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UNFAIR LABOR PRACTICE SETTLEMENT AGREEMENT
By and Between
GRANT COUNTY,
GRANT COUNTY PUBLIC EMPLOYEES ASSOCIATION,
And
RUTH MINA
THIS UNFAIR LABOR PRACTICE SETTLEMENT AGREEMENT is entered
into by and between Grant County and Grant County Public Works Department
(together hereinafter referred to as "Employer"), Grant County Public Employees
Association, representing Public Works employees (hereinafter referred to as the
"Association"), and Ruth Mina (hereinafter referred to as Employee).
"EREAS, the Association and Employee filed an Unfair Labor Practice Charge on
July 31, 2024. PERC assigned Case No. 140052-U-24. The Employer timely filed its
Answers and Affirmative Defenses on August 27, 2024. PERC Hearing Examiner
Daniel Comeau was assigned on August 19, 2024. The ULP hearing was set to
convene June 24-26, 2024. On May 14, 2025, counsel for the Association/Employee
and the Employer requested PERC assign a Mediator. A request for ULP Hearing
continuance was granted. PERC Mediator Loyd Willaford was assigned.
"EREAS, Employee Ruth Mina alleged the Employer hired her in one position
which was alleged to have been divided into two positions. After the Employee was
hired, the Employer elected not to split the position which allegedly resulted in the
Employee having to work more than one position's job requirements. It was alleged
that when the Employee could not keep up with the work, there were PIPS issued for
alleged failure to timely complete tasks.
"EREAS, the purpose of this Agreement is to avoid the uncertainty, risk and
significant fees and expenses which would be incurred by both the Employer and the
Association if there were protracted litigation and potential appeals as well as to
establish a mutually acceptable basis for improvement of relations between the
parties by establishing a reasonable basis for settlement of PERC Case Number
140052-U-24; and,
NOW, THEREFORE, the Employer, the Association, and the Employee hereby
agree to the following settlement terms and conditions:
1. Employer Acknowledgement of Past Mistakes. Employer acknowledges
that mistakes were made in the past by the prior administration. The
Employer further acknowledges that the previous administration in Public
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works made decisions that left the impression that they were not being fair
with the Employee.
2. Employer Future Reasonable steps. The Employer agrees to take
reasonable steps to prevent the past mistakes from reoccurring.
5. Association and Employee Acknowledgement. The Association and
Employee acknowledge that the new Employer administration in Public Work
is significantly improved over the prior leadership. The Association and
Employee pledge their commitment to perform the work in a productive and
efficient manner consistent with the expectations of the new administration.
6. No Pending Claims. The Association and Employee have no other claims,
complaints, grievances, ULPs lawsuits, nor any other legal and/or
administrative law disputes pending relating to the facts and circumstances of
this ULP.
7. Withdrawal and Dismissal with Prejudice of Pending Case. The
Association and the Employee agree to and hereby immediately withdraw and
dismiss with prejudice the pending ULP charge PERC Case No. 140052-U-24.
Counsel for the Employee and Association shall send counsel for the Employer
written confirmation of withdrawal and dismissal with prejudice of PERC Case
No. 140052-U-24 within thirty (30) calendar days of the signing of this
Agreement by all parties.
8. Waiver and Release of Claims. In consideration of the benefits reflected in
this Agreement, and as a material inducement to the Employer, the
Association, and the Employee, the parties enter into this Agreement. The
Employer, the Association, and the Employee release each other from any and
all past and present grievances, claims, ULPs, complaints, charges, etc. arising
out of the ULP and its facts as alleged by the Association and the Employee as
well as any and all claims arising out of the representation by the Association.
The Employee releases all past and present grievances, claims, ULPs,
complaints, charge, etc., if any, against the Employer, Employer's elected and
appointed officials, employees, attorneys and agents arising out of the Unfair
Labor Practice complaint filed by the Association and Employee. The Employee
releases all Employee's past and present claims, if any, against the
Association, Association's officials, employees, and agents arising out of the
Association's representation of the Employee's interests.
9. Non -Admission. This Agreement shall not be construed as an admission by
the Employer of any liability to the Employee and the Association, breach of
any agreement between the Employer, the Association and the Employee,
and/or any violation by the Employer of any statute, law, or regulation. This
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Agreement shall not be construed as an admission by the Association of any
liability to the Employer and the Employee, any breach of any agreement
between the Association, the Employee and the Employer, nor any violation by
the Association of any statute, law, or regulation.
10. Breach and Enforcement. The Employer, the Association, and the Employee
agree that this Agreement may be specifically enforced and may be used as
evidence in a subsequent proceeding in which any party alleges a breach of this
Agreement. The parties agree that in the event of an alleged breach of this
Agreement, the parties will first attempt to resolve their differences -through
PERC Mediation. If PERC Mediation does not resolve, the matter then the
parties shall submit the matter to arbitration pursuant to the provisions of the
current CBA. Each party shall be responsible for their own attorney's fees,
costs, expenses, Arbitrator fees, costs and expenses, etc.
11. Complete Agreement. This Agreement represents and contains the entire
understanding between the parties in connection with the subject matter of
this Agreement. The Agreement shall not be altered nor varied except in a
writing signed by the Employer, the Association and the Employee. It is
expressly acknowledged and recognized by all parties that there are no oral or
written collateral agreements, understandings, or representations between the
parties other than as contained in this document, and any such prior
agreements are specifically terminated.
12. Governing Laws. Unless otherwise controlled by federal law, the
interpretation and enforcement of this Agreement shall be governed by the
laws of the State of Washington.
13. Reliance and Right to Consult with an Attor . The Employee and
Association represent and acknowledge that in executing this Agreement, they
do not rely and have not relied upon any representation or statement not set
forth herein made by the Employer or by any of the Employer's employees,
agents, representatives, or attorneys with regard to the subject matter, basis
or effect of this Agreement. The Employer represents and acknowledges that
in executing this Agreement, they have not relied upon any representation or
statement not set forth herein made by the Association, the Employee or by
any of the Association's and/or Employee's fellow employees, agents,
representatives, or attorneys with regard to the subject matter, basis or effect
of this Agreement or otherwise.
14. Sigi nature n Counterpart and Facsimile Procedures. This Agreement
may be signed and agreed to in counterpart and shall be binding upon the
parties. Transmission of this Agreement by pdf shall serve as an original and
be binding. The parties may circulate duplicate originals of this document for
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signature so that each party has an original of this agreement showing
signatures of all parties.
Attornevs' Fees Costs and Expenses. Each party shall be solely
responsible for paying for their own attorney's fees, costs and expenses.
16. Effective Date, The effective date of this Agreement shall be the date on
which it is fully executed by all the parties heretot
THE TERMS AND CONDITIONS OF THIS AGREEMENT are hereby accepted
by the parties as confirmed by their signatures below:
EMPLOYER4
BOARD OF GRANT COUNTY CO1MISSIONER$*0
Rob�aa irperson of the Board Date
GRANT COUNTY PUBLIC WORKS DEPARTMENT:
7
Andy cloth, Public Works Director Date
GRANT. COUNTY HUMAN RESOURCES DEPARIME Nil:
Decorah Anderson, Human Resources Director
REPRESENTED BY:
n ony nke, anaaement attorney
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12-3D 2D25
Date
12/15/2025
Date
GRANT COUNTY PUBLIC EMPLOYEES ASSOCIATION:
.1.1 Mel C, LAZ-,-,President
.1 plo a
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Date
Date