The Parties also recognize and agree that the releases set forth below represent the Parties' compromise of disputed matters in order to avoid further expense; and WHEREAS the Parties wish to fully, finally, and completely resolve all claims, demands, and liabilities, of any kind as defined in this Agreement. 2 of 9 Stutz Law San Diego/1017/1113/SE/S0255710.DOCX SETTLEMENT AGREEMENT AND RELEASE Oilier v. Sweetwater No. 07cv714-L (JLB); No. 12-56348 NOW, THEREFORE, in exchange for the mutual covenants and promises contained herein and other good and valuable consideration the receipt and sufficiency of which is hereby acknowledged, the Parties agree as follows: AGREEMENT A. SETTLEMENT TERMS 1. Settlement amount regarding Attorneys' Fees and Costs incurred in the Action, the Appeal, and Monitoring Fees and Costs through June 30,2015. Defendants shall pay Plaintiffs' attorneys' fees and costs in the amount of $5,550,000.00 ("Settlement Amount") as follows: a. Two Million Seven Hundred and Seventy-Five Thousand Dollars and No Cents ($2,775,000.00) shall be paid within sixty (60) days of the date of approval by the Sweetwater Union High School District School Board ("School Board") of the Settlement Amount, with such approval to occur at the August 10,2015 School Board meeting; Such Payment shall be made via overnight mail to: Legal Aid Society - Employment Law Center Attention: Elizabeth Kristen 180 Montgomery Street, Suite 600 San Francisco, CA 94104 b. Two Million Seven Hundred and Seventy-Five Thousand Dollars and No Cents ($2,775,000.00) shall be paid by Defendants to Plaintiffs no later than December 31, 2016; Such Payment shall be made via overnight mail to: Legal Aid Society - Employment Law Center Attention: Elizabeth Kristen 180 Montgomery Street, Suite 600 3 of 9 Stute Law San Diego/1017/1 i 13/SE/S0255710.DOCX SETTLEMENT AGREEMENT AND RELEASE Oilier v. Sweetwater No. 07cv714-L (JLB); No. 12-56348 San Francisco, CA 94104 c. Compound daily interest on the above Settlement Amount shall accrue beginning on August 10,2015, at the federal statutory rate as set forth in 28 U.S.C. § 1961 and shall continue to accrue daily on any unpaid Settlement Amount until such Settlement Amount is paid in full. Any interest accrued at the time of payment shall be paid along with the principal sum {i.e., interest accrued as of the first payment shall be paid within sixty (60) days of August 10, 2015; the interest on the remaining balance shall be paid with the December 31,2016 payment). d. Should a motion for District Court approval of this Agreement be necessary, the parties shall cooperate and file a Joint Motion seeking approval. 2. Post-June 30,2015 Monitoring Fees and Costs. a. Plaintiffs' attorneys shall invoice Defendants for Monitoring Fees and Costs incurred July 1, 2015 through December 31, 2015. Defendants shall pay Plaintiffs' attorneys' Monitoring Fees and Costs incurred from July 1, 2015 through December 31, 2015, in an amount not to exceed Thirty Thousand Dollars and No Cents ($30,000.00). Defendants shall pay Plaintiffs' attorneys' invoice within thirty (30) days of the invoice date; b. For Monitoring Fees and Costs incurred after December 31, 2015, Defendants shall pay Plaintiffs' attorneys' twice-yearly invoices, in an amount not to exceed Sixty Thousand Dollars and No Cents ($60,000.00) per calendar year. Defendants shall pay Plaintiffs' attorneys' invoices within thirty (30) days of the invoice date. c. Notwithstanding the foregoing. Plaintiffs' attorneys shall have the right to seek, by motion to the District Court, an award of Monitoring Fees and Costs in excess of Sixty Thousand Dollars and No Cents ($60,000.00) per year (and in excess of $30,000 for July 1, 4 of 9 Stutz Law San Diego/1017/1113/SE/S0255710.DOCX SETTLEMENT AGREEMENT AND RELEASE Oilier v. Sweetwater No. 07cv7l4-L (JLB); No. 12-56348 2015 through December 31, 2015) if in the unlikely event circumstances, actions, or events at Castle Park High School require Plaintiffs' counsel to significantly increase monitoring time and efforts. d. Prior to filing any such motion, Plaintiffs' counsel shall notify counsel for Defendants via e-mail and first class regular U.S. mail of their intent to file a motion seeking additional fees. Within ten (10) business days of the notice set forth above, the Parties shall meet and confer in good faith to resolve the dispute. The time by which the Parties may meet and confer shall not exceed thirty (30) days of the date of the notice. Plaintiffs are entitled to seek from the District Court reasonable attorneys' fees and costs in connection with such a motion. 3. Notices. Unless otherwise provided in this Agreement, all notices required to be given shall be in writing and sent by e-mail and first- class regular mail to the Parties. Notice shall be deemed effective upon e-mail transmission. If to Plaintiffs' counsel: Legal Aid Society - Employment Law Center Attention: Elizabeth Kristen 180 Montgomery Street, Suite 600 San Francisco, CA 94104 E-mail: [email protected] If to Defendants' counsel: Daniel R. Shinoff Stutz Artiano Shinoff & Holtz 2488 Historic Decatur Rd #200 San Diego, CA 92106-6113 Email: [email protected] 5 of 9 Stutz Law San Diego/1017/1113/SE/S0255710.DOCX SETTLEMENT AGREEMENT AND RELEASE Oilier v. Sweetwater No. 07cv714-L (JLB); No. 12-56348 If any of the Parties changes its business address or the person or persons to whom notices are to be directed, it shall notify the other Party, in writing, of such change of address or designated representative. 4. Bankruptcy & Fiscal Soundness. Defendants represent they cannot discharge any obligations under this Agreement or the Compliance Plan by declaring bankruptcy and further represent that the District is fiscally sound and that it is not in jeopardy of being declared, or know of plans to declare, insolvency at any time within the next five (5) years.
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