04/16/2014 - Personnel CommitteePERSONNEL COMMITTEE MEETING
WEDNESDAY, APRIL 16, 2014
5:00 - 5:30 P.M.
EAGAN MUNICIPAL BUILDING
AGENDA
I. AGENDA ADOPTION
II. FIRE RELIEF AND PERA
III. OTHER BUSINESS
IV. ADJOURNMENT
DDougherty, Molenda, Solfest, Hills & Bauer P.A.
OUGIMRTY MOLENDA
Attorneys I Advisors
MEMORANDUM
To: Eagan City Council
From: Mike Dougherty, City Attorney
7300 West 147th Street
Suite 600
Apple Valley, MN 55124
(952)432-3136 Phone
(952)432-3780 Fax
www.dmshb.com
PRIVILEGED AND CONFIDENTIAL
Date: 4/9/2014
Re: Michael Scott / Firefighter Relief Association Pension
In discussions with City Administrator Osberg, the matter described in this memo is intended to
be presented to the Personnel Committee on April 16, 2014. It is our opinion that the most
appropriate forum for a discussion of the topic is the Committee. Chief Mike Scott is aware that
this matter will be discussed by the Committee.
In June of 2013, an attorney representing Mike Scott submitted a claim to the City and the Eagan
Firefighter's Relief Association demanding a payment in excess of $80,000.00 to Chief Scott's
pension fund. The author of the letter asserted that the City had wrongly denied pension
payments that Chief Scott was entitled. The asserted claims extended back to 2006, when Mike
Scott was hired as Fire Chief. The City's administration has denied that it took or failed to take
any action that caused Chief Scott to suffer any damage.
Nevertheless, since the receipt of the letter, the City Administrator and I have met with Mike
Scott, as well as with officers in the Eagan Firefighter's Relief Association. The end result of
these discussions is that Mike Scott is agreeable to accept a payment of $8,900.00 in full
satisfaction and release of all claims regarding his Relief Association pension. Under the
circumstances, it is an amount that the City Administrator and I believe to be reasonable to
effectuate a settlement. As a preliminary step toward completing a settlement, I have prepared a
Release of Claims to be executed by Chief Scott and to be delivered to the City in exchange for
the payment of $8,900.00 by the City.
Procedurally, as noted above, Mike Scott's claim will be reviewed by the Personnel Committee.
If the Committee determines that it is able to recommend settlement, the resolution of this matter
will be placed on the May 5 Council Agenda as part of the Personnel Items. Otherwise, the
administration will respond appropriately to the direction of the Committee.
While the Council has the ability to meet in a closed session to discuss the claim and/or the
settlement proposal, a notification of the purpose for the closed session would need to be placed
in the public record. If any Council Member has any questions concerning the claim, the
settlement or the proposed process, please call Mr. Osberg.
RELEASE OF CLAIMS
IN CONSIDERATION of the an agreed upon sum of money paid by the City of Eagan, a
Minnesota municipal corporation ("City"), the receipt of which is hereby acknowledged,
Michael Scott ("Scott") absolutely and unconditionally releases, acquits and forever discharges
the City and the Eagan Firefighters Relief Association, a Minnesota governmental entity ("Relief
Association") from any and all claims, disputes, demands, actions, suits, contracts, debts,
agreements, damages (including attorney fees), costs, expenses and other liabilities whatsoever,
whether liquidated or unliquidated, absolute or contingent, that were or could have been asserted
as of the date of this release, in connection with Scott's participation in the Relief Association's
pension.
The undersigned acknowledge that the City and Relief Association have denied legal
liability and denied the nature and extent of any and all claims asserted by Scott.
Scott hereto warrants that no promise or inducement has been offered, except as herein
set forth, and that this release is executed without reliance, on any statements or representations
by the parties released or their representatives, and that the undersigned is of legal age, legally
competent to execute this release, and accepts full responsibility for its content.
Michael Scott
Subscribed and sworn to before
me this day of
2014.
Notary Public
This is a Legally Binding Obligation.
If not understood or you desire legal advice, consult an attorney.