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grievances regarding a specific rotation under the Pilot Working Agreement (“PWA”) and any 1
claims that cannot be released under any circumstances as a matter of law (the “Non-2
Released Claims”), I hereby release, withdraw, waive and forever discharge and agree not to 3
bring a claim in court, arbitration, or under the PWA for any and all claims or actions which I 4
now have or may have against Delta Air Lines, Inc., the Delta Pilots Savings Plan, the Delta 5
Pilots Defined Contribution Plan, the Delta Account-Based Healthcare Plan, the Delta Pilots 6
Medical Plan, and the Delta Pilots Disability and Survivorship Plan (collectively the “Delta 7
Plans”), Northwest Airlines Corporation, Northwest Airlines, Inc. (“Northwest”), the Northwest 8
Airlines Retirement Savings Plan for Pilot Employees, the Northwest Airlines Money Purchase 9
Pension Plan for Pilot Employees, the Northwest Airlines Pilots Long Term Disability Plan, the 10
Northwest Airlines Pension Plan for Pilot Employees, the Northwest Airlines Pension Excess 11
Plan for Pilot Employees, the Northwest Airlines, Inc. Group Medical Plan (Plan Number 503) 12
and the Northwest Airlines, Inc. Group Life Insurance Plan (Plan 501) (collectively the 13
“Northwest Plans”) and the Air Line Pilots Association, International (the “Association”) and 14
their predecessors, successors, administrators, fiduciaries, parents, subsidiaries, affiliates, 15
members of their Boards of Directors, officers, directors, shareholders, representatives, 16
agents, employees, and all persons acting through or in connection with Delta and/or the 17
Delta Plans and Northwest and/or the Northwest Plans and/or the Association (each a 18
“Released Party”), including as a result of my being hired by any Released Party, my 19
employment with any Released Party, the termination of my employment with any Released 20
Party, or any other fact or matter occurring or existing at any time from the beginning of time 21
until the date I sign this Release. I also, for myself, my heirs, successors, executors, and 22
assigns, hereby release and discharge the Released Parties from all liability for judgments or 23
damages and agree not to institute any claim for judgment or damages and not to authorize 24
any other party, governmental or otherwise, to institute any claim for judgment or damages,25
except for the Non-Released Claims. I understand that by this Release, except for the Non-26
Released Claims, I am releasing the Released Parties from any and all claims including, but 27
not limited to, any claims arising under Title VII of the Civil Rights Act; Section 1981, 42 28
U.S.C. § 1981, et seq.; Executive Order 11246; the Age Discrimination in Employment Act; 29
the Americans with Disabilities Act, as amended; Section 503 of the Rehabilitation Act of 30
1973; Executive Order 11246, as amended; the Federal Equal Pay Act; the Pregnancy 31
Discrimination Act; the Fair Credit Reporting Act; the Uniformed Service Employment and 32
Reemployment Rights Act; the Worker Adjustment and Retraining Notification Act; the 33
Employee Retirement Income Security Act of 1974; the Minnesota Human Rights Act; the 34
Minnesota Equal Pay Law; the Minnesota Occupational Safety and Health Act of 1973; the 35
Minnesota Whistleblower Protection Law; the Elliott Larsen Civil Rights Act; the Michigan 36
Persons with Disabilities Civil Rights Act; the New Jersey Conscientious Employee Protection Act; 37
the West Virginia Human Rights Acts; the North Carolina Wage and Hour Act, and all other 38
federal, state and local statutes, constitutions and ordinances; as well as any contract, quasi 39
contract, statutory, whistleblower or tort claims, whether developed or undeveloped, known or 40
unknown, or asserted or unasserted, arising from or related to my employment, termination of 41
employment, or any other fact or matter occurring or existing at any time from the beginning 42
of time through the date I sign this Release. 43
44
45
b. I understand that this Release will discharge all claims against the Released Parties, except 46
the Non-Released Claims, to the extent permitted by law, but will not prohibit me from filing a 47
charge or claim with any local, state, or federal administrative agency or from cooperating in 48
any investigation conducted by such an agency. This Release does, however, include a 49
general release of my right to bring a claim in court or arbitration or to seek individual 50
remedies or monetary damages in any action to the fullest extent of the law, including in any 51
action filed by a federal or state discrimination agency. 52
53
c. I acknowledge and agree that during my employment, I had the opportunity to take all leave 54
and was afforded all other rights to which I was entitled under the Family Medical Leave Act 55
(FMLA), the Minnesota Parental Leave Act (“MPLA”), the Uniformed Services Employment and 56
Reemployment Rights Act (“USERRA”), or any other applicable federal or state leave of 57
absence law, and my Employer has not in any way discriminated against me, or interfered 58
with or taken punitive action against me for exercising (or attempting to exercise) any such 59