UNDER TITLE
VII OF THE CIVIL RIGHTS ACT OF 1964, AS AMENDED, SECTION 1981 OF THE CIVIL
RIGHTS ACT OF 1866, AS AMENDED, THE CIVIL RIGHTS ACT OF 1991, AS AMENDED, THE
FAMILY AND MEDICAL LEAVE ACT, THE AGE DISCRIMINATION IN EMPLOYMENT ACT, AS
AMENDED BY THE OLDER WORKERS BENEFIT PROTECTION ACT OF 1990 ("ADEA"), THE
AMERICANS WITH DISABILITIES ACT, THE EMPLOYEE RETIREMENT INCOME SECURITY ACT
("ERISA); CLAIMS UNDER ANY OTHER FEDERAL, STATE OR LOCAL STATUTE, REGULATION OR
ORDINANCE; CLAIMS FOR DISCRIMINATION OR HARASSMENT OF ANY, KIND, BREACH OF
CONTRACT OR PUBLIC POLICY, WRONGFUL OR RETALIATORY DISCHARGE, DEFAMATION OR
OTHER PERSONAL OR BUSINESS 'INJURY OF ANY KIND; CLAIMS FOR BREACH OF ANY
AGREEMENT BETWEEN REINO AND MEDQUIST OR FOR ANY COMPENSATION OR BENEFITS
PROVIDED FOR PURSUANT TO ANY SUCH AGREEMENT; AND ANY AND ALL OTHER CLAIMS TO ANY
FORM OF LEGAL OR EQUITABLE RELIEF OR DAMAGES; ANY OTHER CLAIMS FOR COMPENSATION
OR BENEFITS; OR ANY CLAIMS FOR ATTORNEYS' FEES OR COSTS.
7.
EXCLUSION FOR CERTAIN CLAIMS.
REINO AND MEDQUIST UNDERSTAND AND
AGREE THAT THE RELEASE IN PARAGRAPH 6 SHALL NOT APPLY TO ANY CLAIMS, INCLUDING
ANY CLAIMS UNDER ADEA, ARISING AFTER THE EFFECTIVE DATE OF THIS AGREEMENT, NOR
SHALL ANYTHING HEREIN PREVENT ANY PARTY FROM INSTITUTING ANY ACTION TO ENFORCE
THE TERMS OF THIS AGREEMENT.
8.
EXCLUSION OF FILING EEOC CHARGES/WAIVER OF INDIVIDUAL RECOVERY.
REINO AND MEDQUIST UNDERSTAND AND AGREE THAT NOTHING IN THIS AGREEMENT SHALL
PREVENT REINO FROM FILING A CHARGE WITH THE EQUAL EMPLOYMENT OPPORTUNITY
COMMISSION ("EEOC"), OR FROM PARTICIPATING IN ANY EEOC INVESTIGATION OR
PROCEEDING; PROVIDED, HOWEVER, THAT REINO WAIVES ANY AND ALL RIGHTS TO RECOVER
ANY INDIVIDUAL DAMAGES OR RELIEF IN CONNECTION WITH ANY EEOC INVESTIGATION OR
PROCEEDING.
9.
DISCLOSURE OF ANY MATERIAL INFORMATION.
AS OF THE DATE REINO
SIGNS THIS AGREEMENT, REINO REPRESENTS AND WARRANTS THAT SHE HAS DISCLOSED TO
MEDQUIST ANY INFORMATION IN HER POSSESSION CONCERNING ANY CONDUCT INVOLVING
MEDQUIST THAT SHE HAS ANY REASON TO BELIEVE MAY BE UNLAWFUL, VIOLATES ANY
MEDQUIST POLICY OR WOULD OTHERWISE REFLECT POORLY ON MEDQUIST IN ANY RESPECT.
10.
DUTY TO COOPERATE.
REINO UNDERSTANDS AND AGREES THAT SHE SHALL
COOPERATE FULLY WITH MEDQUIST REGARDING ANY MATTER, INCLUDING, BUT NOT LIMITED
TO, ANY LITIGATION, INVESTIGATION, GOVERNMENTAL PROCEEDING OR INTERNAL MEDQUIST
REVIEW, WHICH RELATES TO ANY MATTER IN WHICH REINO WAS INVOLVED OR CONCERNING
WHICH MEDQUIST REASONABLY DETERMINES REINO MAY HAVE RESPONSIVE OR RELEVANT
INFORMATION.
REINO FURTHER UNDERSTANDS AND AGREES THAT SUCH COOPERATION
INCLUDES, BUT IS NOT LIMITED TO, FULL DISCLOSURE OF ALL RELEVANT INFORMATION;
TRUTHFULLY TESTIFYING AND/OR ANSWERING QUESTIONS; AND MAKING HERSELF REASONABLY
AVAILABLE FOR INTERVIEWS, DEPOSITIONS OR COURT APPEARANCES IN CONNECTION WITH
ANY SUCH LITIGATION, INVESTIGATION, PROCEEDING OR INTERNAL MEDQUIST REVIEW.
REINO UNDERSTANDS AND AGREES THAT SHE SHALL RENDER ANY SUCH COOPERATION IN A
TIMELY MANNER AND AT SUCH TIMES AND PLACES AS MAY BE MUTUALLY AGREEABLE TO REINO
AND MEDQUIST.
UPON SUBMISSION OF APPROPRIATE DOCUMENTATION, MEDQUIST SHALL
REIMBURSE REINO FOR REASONABLE TRAVEL, LODGING, MEALS, AND TELECOMMUNICATIONS
EXPENSES INCURRED BY REINO IN CONNECTION WITH HER COMPLIANCE WITH THIS