Common use of ADDITIONAL TERMS OF SETTLEMENT Clause in Contracts

ADDITIONAL TERMS OF SETTLEMENT. 17. If IER has reason to believe that Respondent has violated or is violating any provision of this Agreement, IER may, in its sole discretion, notify Respondent of the purported violation rather than initiate a new discrimination investigation or seek to judicially enforce the Agreement. If IER has exercised its discretion to notify Respondent of the purported violation, Respondent shall have thirty (30) calendar days from the date IER notifies it of the purported violation(s) to cure the violation(s) to IER’s satisfaction, before IER deems Respondent to be in violation of this Agreement and proceeds to take appropriate enforcement actions. 18. This Agreement may be enforced in the United States District Court for the District of South Carolina. This paragraph, or the initiation of a lawsuit to enforce the Agreement under this paragraph, including any counterclaims asserted, does not constitute and should not be construed as a waiver of sovereign immunity or any other jurisdictional or legal defense available to the United States. The Parties agree that the paragraphs set forth in Part II of this Agreement (entitled “Terms of Settlement”) contain material terms, without waiver of either Parties’ right to argue that the other terms in the Agreement are material. 19. The Parties agree that, as of the Effective Date, litigation concerning the alleged violations of 8 U.S.C. § 1324b that IER has found is not reasonably foreseeable. To the extent that any party previously implemented a litigation hold to preserve documents, electronically stored information, or things related to this matter, the party is no longer required to maintain such a litigation hold. Nothing in this paragraph relieves either party of any other obligations imposed by this Agreement. 20. Should any provision of this Agreement be declared or determined by any court to be illegal or invalid, the validity of the remaining parts, terms or provisions shall not be affected and the term or provision shall be deemed not to be a part of this Agreement. The Parties agree that they will not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 21. The Parties agree to bear their own costs, attorneys’ fees and other expenses incurred in the IER Investigation.

ADDITIONAL TERMS OF SETTLEMENT. 17. If IER has reason to believe that Respondent has violated or is violating any provision of this Agreement, IER may, in its sole discretion, notify Respondent of the purported violation rather than initiate a new discrimination investigation or seek to judicially enforce the Agreement. If IER has exercised its discretion to notify Respondent of the purported violation, Respondent shall have thirty (30) calendar days from the date IER notifies it of the purported violation(s) to cure the violation(s) to IER’s satisfaction, before IER deems Respondent to be in violation of this Agreement and proceeds to take appropriate enforcement actions. 1812. This Agreement may be enforced in is governed by the laws of the United States District Court for the District of South CarolinaStates. This paragraph, or the initiation of a lawsuit Agreement shall be deemed to enforce the Agreement under this paragraph, including any counterclaims asserted, does not constitute have been drafted by both Parties and should shall not be construed as against any one party in the event of a waiver subsequent dispute concerning the terms of sovereign immunity or any other jurisdictional or legal defense available to the United StatesAgreement. The Parties agree that the paragraphs set forth in Part II of this Agreement (entitled “Terms of Settlement”) contain are material terms. 13. The United States District Court for the Northern District of Georgia shall be the preferred venue for enforcement of any claims over which that court has subject matter jurisdiction. Otherwise, without a party must bring any claim or counterclaim to enforce this Agreement in a court of competent jurisdiction. This provision does not constitute a waiver of either Parties’ right to argue that sovereign immunity or any other defense the other terms in the Agreement are materialUnited States might have against a claim for enforcement or counterclaims asserted against it. 1914. The Parties agree that, as of the Effective DateDate of this Agreement, litigation concerning the alleged violations of 8 U.S.C. § 1324b that IER has found XXX believes Respondent committed is not reasonably foreseeable. To the extent that any If either party previously implemented a litigation hold to preserve documents, electronically stored information, or things related to this matter, the party is no longer required to maintain such a litigation hold. Nothing in this paragraph relieves either party of any other obligations imposed by this Agreement. 2015. Should any provision of this Agreement be declared or determined by any court to be illegal or invalid, the validity of the remaining parts, terms terms, or provisions shall not be affected affected, and the term or provision shall be deemed not to be a part of this Agreement. The Parties agree that they will not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 2116. The Parties agree to bear their own costs, attorneys’ fees fees, and other expenses incurred in this action. 17. This Agreement sets forth the IER Investigationentire agreement between the Parties and fully supersedes any and all prior agreements or understandings between the Parties pertaining to the subject matter herein.

ADDITIONAL TERMS OF SETTLEMENT. 17. If IER has reason to believe that Respondent has violated or is violating any provision of this Agreement, IER may, in its sole discretion, notify Respondent of the purported violation rather than initiate a new discrimination investigation or seek to judicially enforce the Agreement. If IER has exercised its discretion to notify Respondent of the purported violation, Respondent shall have thirty (30) calendar days from the date IER notifies it of the purported violation(s) to cure the violation(s) to IER’s satisfaction, before IER deems Respondent to be in violation of this Agreement and proceeds to take appropriate enforcement actions. 1820. This Agreement may be enforced in is governed by the laws of the United States District Court for the District of South CarolinaStates. This paragraph, or the initiation of a lawsuit Agreement shall be deemed to enforce the Agreement under this paragraph, including any counterclaims asserted, does not constitute have been drafted by both Parties and should shall not be construed as against any one party in the event of a waiver subsequent dispute concerning the terms of sovereign immunity or any other jurisdictional or legal defense available to the United StatesAgreement. The Parties agree that the paragraphs set forth in Part II of this Agreement (entitled “Terms of Settlement”) contain are material terms. 21. The United States District Court for the Northern District of Texas shall be the preferred venue for enforcement of any claims over which that court has subject matter jurisdiction. Otherwise, without a party must bring any claim or counterclaim to enforce this Agreement in a court of competent jurisdiction. This provision does not constitute a waiver of either Parties’ right to argue that sovereign immunity or any other defense the other terms in the Agreement are materialUnited States might have against a claim for enforcement or counterclaims asserted against it. 1922. Should any court declare or determine that any provision of this Agreement is illegal or invalid, the validity of the remaining parts, terms or provisions shall not be affected and said illegal or invalid part(s), term(s), or provision(s) shall be deemed not to be a part of this Agreement. The Parties shall not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 23. The Parties agree that, as of the Effective Date, litigation concerning the alleged violations of 8 U.S.C. § 1324b that IER has found are the subject of the Investigation is not reasonably foreseeable. To the extent that any party previously implemented a litigation hold to preserve documents, electronically stored information, or things related to this matter, the party is no longer required to maintain such a litigation hold. Nothing in this paragraph relieves either party of any other obligations imposed by this Agreement. 20. Should any provision of this Agreement be declared or determined by any court to be illegal or invalid, the validity of the remaining parts, terms or provisions shall not be affected and the term or provision shall be deemed not to be a part of this Agreement24. The Parties agree that they will not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 21. The Parties agree to shall each bear their own costs, attorneys’ fees and other expenses incurred in this action. 25. This Agreement sets forth the entire agreement between the Parties and fully supersedes any and all prior agreements or understandings between the Parties pertaining to the IER Investigation. 26. This Agreement may be executed in multiple counterparts, each of which together shall be considered an original but all of which shall constitute one agreement. The Parties agree to be bound by facsimile signatures.

ADDITIONAL TERMS OF SETTLEMENT. 17. If IER has reason to believe that Respondent has violated or is violating any provision of this Agreement, IER may, in its sole discretion, notify Respondent of the purported violation rather than initiate a new discrimination investigation or seek to judicially enforce the Agreement. If IER has exercised its discretion to notify Respondent of the purported violation, Respondent shall have thirty (30) calendar days from the date IER notifies it of the purported violation(s) to cure the violation(s) to IER’s satisfaction, before IER deems Respondent to be in violation of this Agreement and proceeds to take appropriate enforcement actions. 1811. This Agreement may be enforced in is governed by the laws of the United States District Court for the District of South CarolinaStates. This paragraph, or the initiation of a lawsuit Agreement shall be deemed to enforce the Agreement under this paragraph, including any counterclaims asserted, does not constitute have been drafted by both Parties and should shall not be construed as against any one party in the event of a waiver subsequent dispute concerning the terms of sovereign immunity or any other jurisdictional or legal defense available to the United StatesAgreement. The Parties agree that the paragraphs set forth in Part II of this Agreement (entitled “Terms of Settlement”) contain are material terms. 12. The United States District Court for the Southern District of Ohio shall be the preferred venue for enforcement of any claims over which that court has subject matter jurisdiction. Otherwise, without a party must bring any claim or counterclaim to enforce this Agreement in a court of competent jurisdiction. This provision does not constitute a waiver of either Parties’ right to argue that sovereign immunity or any other defense the other terms in the Agreement are materialUnited States might have against a claim for enforcement or counterclaims asserted against it. 1913. The Parties agree that, as of the Effective DateDate of this Agreement, litigation concerning the alleged violations of 8 U.S.C. § 1324b that IER has found XXX believes Respondent committed is not reasonably foreseeable. To the extent that any If either party previously implemented a litigation hold to preserve documents, electronically stored information, or things related to this matter, the party is no longer required to maintain such a litigation hold. Nothing in this paragraph relieves either party of any other obligations imposed by this Agreement. 2014. Should any provision of this Agreement be declared or determined by any court to be illegal or invalid, the validity of the remaining parts, terms terms, or provisions shall not be affected and the term or provision shall be deemed not to be a part of this Agreement. The Parties agree that they will not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 2115. The Parties agree to bear their own costs, attorneys’ fees fees, and other expenses incurred in this action. 16. This Agreement sets forth the IER Investigationentire agreement between the Parties and fully supersedes any and all prior agreements or understandings between the Parties pertaining to the subject matter herein. 17. This Agreement may be executed in multiple counterparts, each of which together shall be considered an original, but all of which shall constitute one agreement. The Parties agree to be bound by electronically transmitted signatures.

ADDITIONAL TERMS OF SETTLEMENT. 17. If IER has reason to believe that Respondent has violated or is violating any provision of this Agreement, IER may, in its sole discretion, notify Respondent of the purported violation rather than initiate a new discrimination investigation or seek to judicially enforce the Agreement. If IER has exercised its discretion to notify Respondent of the purported violation, Respondent shall have thirty (30) calendar days from the date IER notifies it of the purported violation(s) to cure the violation(s) to IER’s satisfaction, before IER deems Respondent to be in violation of this Agreement and proceeds to take appropriate enforcement actions. 18. This Agreement may be enforced in is governed by the laws of the United States District Court for the District of South CarolinaStates. This paragraph, or the initiation of a lawsuit Agreement shall be deemed to enforce the Agreement under this paragraph, including any counterclaims asserted, does not constitute have been drafted by both Parties and should shall not be construed as against any one party in the event of a waiver subsequent dispute concerning the terms of sovereign immunity or any other jurisdictional or legal defense available to the United StatesAgreement. The Parties agree that the paragraphs set forth in Part II of this Agreement (entitled “Terms of Settlement”) contain are material terms, without waiver of either Parties’ right to argue that the other terms in the Agreement are material. 19. The United States District Court for the Eastern District of Pennsylvania shall be the preferred venue for enforcement of any claims over which that court has subject matter jurisdiction. Otherwise, a party must bring any claim or counterclaim to enforce this Agreement in a court of competent jurisdiction. This provision does not constitute a waiver of sovereign immunity or any other defense the United States might have against a claim for enforcement or counterclaims asserted against it. 20. Should any court declare or determine that any provision of this Agreement is illegal or invalid, the validity of the remaining parts, terms or provisions shall not be affected and said illegal or invalid part(s), term(s), or provision(s) shall be deemed not to be a part of this Agreement. The Parties shall not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 21. The Parties agree that, as of the Effective Date, litigation concerning the alleged violations of 8 U.S.C. § 1324b that IER has found are the subject of the Investigation is not reasonably foreseeable. To the extent that any party previously implemented a litigation hold to preserve documents, electronically stored information, or things related to this matter, the party is no longer required to maintain such a litigation hold. Nothing in this paragraph relieves either party of any other obligations imposed by this Agreement. 20. Should any provision of this Agreement be declared or determined by any court to be illegal or invalid, the validity of the remaining parts, terms or provisions shall not be affected and the term or provision shall be deemed not to be a part of this Agreement22. The Parties agree that they will not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 21. The Parties agree to shall each bear their own costs, attorneys’ fees and other expenses incurred in this action. 23. This Agreement sets forth the entire agreement between the Parties and fully supersedes any and all prior agreements or understandings between the Parties pertaining to the IER Investigation. 24. This Agreement may be executed in multiple counterparts, each of which together shall be considered an original but all of which shall constitute one agreement. The Parties agree to be bound by facsimile signatures.

ADDITIONAL TERMS OF SETTLEMENT. 17. If IER has reason to believe that Respondent has violated or is violating any provision of this Agreement, IER may, in its sole discretion, notify Respondent of the purported violation rather than initiate a new discrimination investigation or seek to judicially enforce the Agreement. If IER has exercised its discretion to notify Respondent of the purported violation, Respondent shall have thirty (30) calendar days from the date IER notifies it of the purported violation(s) to cure the violation(s) to IER’s satisfaction, before IER deems Respondent to be in violation of this Agreement and proceeds to take appropriate enforcement actions. 1811. This Agreement may be enforced in is governed by the laws of the United States District Court for the District of South CarolinaStates. This paragraph, or the initiation of a lawsuit Agreement shall be deemed to enforce the Agreement under this paragraph, including any counterclaims asserted, does not constitute have been drafted by both Parties and should shall not be construed as against any one party in the event of a waiver subsequent dispute concerning the terms of sovereign immunity or any other jurisdictional or legal defense available to the United StatesAgreement. The Parties agree that the paragraphs set forth in Part II of this Agreement (entitled “Terms of Settlement”) contain are material terms. 12. The United States District Court for the Northern District of Georgia shall be the preferred venue for enforcement of any claims over which that court has subject matter jurisdiction. Otherwise, without a party must bring any claim or counterclaim to enforce this Agreement in a court of competent jurisdiction. This provision does not constitute a waiver of either Parties’ right to argue that sovereign immunity or any other defense the other terms in the Agreement are materialUnited States might have against a claim for enforcement or counterclaims asserted against it. 1913. The Parties agree that, as of the Effective DateDate of this Agreement, litigation concerning the alleged violations violation of 8 U.S.C. § 1324b that IER has found XXX believes Respondent committed is not reasonably foreseeable. To the extent that any If either party previously implemented a litigation hold to preserve documents, electronically stored information, or things related to this matter, the party is no longer required to maintain such a litigation hold. Nothing in this paragraph relieves either party of any other obligations imposed by this Agreement. 2014. Should any provision of this Agreement be declared or determined by any court to be illegal or invalid, the validity of the remaining parts, terms terms, or provisions shall not be affected and the term or provision shall be deemed not to be a part of this Agreement. The Parties agree that they will not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 2115. The Parties agree to bear their own costs, attorneys’ fees fees, and other expenses incurred in this action. 16. This Agreement sets forth the IER Investigationentire agreement between the Parties and fully supersedes any and all prior agreements or understandings between the Parties pertaining to the subject matter herein. 17. This Agreement may be executed in multiple counter parts, each of which together shall be considered an original, but all of which shall constitute one agreement. The Parties agree to be bound by electronically transmitted signatures.

ADDITIONAL TERMS OF SETTLEMENT. 17. If IER has reason to believe that Respondent has violated or is violating any provision of this Agreement, IER may, in its sole discretion, notify Respondent of the purported violation rather than initiate a new discrimination investigation or seek to judicially enforce the Agreement. If IER has exercised its discretion to notify Respondent of the purported violation, Respondent shall have thirty (30) calendar days from the date IER notifies it of the purported violation(s) to cure the violation(s) to IER’s satisfaction, before IER deems Respondent to be in violation of this Agreement and proceeds to take appropriate enforcement actions. 1814. This Agreement may be enforced in is governed by the laws of the United States District Court for the District of South CarolinaStates. This paragraph, or the initiation of a lawsuit Agreement shall be deemed to enforce the Agreement under this paragraph, including any counterclaims asserted, does not constitute have been drafted by both Parties and should shall not be construed as against any one Party in the event of a waiver subsequent dispute concerning the terms of sovereign immunity or any other jurisdictional or legal defense available to the United StatesAgreement. The Parties agree that the paragraphs set forth in Part II of this Agreement (entitled “Terms of Settlement”) contain are material terms, without waiver of either Parties’ Party’s right to argue that the other terms in the Agreement are material. 1915. The Parties agree that, as of United States District Court for New Jersey shall be the Effective Date, litigation concerning the alleged violations of 8 U.S.C. § 1324b that IER has found is not reasonably foreseeable. To the extent that any party previously implemented a litigation hold to preserve documents, electronically stored information, or things related to this matter, the party is no longer required to maintain such a litigation hold. Nothing in this paragraph relieves either party preferred venue for enforcement of any claims over which that court has subject matter jurisdiction. Otherwise, a Party must bring any claim or counterclaim to enforce the Agreement in a court of competent jurisdiction. This provision does not constitute a waiver of sovereign immunity or any other obligations imposed by this Agreementdefense the United States might have against a claim for enforcement or counterclaims asserted against it. 2016. Should any court declare or determine that any provision of this Agreement be declared or determined by any court to be is illegal or invalid, the validity of the remaining parts, terms or provisions shall not be affected and the illegal or invalid term or provision shall be deemed not to be a part of this Agreement. The Parties agree that they will shall not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 2117. The Parties agree that, as of the Effective Date, litigation concerning the violations of 8 U.S.C. § 1324b that are the subject of the IER Investigation is not reasonably foreseeable. To the extent that either Party previously implemented a litigation hold to preserve documents, electronically stored information, or things related to this matter, the Party is no longer required to maintain such a litigation hold. Nothing in this paragraph relieves either Party of any other obligations imposed by this Agreement. 18. The Parties agree to bear their own costs, attorneys’ fees fees, and other expenses incurred in the IER Investigation. 19. This Agreement sets forth the entire agreement between the Parties and fully supersedes any and all prior agreements or understandings between the Parties pertaining to the IER Investigation. 20. This Agreement may be executed in multiple counterparts, each of which together shall be considered an original but all of which shall constitute one agreement. The Parties shall be bound by electronically transmitted images of original signatures or facsimile signatures.

ADDITIONAL TERMS OF SETTLEMENT. 17. If IER has reason to believe that Respondent has violated or is violating any provision of this Agreement, IER may, in its sole discretion, notify Respondent of the purported violation rather than initiate a new discrimination investigation or seek to judicially enforce the Agreement. If IER has exercised its discretion to notify Respondent of the purported violation, Respondent shall have thirty (30) calendar days from the date IER notifies it of the purported violation(s) to cure the violation(s) to IER’s satisfaction, before IER deems Respondent to be in violation of this Agreement and proceeds to take appropriate enforcement actions. 1811. This Agreement may be enforced in is governed by the laws of the United States District Court for the District of South CarolinaStates. This paragraph, or the initiation of a lawsuit Agreement shall be deemed to enforce the Agreement under this paragraph, including any counterclaims asserted, does not constitute have been drafted by both Parties and should shall not be construed as against any one party in the event of a waiver subsequent dispute concerning the terms of sovereign immunity or any other jurisdictional or legal defense available to the United StatesAgreement. The Parties agree that the paragraphs set forth in Part II of this Agreement (entitled “Terms of Settlement”) contain are material terms. 12. The United States District Court for the Western District of Arkansas shall be the preferred venue for enforcement of any claims over which that court has subject matter jurisdiction. Otherwise, without a party must bring any claim or counterclaim to enforce this Agreement in a court of competent jurisdiction. This provision does not constitute a waiver of either Parties’ right to argue that sovereign immunity or any other defense the other terms in the Agreement are materialUnited States might have against a claim for enforcement or counterclaims asserted against it. 1913. The Parties agree that, as of the Effective DateDate of this Agreement, litigation concerning the alleged violations of 8 U.S.C. § 1324b that IER has found XXX believes Respondent committed is not reasonably foreseeable. To the extent that any If either party previously implemented a litigation hold to preserve documents, electronically stored information, or things related to this matter, the party is no longer required to maintain such a litigation hold. Nothing in this paragraph relieves either party of any other obligations imposed by this Agreement. 2014. Should any provision of this Agreement be declared or determined by any court to be illegal or invalid, the validity of the remaining parts, terms terms, or provisions shall not be affected and the term or provision shall be deemed not to be a part of this Agreement. The Parties agree that they will not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 2115. The Parties agree to bear their own costs, attorneys’ fees fees, and other expenses incurred in this action. 16. This Agreement sets forth the IER Investigationentire agreement between the Parties and fully supersedes any and all prior agreements or understandings between the Parties pertaining to the subject matter herein. 17. This Agreement may be executed in multiple counterparts, each of which together shall be considered an original, but all of which shall constitute one agreement. The Parties agree to be bound by electronically transmitted signatures.

ADDITIONAL TERMS OF SETTLEMENT. 17. If IER has reason to believe that Respondent has violated or is violating any provision of this Agreement, IER may, in its sole discretion, notify Respondent of the purported violation rather than initiate a new discrimination investigation or seek to judicially enforce the Agreement. If IER has exercised its discretion to notify Respondent of the purported violation, Respondent shall have thirty (30) calendar days from the date IER notifies it of the purported violation(s) to cure the violation(s) to IER’s satisfaction, before IER deems Respondent to be in violation of this Agreement and proceeds to take appropriate enforcement actions. 1811. This Agreement may be enforced in is governed by the laws of the United States District Court for the District of South CarolinaStates. This paragraph, or the initiation of a lawsuit Agreement shall be deemed to enforce the Agreement under this paragraph, including any counterclaims asserted, does not constitute have been drafted by both Parties and should shall not be construed as against any one party in the event of a waiver subsequent dispute concerning the terms of sovereign immunity or any other jurisdictional or legal defense available to the United StatesAgreement. The Parties agree that the paragraphs set forth in Part II of this Agreement (entitled “Terms of Settlement”) contain are material terms. 12. The United States District Court for the Northern District of Georgia shall be the preferred venue for enforcement of any claims over which that court has subject matter jurisdiction. Otherwise, without a party must bring any claim or counterclaim to enforce this Agreement in a court of competent jurisdiction. This provision does not constitute a waiver of either Parties’ right to argue that sovereign immunity or any other defense the other terms in the Agreement are materialUnited States might have against a claim for enforcement or counterclaims asserted against it. 1913. The Parties agree that, as of the Effective DateDate of this Agreement, litigation concerning the alleged violations of 8 U.S.C. § 1324b that IER has found XXX believes Respondent committed is not reasonably foreseeable. To the extent that any If either party previously implemented a litigation hold to preserve documents, electronically stored information, or things related to this matter, the party is no longer required to maintain such a litigation hold. Nothing in this paragraph relieves either party of any other obligations imposed by this Agreement. 2014. Should any provision of this Agreement be declared or determined by any court to be illegal or invalid, the validity of the remaining parts, terms terms, or provisions shall not be affected and the term or provision shall be deemed not to be a part of this Agreement. The Parties agree that they will not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 2115. The Parties agree to bear their own costs, attorneys’ fees fees, and other expenses incurred in this action. 16. This Agreement sets forth the IER Investigationentire agreement between the Parties and fully supersedes any and all prior agreements or understandings between the Parties pertaining to the subject matter herein. 17. This Agreement may be executed in multiple counterparts, each of which together shall be considered an original, but all of which shall constitute one agreement. The Parties agree to be bound by electronically transmitted signatures.

ADDITIONAL TERMS OF SETTLEMENT. 1716. If IER has reason This Agreement resolves any and all differences between the parties relating to believe that Respondent has violated or is violating any provision investigations DJ #s 000-00-000, 000-00-000 and 000-00-000 through the Effective Date of this Agreement, IER may, in its sole discretion, notify Respondent . 17. This Agreement sets forth the entire agreement between the parties and fully supersedes any and all prior agreements or understandings between the parties pertaining to the subject matter herein. This Agreement is governed by the laws of the purported violation rather than initiate United States. This Agreement shall be deemed to have been drafted by both parties and shall not be construed against any one party in the event of a new discrimination investigation or seek to judicially enforce subsequent dispute concerning the terms of the Agreement. If IER has exercised its discretion to notify Respondent of The parties agree that the purported violation, Respondent shall have thirty (30) calendar days from the date IER notifies it of the purported violation(s) to cure the violation(s) to IER’s satisfaction, before IER deems Respondent to be paragraphs set forth in violation Part II of this Agreement and proceeds (entitled "Terms of Settlement") are material terms, without waiver of either Parties' right to take appropriate enforcement actionsargue that other terms in the Agreement are material. 18. This Agreement may be enforced in the United States District Court for the District of South CarolinaNew Jersey. This paragraph, or the initiation of a lawsuit to enforce the Agreement under this paragraph, including any counterclaims asserted, does not constitute and should not be construed as a waiver of sovereign immunity or any other jurisdictional or legal defense available to the United States. The Parties agree that the paragraphs set forth in Part II of this Agreement (entitled “Terms of Settlement”) contain material terms, without waiver of either Parties’ right to argue that the other terms in the Agreement are materialStates might have against a claim for enforcement. 19. The Parties parties agree that, as of the Effective DateDate of this Agreement, litigation concerning the alleged violations of 8 U.S.C. § 1324b that IER XXX has found reasonable cause to believe that Respondent committed is not reasonably foreseeable. To the extent that any either party previously implemented a litigation hold to preserve documents, electronically stored information, or things related to this matter, the party is no longer required to maintain such a litigation hold. Nothing in this paragraph relieves either party of any other obligations imposed by this Agreement. 20. Should any provision of this Agreement be declared or determined by any court to be illegal or invalid, the validity of the remaining parts, terms or provisions shall not be affected and the term or provision shall be deemed not to be a part of this Agreement. The Parties parties agree that they will not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 21. The Parties parties agree to bear their own costs, attorneys’ fees and other expenses incurred in the IER Investigationthis action. 22. This Agreement may be executed in multiple counterparts, each of which together shall be considered an original but all of which shall constitute one agreement. The parties agree to be bound by facsimile signatures.

ADDITIONAL TERMS OF SETTLEMENT. 17. If IER has reason to believe that Respondent has violated or is violating any provision of this Agreement, IER may, in its sole discretion, notify Respondent of the purported violation rather than initiate a new discrimination investigation or seek to judicially enforce the Agreement. If IER has exercised its discretion to notify Respondent of the purported violation, Respondent shall have thirty (30) calendar days from the date IER notifies it of the purported violation(s) to cure the violation(s) to IER’s satisfaction, before IER deems Respondent to be in violation of this Agreement and proceeds to take appropriate enforcement actions. 1811. This Agreement may be enforced in is governed by the laws of the United States District Court for the District of South CarolinaStates. This paragraph, or the initiation of a lawsuit Agreement shall be deemed to enforce the Agreement under this paragraph, including any counterclaims asserted, does not constitute have been drafted by both Parties and should shall not be construed as against any one party in the event of a waiver subsequent dispute concerning the terms of sovereign immunity or any other jurisdictional or legal defense available to the United StatesAgreement. The Parties agree that the paragraphs set forth in Part II of this Agreement (entitled “Terms of Settlement”) contain are material terms. 12. The United States District Court for the District of Columbia shall be the preferred venue for enforcement of any claims over which that court has subject matter jurisdiction. Otherwise, without a party must bring any claim or counterclaim to enforce this Agreement in a court of competent jurisdiction. This provision does not constitute a waiver of either Parties’ right to argue that sovereign immunity or any other defense the other terms in the Agreement are materialUnited States might have against a claim for enforcement or counterclaims asserted against it. 1913. The Parties agree that, as of the Effective DateDate of this Agreement, litigation concerning the alleged violations of 8 U.S.C. § 1324b that IER has found XXX believes Respondent committed is not reasonably foreseeable. To the extent that any If either party previously implemented a litigation hold to preserve documents, electronically stored information, or things related to this matter, the party is no longer required to maintain such a litigation hold. Nothing in this paragraph relieves either party of any other obligations imposed by this Agreement. 2014. Should any provision of this Agreement be declared or determined by any court to be illegal or invalid, the validity of the remaining parts, terms terms, or provisions shall not be affected and the term or provision shall be deemed not to be a part of this Agreement. The Parties agree that they will not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 2115. The Parties agree to bear their own costs, attorneys’ fees fees, and other expenses incurred in this action. 16. This Agreement sets forth the IER Investigationentire agreement between the Parties and fully supersedes any and all prior agreements or understandings between the Parties pertaining to the subject matter herein. 17. This Agreement may be executed in multiple counterparts, each of which together shall be considered an original, but all of which shall constitute one agreement. The Parties agree to be bound by electronically transmitted signatures.

ADDITIONAL TERMS OF SETTLEMENT. 1718. If IER has reason to believe that Respondent has violated or is violating any provision of this Agreement, IER may, in its sole discretion, notify Respondent of the purported violation rather than initiate a new discrimination investigation or seek to judicially enforce immediate judicial enforcement of the Agreement. If IER has exercised its discretion to notify Respondent of the purported violation, Respondent shall have will then be given thirty (30) calendar days from the date IER notifies it of the purported violation(s) in which to cure the violation(s) to IER’s satisfaction, satisfaction before IER deems Respondent to be in violation of this Agreement and proceeds to take appropriate enforcement actions. 1819. This Agreement may be enforced in the United States District Court for the District of South CarolinaColumbia or any other court of competent jurisdiction. This paragraph, or the initiation of a lawsuit to enforce the Agreement under this paragraph, including any counterclaims asserted, does not constitute and should not be construed as a waiver of sovereign immunity or any other jurisdictional or legal defense available to the United States. The Parties agree that the paragraphs set forth in Part II of this Agreement (entitled “Terms of the Settlement”) contain material terms, without waiver of either Parties’ right to argue that the other terms in the Agreement are material. 1920. IER will not offer this Agreement as evidence of liability in a legal proceeding or action except if required to do so by law, and IER retains the right to use this Agreement in any legal proceeding or action to enforce the terms of this Agreement. 21. The Parties agree that, as of the Effective Date, litigation concerning the alleged violations of 8 U.S.C. § 1324b that IER has found is not reasonably foreseeable. To the extent that any party previously implemented a litigation hold to preserve documents, electronically stored information, or things related to this matter, the party is no longer required to maintain such a litigation hold. Nothing in this paragraph relieves either party of any other obligations imposed by this Agreement. 2022. Should any provision of this Agreement be declared or determined by any court to be illegal or invalid, the validity of the remaining parts, terms or provisions shall not be affected thereby and the said illegal or invalid part, term or provision shall be deemed not to be a part of this Agreement. The Parties agree that they will not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 2123. The Parties agree to shall each bear their own costs, attorneys’ fees fees, and other expenses incurred in this action. 24. This Agreement sets forth the IER Investigationentire agreement between the Parties and fully supersedes any and all prior agreements or understandings between the Parties pertaining to the subject matter herein. This Agreement is governed by the laws of the United States. This Agreement shall be deemed to have been drafted by both Parties and shall not be construed against any one party in the event of a subsequent dispute concerning the terms of the Agreement.

ADDITIONAL TERMS OF SETTLEMENT. 17. If IER has reason to believe that Respondent has violated or is violating any provision of this Agreement, IER may, in its sole discretion, notify Respondent of the purported violation rather than initiate a new discrimination investigation or seek to judicially enforce the Agreement. If IER has exercised its discretion to notify Respondent of the purported violation, Respondent shall have thirty (30) calendar days from the date IER notifies it of the purported violation(s) to cure the violation(s) to IER’s satisfaction, before IER deems Respondent to be in violation of this Agreement and proceeds to take appropriate enforcement actions. 1815. This Agreement may be enforced in is governed by the laws of the United States District Court for the District of South CarolinaStates. This paragraph, or the initiation of a lawsuit Agreement shall be deemed to enforce the Agreement under this paragraph, including any counterclaims asserted, does not constitute have been drafted by both Parties and should shall not be construed as against any one party in the event of a waiver subsequent dispute concerning the terms of sovereign immunity or any other jurisdictional or legal defense available to the United StatesAgreement. The Parties agree that the paragraphs set forth in Part II of this Agreement (entitled “Terms of Settlement”) contain are material terms. 16. The United States District Court for the District of Maryland shall be the preferred venue for enforcement of any claims over which that court has subject matter jurisdiction. Otherwise, without a party must bring any claim or counterclaim to enforce this Agreement in a court of competent jurisdiction. This provision does not constitute a waiver of either Parties’ right to argue that sovereign immunity or any other defense the other terms in the Agreement are materialUnited States might have against a claim for enforcement or counterclaims asserted against it. 1917. Should any court declare or determine that any provision of this Agreement is illegal or invalid, the validity of the remaining parts, terms or provisions shall not be affected and said illegal or invalid part(s), term(s), or provision(s) shall be deemed not to be a part of this Agreement. The Parties shall not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 18. The Parties agree that, as of the Effective Date, litigation concerning the alleged violations violation of 8 U.S.C. § 1324b that IER has found is the subject of the Investigation is not reasonably foreseeable. To the extent that any party previously implemented a litigation hold to preserve documents, electronically stored information, or things related to this matter, the party is no longer required to maintain such a litigation hold. Nothing in this paragraph relieves either party of any other obligations imposed by this Agreement. 20. Should any provision of this Agreement be declared or determined by any court to be illegal or invalid, the validity of the remaining parts, terms or provisions shall not be affected and the term or provision shall be deemed not to be a part of this Agreement19. The Parties agree that they will not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 21. The Parties agree to shall each bear their own costs, attorneys’ fees and other expenses incurred in this action. 20. This Agreement sets forth the entire agreement between the Parties and fully supersedes any and all prior agreements or understandings between the Parties pertaining to the IER Investigation. 21. This Agreement may be executed in multiple counterparts, each of which together shall be considered an original but all of which shall constitute one agreement. The Parties agree to be bound by facsimile signatures.

ADDITIONAL TERMS OF SETTLEMENT. 17. If IER has reason to believe that Respondent has violated or is violating any provision of this Agreement, IER may, in its sole discretion, notify Respondent of the purported violation rather than initiate a new discrimination investigation or seek to judicially enforce the Agreement. If IER has exercised its discretion to notify Respondent of the purported violation, Respondent shall have thirty (30) calendar days from the date IER notifies it of the purported violation(s) to cure the violation(s) to IER’s satisfaction, before IER deems Respondent to be in violation of this Agreement and proceeds to take appropriate enforcement actions. 1811. This Agreement may be enforced in is governed by the laws of the United States District Court for the District of South CarolinaStates. This paragraph, or the initiation of a lawsuit Agreement shall be deemed to enforce the Agreement under this paragraph, including any counterclaims asserted, does not constitute have been drafted by both Parties and should shall not be construed as against any one party in the event of a waiver subsequent dispute concerning the terms of sovereign immunity or any other jurisdictional or legal defense available to the United StatesAgreement. The Parties agree that the paragraphs set forth in Part II of this Agreement (entitled “Terms of Settlement”) contain are material terms. 12. The United States District Court for the Western District of North Carolina shall be the preferred venue for enforcement of any claims over which that court has subject matter jurisdiction. Otherwise, without a party must bring any claim or counterclaim to enforce this Agreement in a court of competent jurisdiction. This provision does not constitute a waiver of either Parties’ right to argue that sovereign immunity or any other defense the other terms in the Agreement are materialUnited States might have against a claim for enforcement or counterclaims asserted against it. 1913. The Parties agree that, as of the Effective DateDate of this Agreement, litigation concerning the alleged violations of 8 U.S.C. § 1324b that IER has found XXX believes Respondent committed is not reasonably foreseeable. To the extent that any If either party previously implemented a litigation hold to preserve documents, electronically stored information, or things related to this matter, the party is no longer required to maintain such a litigation hold. Nothing in this paragraph relieves either party of any other obligations imposed by this Agreement. 2014. Should any provision of this Agreement be declared or determined by any court to be illegal or invalid, the validity of the remaining parts, terms terms, or provisions shall not be affected and the term or provision shall be deemed not to be a part of this Agreement. The Parties agree that they will not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 2115. The Parties agree to bear their own costs, attorneys’ fees fees, and other expenses incurred in this action. 16. This Agreement sets forth the IER Investigationentire agreement between the Parties and fully supersedes any and all prior agreements or understandings between the Parties pertaining to the subject matter herein.

ADDITIONAL TERMS OF SETTLEMENT. 17. If IER has reason to believe that Respondent has violated or is violating any provision of this Agreement, IER may, in its sole discretion, notify Respondent of the purported violation rather than initiate a new discrimination investigation or seek to judicially enforce the Agreement. If IER has exercised its discretion to notify Respondent of the purported violation, Respondent shall have thirty (30) calendar days from the date IER notifies it of the purported violation(s) to cure the violation(s) to IER’s satisfaction, before IER deems Respondent to be in violation of this Agreement and proceeds to take appropriate enforcement actions. 1815. This Agreement may be enforced in sets forth the entire agreement between the Parties and fully supersedes any and all prior agreements or understandings between the Parties pertaining to the Investigation. This Agreement is governed by the laws of the United States District Court for the District of South CarolinaStates. This paragraph, or Agreement shall be deemed to have been drafted by the initiation of a lawsuit to enforce the Agreement under this paragraph, including any counterclaims asserted, does not constitute Parties and should shall not be construed as against any one party in the event of a waiver subsequent dispute concerning the terms of sovereign immunity or any other jurisdictional or legal defense available to the United StatesAgreement. The Parties agree that the paragraphs set forth in Part II of this Agreement and attachments (entitled “Terms of Settlement”) contain are material terms, without waiver of either Parties’ any Party’s right to argue that the other terms in the Agreement are material. 1916. The United States District Court for the Northern District of Alabama shall be the preferred venue for enforcement of any claims over which that court has subject matter jurisdiction. Otherwise, a Party must bring any claim or counterclaim to enforce this Agreement in a court of competent jurisdiction. This provision does not constitute a waiver of sovereign immunity or any other defense the United States might have against a claim for enforcement or counterclaims asserted against it. 17. Should any court declare or determine that any provision(s) of this Agreement is/are illegal or invalid, the validity of the remaining parts, terms or provisions shall not be affected and said illegal or invalid part(s), term(s), or provision(s) shall be deemed not to be part of this Agreement. The Parties shall not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 18. The Parties agree that, as of the Effective Date, litigation concerning the alleged violations of 8 U.S.C. § 1324b that IER has found are the subject of the Investigation is not reasonably foreseeable. To the extent that any party previously implemented a litigation hold to preserve documents, electronically stored information, or things related to this matter, the party is no longer required to maintain such a litigation hold. Nothing in this paragraph relieves either party of any other obligations imposed by this Agreement. 20. Should any provision of this Agreement be declared or determined by any court to be illegal or invalid, the validity of the remaining parts, terms or provisions shall not be affected and the term or provision shall be deemed not to be a part of this Agreement19. The Parties agree that they will not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 21. The Parties agree to shall each bear their own costs, attorneys’ fees and other expenses incurred in the IER Investigationthis action. 20. This Agreement may be executed in multiple counterparts, each of which together shall be considered an original but all of which shall constitute one agreement. The Parties shall be bound by facsimile signatures.

ADDITIONAL TERMS OF SETTLEMENT. 1720. If IER has reason This Agreement sets forth the entire agreement between the parties and fully supersedes any and all prior agreements or understandings between the parties pertaining to believe that Respondent has violated or the subject matter herein. This Agreement is violating any provision of this Agreement, IER may, in its sole discretion, notify Respondent governed by the laws of the purported violation rather than initiate United States. This Agreement shall be deemed to have been drafted by both parties and shall not be construed against any one party in the event of a new discrimination investigation or seek to judicially enforce subsequent dispute concerning the terms of the Agreement. If IER has exercised its discretion to notify Respondent of The parties agree that the purported violation, Respondent shall have thirty (30) calendar days from the date IER notifies it of the purported violation(s) to cure the violation(s) to IER’s satisfaction, before IER deems Respondent to be paragraphs set forth in violation Part II of this Agreement and proceeds (entitled “Terms of Settlement”) are material terms, without waiver of either party’s right to take appropriate enforcement actionsargue that other terms in the Agreement are material. 1821. This Agreement may be enforced in the United States District Court for the District of South CarolinaMaryland. This paragraph, or the initiation of a lawsuit to enforce the Agreement under this paragraph, including any counterclaims asserted, does not constitute and should not be construed as a waiver of sovereign immunity or any other jurisdictional defense the United States might have against a claim for enforcement. 22. If any deadline for an obligation to be performed under this Agreement falls on a weekend or legal defense available a federal holiday, the deadline shall be extended to the United Statesnext business day. 23. The Parties agree that the paragraphs set forth in Part II of this Agreement (entitled “Terms of Settlement”) contain material terms, without waiver of either Parties’ right to argue that the other terms in the Agreement are material. 19. The Parties parties agree that, as of the Effective DateDate of this Agreement, litigation concerning the alleged violations of 8 U.S.C. § 1324b that IER XXX has found reasonable cause to believe that Respondent committed is not reasonably foreseeable. To the extent that any either party previously implemented a litigation hold to preserve documents, electronically stored information, or things related to this matter, the party is no longer required to maintain such a litigation hold. Nothing in this paragraph relieves either party of any other obligations imposed by this Agreement. 2024. Should any provision of this Agreement be declared or determined by any court to be illegal or invalid, the validity of the remaining parts, terms or provisions shall not be affected and the term or provision shall be deemed not to be a part of this Agreement. The Parties parties agree that they will not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 2125. The Parties agree to parties shall bear their own costs, attorneys’ fees and other expenses incurred in the IER Investigationthis action.

ADDITIONAL TERMS OF SETTLEMENT. 17. If IER has reason to believe that Respondent has violated or is violating any provision of this Agreement, IER may, in its sole discretion, notify Respondent of the purported violation rather than initiate a new discrimination investigation or seek to judicially enforce the Agreement. If IER has exercised its discretion to notify Respondent of the purported violation, Respondent shall have thirty (30) calendar days from the date IER notifies it of the purported violation(s) to cure the violation(s) to IER’s satisfaction, before IER deems Respondent to be in violation of this Agreement and proceeds to take appropriate enforcement actions. 1816. This Agreement may be enforced in is governed by the laws of the United States District Court for the District of South CarolinaStates. This paragraph, or the initiation of a lawsuit Agreement shall be deemed to enforce the Agreement under this paragraph, including any counterclaims asserted, does not constitute have been drafted by both Parties and should shall not be construed as against any one Party in the event of a waiver subsequent dispute concerning the terms of sovereign immunity or any other jurisdictional or legal defense available to the United StatesAgreement. The Parties agree that the paragraphs set forth in Part II of this Agreement (entitled “Terms of Settlement”) contain are material terms, without waiver of either Parties’ Party’s right to argue that the other terms in the Agreement are material. 17. The United States District Court for the Eastern District of Virginia shall be the preferred venue for enforcement of any claims over which that court has subject matter jurisdiction. Otherwise, a Party must bring any claim or counterclaim to enforce the Agreement in a court of competent jurisdiction. This provision does not constitute a waiver of sovereign immunity or any other defense the United States might have against a claim for enforcement or counterclaims asserted against it. 18. Should any court declare or determine that any provision(s) of this Agreement is/are illegal or invalid, the validity of the remaining parts, terms or provisions shall not be affected and said illegal or invalid part, term or provision shall be deemed not to be a part of this Agreement. The Parties shall not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 19. The Parties agree that, as of the Effective Date, litigation concerning the alleged violations of 8 U.S.C. § 1324b that IER has found are the subject of the Investigation is not reasonably foreseeable. To the extent that any party previously implemented a litigation hold to preserve documents, electronically stored information, or things related to this matter, the party is no longer required to maintain such a litigation hold. Nothing in this paragraph relieves either party of any other obligations imposed by this Agreement. 20. Should any provision of this Agreement be declared or determined by any court to be illegal or invalid, the validity of the remaining parts, terms or provisions shall not be affected and the term or provision shall be deemed not to be a part of this Agreement. The Parties agree that they will not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 21. The Parties agree to shall each bear their own costs, attorneys’ fees and other expenses incurred in this action. 21. This Agreement sets forth the IER Investigationentire agreement between the Parties and fully supersedes any and all prior agreements or understandings between the Parties pertaining to the subject matter herein. 22. This Agreement may be executed in multiple counterparts, each of which together shall be considered an original but all of which shall constitute one agreement. The Parties agree to be bound by facsimile or electronic signatures.

ADDITIONAL TERMS OF SETTLEMENT. 17. If IER has reason to believe that Respondent has violated or is violating any provision of this Agreement, IER may, in its sole discretion, notify Respondent of the purported violation rather than initiate a new discrimination investigation or seek to judicially enforce the Agreement. If IER has exercised its discretion to notify Respondent of the purported violation, Respondent shall have thirty (30) calendar days from the date IER notifies it of the purported violation(s) to cure the violation(s) to IER’s satisfaction, before IER deems Respondent to be in violation of this Agreement and proceeds to take appropriate enforcement actions. 1811. This Agreement may be enforced in is governed by the laws of the United States District Court for the District of South CarolinaStates. This paragraph, or the initiation of a lawsuit Agreement shall be deemed to enforce the Agreement under this paragraph, including any counterclaims asserted, does not constitute have been drafted by both Parties and should shall not be construed as against any one party in the event of a waiver subsequent dispute concerning the terms of sovereign immunity or any other jurisdictional or legal defense available to the United StatesAgreement. The Parties agree that the paragraphs set forth in Part II of this Agreement (entitled “Terms of Settlement”) contain are material terms, without waiver of either Parties’ right to argue that the other terms in the Agreement are material. 1912. The United States District Court for the Northern District of Georgia shall be the preferred venue for enforcement of any claims over which that court has subject matter jurisdiction. Otherwise, a party must bring any claim or counterclaim to enforce this Agreement in a court of competent jurisdiction. 13. The Parties agree that, as of the Effective DateDate of this Agreement, litigation concerning the alleged violations of 8 U.S.C. § 1324b that IER has found XXX believes Respondent committed is not reasonably foreseeable. To the extent that any If either party previously implemented a litigation hold to preserve documents, electronically stored information, or things related to this matter, the party is no longer required to maintain such a litigation hold. Nothing in this paragraph relieves either party of any other obligations imposed by this Agreement. 2014. Should any provision of this Agreement be declared or determined by any court to be illegal or invalid, the validity of the remaining parts, terms terms, or provisions shall not be affected and the term or provision shall be deemed not to be a part of this Agreement. The Parties agree that they will not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 2115. The Parties agree to bear their own costs, attorneys’ fees fees, and other expenses incurred in this action. 16. This Agreement sets forth the IER Investigationentire agreement between the Parties and fully supersedes any and all prior agreements or understandings between the Parties pertaining to the subject matter herein. This Agreement may be modified, or the duration extended, only by written agreement of the parties. 17. This Agreement may be executed in multiple counterparts, each of which together shall be considered an original, but all of which shall constitute one agreement. The Parties agree to be bound by electronically transmitted signatures.

ADDITIONAL TERMS OF SETTLEMENT. 17. If IER has reason to believe that Respondent has violated or is violating any provision of this Agreement, IER may, in its sole discretion, notify Respondent of the purported violation rather than initiate a new discrimination investigation or seek to judicially enforce the Agreement. If IER has exercised its discretion to notify Respondent of the purported violation, Respondent shall have thirty (30) calendar days from the date IER notifies it of the purported violation(s) to cure the violation(s) to IER’s satisfaction, before IER deems Respondent to be in violation of this Agreement and proceeds to take appropriate enforcement actions. 1814. This Agreement may be enforced in is governed by the laws of the United States District Court for the District of South CarolinaStates. This paragraph, or the initiation of a lawsuit Agreement shall be deemed to enforce the Agreement under this paragraph, including any counterclaims asserted, does not constitute have been drafted by both Parties and should shall not be construed as against any one party in the event of a waiver subsequent dispute concerning the terms of sovereign immunity or any other jurisdictional or legal defense available to the United StatesAgreement. The Parties agree that the paragraphs set forth in Part II of this Agreement (entitled “Terms of Settlement”) contain ), including all Attachments, are material terms, without waiver of either Parties’ Party’s right to argue that the other terms in the Agreement are material. 1915. The United States District Court for the Middle District of Florida shall be the preferred venue for enforcement of any claims over which that court has subject matter jurisdiction. Otherwise, a party must bring any claim or counterclaim to enforce the Agreement in a court of competent jurisdiction. This provision does not constitute a waiver of sovereign immunity or any other defense the United States might have against a claim for enforcement or counterclaims asserted against it. 16. Should any court declare or determine that any provision of this Agreement is illegal or invalid, the validity of the remaining parts, terms or provisions shall not be affected and the illegal or invalid term or provision shall be deemed not to be a part of this Agreement. The Parties shall not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 17. The Parties agree that, as of the Effective Date, litigation concerning the alleged violations of 8 U.S.C. § 1324b that are the subject of the IER has found Investigation is not reasonably foreseeable. To the extent that any either party previously implemented a litigation hold to preserve documents, electronically stored information, or things related to this matter, the party is no longer required to maintain such a litigation hold. Nothing in this paragraph relieves either party of any other obligations imposed by this Agreement. 20. Should any provision of this Agreement be declared or determined by any court to be illegal or invalid, the validity of the remaining parts, terms or provisions shall not be affected and the term or provision shall be deemed not to be a part of this Agreement. The Parties agree that they will not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 2118. The Parties agree to bear their own costs, attorneys’ fees and other expenses incurred in the IER Investigation. 19. This Agreement sets forth the entire agreement between the Parties and fully supersedes any and all prior agreements or understandings between the Parties pertaining to the IER Investigation. 20. This Agreement may be executed in multiple counterparts, each of which together shall be considered an original but all of which shall constitute one agreement. The Parties shall be bound by electronically transmitted images of original signatures or facsimile signatures.

ADDITIONAL TERMS OF SETTLEMENT. 17. If IER has reason to believe that Respondent has violated or is violating any provision of this Agreement, IER may, in its sole discretion, notify Respondent of the purported violation rather than initiate a new discrimination investigation or seek to judicially enforce the Agreement. If IER has exercised its discretion to notify Respondent of the purported violation, Respondent shall have thirty (30) calendar days from the date IER notifies it of the purported violation(s) to cure the violation(s) to IER’s satisfaction, before IER deems Respondent to be in violation of this Agreement and proceeds to take appropriate enforcement actions. 1819. This Agreement may be enforced in sets forth the entire agreement between the Parties and fully supersedes any and all prior agreements or understandings between the Parties pertaining to the IER Investigation. This Agreement is governed by the laws of the United States District Court for the District of South CarolinaStates. This paragraph, or the initiation of a lawsuit Agreement shall be deemed to enforce the Agreement under this paragraph, including any counterclaims asserted, does not constitute have been drafted by both Parties and should shall not be construed as against any one party in the event of a waiver subsequent dispute concerning the terms of sovereign immunity or any other jurisdictional or legal defense available to the United StatesAgreement. The Parties agree that the paragraphs set forth in Part II of this Agreement (entitled “Terms of Settlement”) contain are material terms, without waiver of either Parties’ Party’s right to argue that the other terms in the Agreement are material. 1920. The United States District Court for the Eastern District of Virginia shall be the preferred venue for enforcement of any claims over which that court has subject matter jurisdiction. Otherwise, a party must bring any claim or counterclaim to enforce the agreement in a court of competent jurisdiction. This provision does not constitute a waiver of sovereign immunity or any other defense the United States might have against a claim for enforcement or counterclaims asserted against it. 21. In accordance with rules and precedent determining the standard for implementing or maintaining a litigation hold, the Parties agree that, as of the Effective Date, litigation concerning the alleged violations violation of 8 U.S.C. § 1324b that are the subject of the IER has found Investigation is not reasonably foreseeable. To the extent that any party previously implemented a litigation hold to preserve documents, electronically stored information, or things related to this matter, the party is no longer required to maintain such a litigation hold. Nothing in this paragraph relieves either party of any other obligations imposed by this Agreement. 2022. Should any provision of this Agreement be declared or determined by any court to be illegal or invalid, the validity of the remaining parts, terms or provisions shall not be affected and the invalid term or provision shall be deemed not to be a part of this Agreement. The Parties agree that they will not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 2123. The Parties agree to shall bear their own costs, attorneys’ fees and other expenses incurred in the IER Investigationthis investigation. 24. This Agreement may be executed in multiple counterparts, each of which together shall be considered an original but all of which shall constitute one agreement. The Parties shall be bound by facsimile signatures.

ADDITIONAL TERMS OF SETTLEMENT. 17. If IER has reason to believe that Respondent has violated or is violating any provision of this Agreement, IER may, in its sole discretion, notify Respondent of the purported violation rather than initiate a new discrimination investigation or seek to judicially enforce the Agreement. If IER has exercised its discretion to notify Respondent of the purported violation, Respondent shall have thirty (30) calendar days from the date IER notifies it of the purported violation(s) to cure the violation(s) to IER’s satisfaction, before IER deems Respondent to be in violation of this Agreement and proceeds to take appropriate enforcement actions. 1811. This Agreement may be enforced in is governed by the laws of the United States District Court for the District of South CarolinaStates. This paragraph, or the initiation of a lawsuit Agreement shall be deemed to enforce the Agreement under this paragraph, including any counterclaims asserted, does not constitute have been drafted by both Parties and should shall not be construed as against any one party in the event of a waiver subsequent dispute concerning the terms of sovereign immunity or any other jurisdictional or legal defense available to the United StatesAgreement. The Parties agree that the paragraphs set forth in Part II of this Agreement (entitled “Terms of Settlement”) contain are material terms. 12. The United States District Court for the District of Kansas shall be the preferred venue for enforcement of any claims over which that court has subject matter jurisdiction. Otherwise, without a party must bring any claim or counterclaim to enforce this Agreement in a court of competent jurisdiction. This provision does not constitute a waiver of either Parties’ right to argue that sovereign immunity or any other defense the other terms in the Agreement are materialUnited States might have against a claim for enforcement or counterclaims asserted against it. 1913. The Parties agree that, as of the Effective DateDate of this Agreement, litigation concerning the alleged violations of 8 U.S.C. § 1324b that IER has found XXX believes Respondent committed is not reasonably foreseeable. To the extent that any If either party previously implemented a litigation hold to preserve documents, electronically stored information, or things related to this matter, the party is no longer required to maintain such a litigation hold. Nothing in this paragraph relieves either party of any other obligations imposed by this Agreement. 2014. Should any provision of this Agreement be declared or determined by any court to be illegal or invalid, the validity of the remaining parts, terms terms, or provisions shall not be affected and the term or provision shall be deemed not to be a part of this Agreement. The Parties agree that they will not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 2115. The Parties agree to bear their own costs, attorneys’ fees fees, and other expenses incurred in this action. 16. This Agreement sets forth the IER Investigationentire agreement between the Parties and fully supersedes any and all prior agreements or understandings between the Parties pertaining to the subject matter herein. 17. This Agreement may be executed in multiple counterparts, each of which together shall be considered an original, but all of which shall constitute one agreement. The Parties agree to be bound by electronically transmitted signatures.

ADDITIONAL TERMS OF SETTLEMENT. 17. If IER has reason to believe that Respondent has violated or is violating any provision of this Agreement, IER may, in its sole discretion, notify Respondent of the purported violation rather than initiate a new discrimination investigation or seek to judicially enforce the Agreement. If IER has exercised its discretion to notify Respondent of the purported violation, Respondent shall have thirty (30) calendar days from the date IER notifies it of the purported violation(s) to cure the violation(s) to IER’s satisfaction, before IER deems Respondent to be in violation of this Agreement and proceeds to take appropriate enforcement actions. 1811. This Agreement may be enforced in is governed by the laws of the United States District Court for the District of South CarolinaStates. This paragraph, or the initiation of a lawsuit Agreement shall be deemed to enforce the Agreement under this paragraph, including any counterclaims asserted, does not constitute have been drafted by both Parties and should shall not be construed as against any one party in the event of a waiver subsequent dispute concerning the terms of sovereign immunity or any other jurisdictional or legal defense available to the United StatesAgreement. The Parties agree that the paragraphs set forth in Part II of this Agreement (entitled “Terms of Settlement”) contain are material terms. 12. The United States District Court for the Middle District of Tennessee shall be the preferred venue for enforcement of any claims over which that court has subject matter jurisdiction. Otherwise, without a party must bring any claim or counterclaim to enforce this Agreement in a court of competent jurisdiction. This provision does not constitute a waiver of either Parties’ right to argue that sovereign immunity or any other defense the other terms in the Agreement are materialUnited States might have against a claim for enforcement or counterclaims asserted against it. 1913. The Parties agree that, as of the Effective DateDate of this Agreement, litigation concerning the alleged violations of 8 U.S.C. § 1324b that IER has found XXX believes Respondent committed is not reasonably foreseeable. To the extent that any If either party previously implemented a litigation hold to preserve documents, electronically stored information, or things related to this matter, the party is no longer required to maintain such a litigation hold. Nothing in this paragraph relieves either party of any other obligations imposed by this Agreement. 2014. Should any provision of this Agreement be declared or determined by any court to be illegal or invalid, the validity of the remaining parts, terms terms, or provisions shall not be affected and the term or provision shall be deemed not to be a part of this Agreement. The Parties agree that they will not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 2115. The Parties agree to bear their own costs, attorneys’ fees fees, and other expenses incurred in this action. 16. This Agreement sets forth the IER Investigationentire agreement between the Parties and fully supersedes any and all prior agreements or understandings between the Parties pertaining to the subject matter herein. 17. This Agreement may be executed in multiple counterparts, each of which together shall be considered an original, but all of which shall constitute one agreement. The Parties agree to be bound by electronically transmitted signatures.

ADDITIONAL TERMS OF SETTLEMENT. 17. If IER has reason to believe that Respondent has violated or is violating any provision of this Agreement, IER may, in its sole discretion, notify Respondent of the purported violation rather than initiate a new discrimination investigation or seek to judicially enforce the Agreement. If IER has exercised its discretion to notify Respondent of the purported violation, Respondent shall have thirty (30) calendar days from the date IER notifies it of the purported violation(s) to cure the violation(s) to IER’s satisfaction, before IER deems Respondent to be in violation of this Agreement and proceeds to take appropriate enforcement actions. 18. This Agreement may be enforced in is governed by the laws of the United States District Court for the District of South CarolinaStates. This paragraph, or the initiation of a lawsuit Agreement shall be deemed to enforce the Agreement under this paragraph, including any counterclaims asserted, does not constitute have been drafted by both Parties and should shall not be construed as against any one party in the event of a waiver subsequent dispute concerning the terms of sovereign immunity or any other jurisdictional or legal defense available to the United StatesAgreement. The Parties agree that the paragraphs set forth in Part II of this Agreement (entitled “Terms of Settlement”) contain are material terms, without waiver of either Parties’ Party’s right to argue that the other terms in the Agreement are material. 18. The United States District Court for the Central District of California shall be the preferred venue for enforcement of any claims over which that court has subject matter jurisdiction. Otherwise, a party must bring any claim or counterclaim to enforce the agreement in a court of competent jurisdiction. This provision does not constitute a waiver of sovereign immunity or any other defense the United States might have against a claim for enforcement or counterclaims asserted against it. 19. The Parties agree that, as of the Effective Date, litigation concerning the alleged violations of 8 U.S.C. § 1324b that are the subject of the IER has found Investigations is not reasonably foreseeable. To the extent that any party previously implemented a litigation hold to preserve documents, electronically stored information, or things related to this matter, the party is no longer required to maintain such a litigation hold. Nothing in this paragraph relieves either party of any other obligations imposed by this Agreement. 20. Should any provision of this Agreement be declared or determined by any court to be illegal or invalid, the validity of the remaining parts, terms or provisions shall not be affected and the invalid term or provision shall be deemed not to be a part of this Agreement. The Parties agree that they will not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 21. The Parties agree to shall bear their own costs, attorneys’ attorney fees and other expenses incurred in this investigation. 22. This Agreement sets forth the entire agreement between the Parties and fully supersedes any and all prior agreements or understandings between the Parties pertaining to the IER InvestigationInvestigations. 23. This Agreement may be executed in multiple counterparts, each of which together shall be considered an original but all of which shall constitute one agreement. The Parties shall be bound by electronic signatures.

ADDITIONAL TERMS OF SETTLEMENT. 17. If IER has reason to believe that Respondent has violated or is violating any provision of this Agreement, IER may, in its sole discretion, notify Respondent of the purported violation rather than initiate a new discrimination investigation or seek to judicially enforce the Agreement. If IER has exercised its discretion to notify Respondent of the purported violation, Respondent shall have thirty (30) calendar days from the date IER notifies it of the purported violation(s) to cure the violation(s) to IER’s satisfaction, before IER deems Respondent to be in violation of this Agreement and proceeds to take appropriate enforcement actions. 18. This Agreement may be enforced in is governed by the laws of the United States District Court for the District of South CarolinaStates. This paragraph, or the initiation of a lawsuit Agreement shall be deemed to enforce the Agreement under this paragraph, including any counterclaims asserted, does not constitute have been drafted by both Parties and should shall not be construed as against any one party in the event of a waiver subsequent dispute concerning the terms of sovereign immunity or any other jurisdictional or legal defense available to the United StatesAgreement. The Parties agree that the paragraphs set forth in Part II of this Agreement (entitled “Terms of Settlement”) contain are material terms, without waiver of either Parties’ right to argue that the other terms in the Agreement are material. 19. The United States District Court for the District of Rhode Island shall be the preferred venue for enforcement of any claims over which that court has subject matter jurisdiction. Otherwise, a Party must bring any claim or counterclaim to enforce this Agreement in a court of competent jurisdiction. This provision does not constitute a waiver of sovereign immunity or any other defense the United States might have against a claim for enforcement or counterclaims asserted against it. 20. Should any court declare or determine that any provision(s) of this Agreement is/are illegal or invalid, the validity of the remaining parts, terms or provisions shall not be affected and said illegal or invalid part(s), term(s), or provision(s) shall be deemed not to be a part of this Agreement. The Parties shall not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement invalid. 21. The Parties agree that, as of the Effective Date, litigation concerning the alleged violations of 8 U.S.C. § 1324b that IER has found are the subject of the Investigation is not reasonably foreseeable. To the extent that any party previously implemented a litigation hold to preserve documents, electronically stored information, or things related to this matter, the party is no longer required to maintain such a litigation hold. Nothing in this paragraph relieves either party of any other obligations imposed by this Agreement. 20. Should any provision of this Agreement be declared or determined by any court to be illegal or invalid, the validity of the remaining parts, terms or provisions shall not be affected and the term or provision shall be deemed not to be a part of this Agreement. The Parties agree that they will not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 21. The Parties agree to bear their own costs, attorneys’ fees and other expenses incurred in the IER Investigation.

ADDITIONAL TERMS OF SETTLEMENT. 17. If IER has reason to believe that Respondent has violated or is violating any provision of this Agreement, IER may, in its sole discretion, notify Respondent of the purported violation rather than initiate a new discrimination investigation or seek to judicially enforce the Agreement. If IER has exercised its discretion to notify Respondent of the purported violation, Respondent shall have thirty (30) calendar days from the date IER notifies it of the purported violation(s) to cure the violation(s) to IER’s satisfaction, before IER deems Respondent to be in violation of this Agreement and proceeds to take appropriate enforcement actions. 1820. This Agreement may be enforced in sets forth the entire agreement between the Parties and fully supersedes any and all prior agreements or understandings between the Parties pertaining to the IER Investigation. This Agreement is governed by the laws of the United States District Court for the District of South CarolinaStates. This paragraph, or the initiation of a lawsuit Agreement shall be deemed to enforce the Agreement under this paragraph, including any counterclaims asserted, does not constitute have been drafted by both Parties and should shall not be construed as against any one party in the event of a waiver subsequent dispute concerning the terms of sovereign immunity or any other jurisdictional or legal defense available to the United StatesAgreement. The Parties agree that the paragraphs set forth in Part II of this Agreement (entitled “Terms of Settlement”) contain are material terms, without waiver of either Parties’ right to argue that the other terms in the Agreement are material. 1921. This Agreement may be enforced in the United States District Court for the Northern District of Texas or any court of competent jurisdiction. This provision does not constitute a waiver of sovereign immunity or any other defense the United States might have against a claim for enforcement or counterclaims asserted against it. 22. Should any court declare or determine that any provision(s) of this Agreement is/are illegal or invalid, the validity of the remaining part(s), term(s) or provision(s) shall not be affected and said illegal or invalid part(s), term(s), or provision(s) shall be deemed not to be part of this Agreement. The Parties shall not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 23. The Parties agree that, as of the Effective Date, litigation concerning the alleged violations of 8 U.S.C. §§ 1324b 1324b(a)(1) and (a)(6) that IER has found reasonable cause to believe that Respondent committed is not reasonably foreseeable. To the extent that any party previously implemented a litigation hold to preserve documents, electronically stored information, or things related to this matter, the party is no longer required to maintain such a litigation hold. Nothing in this paragraph relieves either party of any other obligations imposed by this Agreement. 20. Should any provision of this Agreement be declared or determined by any court to be illegal or invalid, the validity of the remaining parts, terms or provisions shall not be affected and the term or provision shall be deemed not to be a part of this Agreement24. The Parties agree that they will not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 21. The Parties agree to shall each bear their own costs, attorneys’ fees and other expenses incurred in the IER Investigationthis action.

ADDITIONAL TERMS OF SETTLEMENT. 17. If IER has reason to believe that Respondent has violated or is violating any provision of this Agreement, IER may, in its sole discretion, notify Respondent of the purported violation rather than initiate a new discrimination investigation or seek to judicially enforce the Agreement. If IER has exercised its discretion to notify Respondent of the purported violation, Respondent shall have thirty (30) calendar days from the date IER notifies it of the purported violation(s) to cure the violation(s) to IER’s satisfaction, before IER deems Respondent to be in violation of this Agreement and proceeds to take appropriate enforcement actions. 1814. This Agreement may be enforced in sets forth the entire agreement between the Parties and fully supersedes any and all prior agreements or understandings between the Parties pertaining to the Investigation. This Agreement is governed by the laws of the United States District Court for the District of South CarolinaStates. This paragraph, or Agreement shall be deemed to have been drafted by the initiation of a lawsuit to enforce the Agreement under this paragraph, including any counterclaims asserted, does not constitute Parties and should shall not be construed as against any one party in the event of a waiver subsequent dispute concerning the terms of sovereign immunity or any other jurisdictional or legal defense available to the United StatesAgreement. The Parties agree that the paragraphs set forth in Part II of this Agreement and attachments (entitled “Terms of Settlement”) contain are material terms, without waiver of either Parties’ any Party’s right to argue that the other terms in the Agreement are material. 1915. The United States District Court for the Southern District of California shall be the preferred venue for enforcement of any claims over which that court has subject matter jurisdiction. Otherwise, a Party must bring any claim or counterclaim to enforce this Agreement in a court of competent jurisdiction. This provision does not constitute a waiver of sovereign immunity or any other defense the United States might have against a claim for enforcement or counterclaims asserted against it. 16. Should any court declare or determine that any provision(s) of this Agreement is/are illegal or invalid, the validity of the remaining parts, terms or provisions shall not be affected and said illegal or invalid part(s), term(s), or provision(s) shall be deemed not to be part of this Agreement. The Parties shall not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 17. The Parties agree that, as of the Effective Date, litigation concerning the alleged violations of 8 U.S.C. § 1324b that IER has found are the subject of the Investigation is not reasonably foreseeable. To the extent that any party previously implemented a litigation hold to preserve documents, electronically stored information, or things related to this matter, the party is no longer required to maintain such a litigation hold. Nothing in this paragraph relieves either party of any other obligations imposed by this Agreement. 20. Should any provision of this Agreement be declared or determined by any court to be illegal or invalid, the validity of the remaining parts, terms or provisions shall not be affected and the term or provision shall be deemed not to be a part of this Agreement18. The Parties agree that they will not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 21. The Parties agree to shall each bear their own costs, attorneys’ fees and other expenses incurred in the IER Investigationthis action. 19. This Agreement may be executed in multiple counterparts, each of which together shall be considered an original but all of which shall constitute one agreement. The Parties shall be bound by facsimile signatures. By: [Name] Xxxx X. Xxxxxxx Dated: 10/14/2020 [Title] President/CEO Xxxxxxx Xxxxxxxxxx Deputy Special Counsel By: Dated:

ADDITIONAL TERMS OF SETTLEMENT. 17. If IER has reason to believe that Respondent has violated or is violating any provision of this Agreement, IER may, in its sole discretion, notify Respondent of the purported violation rather than initiate a new discrimination investigation or seek to judicially enforce the Agreement. If IER has exercised its discretion to notify Respondent of the purported violation, Respondent shall have thirty (30) calendar days from the date IER notifies it of the purported violation(s) to cure the violation(s) to IER’s satisfaction, before IER deems Respondent to be in violation of this Agreement and proceeds to take appropriate enforcement actions. 18. This Agreement may be enforced in is governed by the laws of the United States District Court for the District of South CarolinaStates. This paragraph, or the initiation of a lawsuit Agreement shall be deemed to enforce the Agreement under this paragraph, including any counterclaims asserted, does not constitute have been drafted by all Parties and should shall not be construed as against any one party in the event of a waiver subsequent dispute concerning the terms of sovereign immunity or any other jurisdictional or legal defense available to the United StatesAgreement. The Parties agree that the paragraphs set forth in Part II of this Agreement (entitled “Terms of Settlement”) contain are material terms. 18. The United States District Court for Maryland shall be the preferred venue for enforcement of any claims over which that court has subject matter jurisdiction. Otherwise, without a party must bring any claim or counterclaim to enforce this Agreement in a court of competent jurisdiction. This provision does not constitute a waiver of either Parties’ right to argue that sovereign immunity or any other defense the other terms in the Agreement are materialUnited States might have against a claim for enforcement or counterclaims asserted against it. 19. Should any court declare or determine that any provision of this Agreement is illegal or invalid, the validity of the remaining parts, terms or provisions shall not be affected and said illegal or invalid part(s), term(s), or provision(s) shall be deemed not to be a part of this Agreement. The Parties shall not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 20. The Parties agree that, as of the Effective Date, litigation concerning the alleged violations of 8 U.S.C. § 1324b that are the subject of the IER has found Investigation is not reasonably foreseeable. To the extent that any party previously implemented a litigation hold to preserve documents, electronically stored information, or things related to this matter, the party is no longer required to maintain such a litigation hold. Nothing in this paragraph relieves either party of any other obligations imposed by this Agreement. 20. Should any provision of this Agreement be declared or determined by any court to be illegal or invalid, the validity of the remaining parts, terms or provisions shall not be affected and the term or provision shall be deemed not to be a part of this Agreement. The Parties agree that they will not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 21. The Parties agree to shall each bear their own costs, attorneys’ fees and other expenses incurred in this action. 22. This Agreement sets forth the entire agreement between the Parties and fully supersedes any and all prior agreements or understandings between the Parties pertaining to the IER Investigation. 23. This Agreement may be executed in multiple counterparts, each of which together shall be considered an original but all of which shall constitute one agreement. The Parties agree to be bound by electronically transmitted signatures.

ADDITIONAL TERMS OF SETTLEMENT. 17. If IER has reason to believe that Respondent has violated or is violating any provision of this Agreement, IER may, in its sole discretion, notify Respondent of the purported violation rather than initiate a new discrimination investigation or seek to judicially enforce the Agreement. If IER has exercised its discretion to notify Respondent of the purported violation, Respondent shall have thirty (30) calendar days from the date IER notifies it of the purported violation(s) to cure the violation(s) to IER’s satisfaction, before IER deems Respondent to be in violation of this Agreement and proceeds to take appropriate enforcement actions. 18. This Agreement may be enforced in sets forth the entire agreement between the Parties and fully supersedes any and all prior agreements or understandings between the Parties pertaining to the subject matter herein. This Agreement is governed by the laws of the United States District Court for the District of South CarolinaStates. This paragraph, or the initiation of a lawsuit Agreement shall be deemed to enforce the Agreement under this paragraph, including any counterclaims asserted, does not constitute have been drafted by both Parties and should shall not be construed as against any one party in the event of a waiver subsequent dispute concerning the terms of sovereign immunity or any other jurisdictional or legal defense available to the United StatesAgreement. The Parties agree that the paragraphs set forth in Part II of this Agreement (entitled “Terms of Settlement”) contain are material terms, without waiver of either Parties’ right to argue that the other terms in the Agreement are material. 18. The United States District Court for the District of Idaho shall be the preferred venue for enforcement of any claims over which that court has subject matter jurisdiction. Otherwise, a party must bring any claim or counterclaim to enforce the agreement in a court of competent jurisdiction. This provision does not constitute a waiver of sovereign immunity or any other defense the United States might have against a claim for enforcement or counterclaims asserted against it. 19. The Parties agree that, as of the Effective DateDate of this Agreement, litigation concerning the alleged violations of 8 U.S.C. § 1324b that IER XXX has found reasonable cause to believe that Respondent committed is not reasonably foreseeable. To the extent that any either party previously implemented a litigation hold to preserve documents, electronically stored information, or things related to this matter, the party is no longer required to maintain such a litigation hold. Nothing in this paragraph relieves either party of any other obligations imposed by this Agreement. 20. Should any provision of this Agreement be declared or determined by any court to be illegal or invalid, the validity of the remaining parts, terms or provisions shall not be affected and the term or provision shall be deemed not to be a part of this Agreement. The Parties agree that they will not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 21. The Parties agree to shall bear their own costs, attorneys’ fees and other expenses incurred in the IER Investigationthis investigation. 22. This Agreement may be executed in multiple counterparts, each of which together shall be considered an original but all of which shall constitute one agreement. The Parties shall be bound by facsimile or other electronically transmitted signatures.

ADDITIONAL TERMS OF SETTLEMENT. 17. If IER has reason to believe that Respondent has violated or is violating any provision of this Agreement, IER may, in its sole discretion, notify Respondent of the purported violation rather than initiate a new discrimination investigation or seek to judicially enforce the Agreement. If IER has exercised its discretion to notify Respondent of the purported violation, Respondent shall have thirty (30) calendar days from the date IER notifies it of the purported violation(s) to cure the violation(s) to IER’s satisfaction, before IER deems Respondent to be in violation of this Agreement and proceeds to take appropriate enforcement actions. 1820. This Agreement may be enforced in is governed by the laws of the United States District Court for the District of South CarolinaStates. This paragraph, or the initiation of a lawsuit Agreement shall be deemed to enforce the Agreement under this paragraph, including any counterclaims asserted, does not constitute have been drafted by both Parties and should shall not be construed as against any one party in the event of a waiver subsequent dispute concerning the terms of sovereign immunity or any other jurisdictional or legal defense available to the United StatesAgreement. The Parties agree that the paragraphs set forth in Part II of this Agreement (entitled “Terms of Settlement”) contain are material terms. 21. The United States District Court for the Eastern District of Pennsylvania shall be the preferred venue for enforcement of any claims over which that court has subject matter jurisdiction. Otherwise, without a party must bring any claim or counterclaim to enforce this Agreement in a court of competent jurisdiction. This provision does not constitute a waiver of either Parties’ right to argue that sovereign immunity or any other defense the other terms in the Agreement are materialUnited States might have against a claim for enforcement or counterclaims asserted against it. 1922. Should any court declare or determine that any provision of this Agreement is illegal or invalid, the validity of the remaining parts, terms, or provisions shall not be affected and said illegal or invalid part(s), term(s), or provision(s) shall be deemed not to be a part of this Agreement. The Parties shall not, individually or in combination with, or through, another, seek to have any court declare or determine that any provision of this Agreement is invalid. 23. The Parties agree that, as of the Effective Date, litigation concerning the alleged violations of 8 U.S.C. § 1324b that are the subject of the IER has found Investigation is not reasonably foreseeable. To the extent that any party previously implemented a litigation hold to preserve documents, electronically stored information, or things related to this matter, the party is no longer required to maintain such a litigation hold. Nothing in this paragraph relieves either party the Parties of any other obligations imposed by this Agreement. 2024. Should any provision of Neither Party will offer this Agreement be declared as evidence of liability or determined by any court to be illegal or invalidlack thereof in a legal proceeding, the validity of the remaining parts, terms or provisions shall not be affected and the term Parties retain the right to use this Agreement in any legal proceeding or provision shall be deemed not action to be a part enforce the terms of this Agreement. 25. The Parties agree that they will not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 21. The Parties agree to shall each bear their own costs, attorneys’ fees fees, and other expenses incurred in this action. 26. This Agreement sets forth the entire agreement between the Parties and fully supersedes any and all prior agreements or understandings between the Parties pertaining to the IER Investigation. 27. This Agreement may be executed in multiple counterparts, each of which together shall be considered an original but all of which shall constitute one agreement. The Parties agree to be bound by electronic signatures.

ADDITIONAL TERMS OF SETTLEMENT. 17. If IER has reason to believe that Respondent has violated or is violating any provision of this Agreement, IER may, in its sole discretion, notify Respondent of the purported violation rather than initiate a new discrimination investigation or seek to judicially enforce the Agreement. If IER has exercised its discretion to notify Respondent of the purported violation, Respondent shall have thirty (30) calendar days from the date IER notifies it of the purported violation(s) to cure the violation(s) to IER’s satisfaction, before IER deems Respondent to be in violation of this Agreement and proceeds to take appropriate enforcement actions. 1811. This Agreement may be enforced in is governed by the laws of the United States District Court for the District of South CarolinaStates. This paragraph, or the initiation of a lawsuit Agreement shall be deemed to enforce the Agreement under this paragraph, including any counterclaims asserted, does not constitute have been drafted by both Parties and should shall not be construed as against any one party in the event of a waiver subsequent dispute concerning the terms of sovereign immunity or any other jurisdictional or legal defense available to the United StatesAgreement. The Parties agree that the paragraphs set forth in Part II of this Agreement (entitled “Terms of Settlement”) contain are material terms. 12. The United States District Court for the Northern District of Texas shall be the preferred venue for enforcement of any claims over which that court has subject matter jurisdiction. Otherwise, without a party must bring any claim or counterclaim to enforce this Agreement in a court of competent jurisdiction. This provision does not constitute a waiver of either Parties’ right to argue that sovereign immunity or any other defense the other terms in the Agreement are materialUnited States might have against a claim for enforcement or counterclaims asserted against it. 1913. The Parties agree that, as of the Effective DateDate of this Agreement, litigation concerning the alleged violations of 8 U.S.C. § 1324b that IER has found XXX believes Respondent committed is not reasonably foreseeable. To the extent that any If either party previously implemented a litigation hold to preserve documents, electronically stored information, or things related to this matter, the party is no longer required to maintain such a litigation hold. Nothing in this paragraph relieves either party of any other obligations imposed by this Agreement. 2014. Should any provision of this Agreement be declared or determined by any court to be illegal or invalid, the validity of the remaining parts, terms terms, or provisions shall not be affected and the term or provision shall be deemed not to be a part of this Agreement. The Parties agree that they will not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 2115. The Parties agree to bear their own costs, attorneys’ fees fees, and other expenses incurred in this action. 16. This Agreement sets forth the IER Investigationentire agreement between the Parties and fully supersedes any and all prior agreements or understandings between the Parties pertaining to the subject matter herein. 17. This Agreement may be executed in multiple counterparts, each of which together shall be considered an original, but all of which shall constitute one agreement. The Parties agree to be bound by electronically transmitted signatures.

ADDITIONAL TERMS OF SETTLEMENT. 17. If IER has reason to believe that Respondent has violated or is violating any provision of this Agreement, IER may, in its sole discretion, notify Respondent of the purported violation rather than initiate a new discrimination investigation or seek to judicially enforce the Agreement. If IER has exercised its discretion to notify Respondent of the purported violation, Respondent shall have thirty (30) calendar days from the date IER notifies it of the purported violation(s) to cure the violation(s) to IER’s satisfaction, before IER deems Respondent to be in violation of this Agreement and proceeds to take appropriate enforcement actions. 1811. This Agreement may be enforced in is governed by the laws of the United States District Court for the District of South CarolinaStates. This paragraph, Agreement sets forth the entire agreement between the Parties and fully supersedes any and all prior agreements or understandings between the initiation of a lawsuit Parties pertaining to enforce the subject matter herein. This Agreement under this paragraph, including any counterclaims asserted, does not constitute shall be deemed to have been drafted by both Parties and should shall not be construed as against any one party in the event of a waiver subsequent dispute concerning the terms of sovereign immunity or any other jurisdictional or legal defense available to the United StatesAgreement. The Parties agree that the paragraphs set forth in Part II of this Agreement (entitled “Terms of Settlement”) contain are material terms. 12. The United States District Court for the Southern District of New York shall be the preferred venue for enforcement of any claims over which that court has subject matter jurisdiction. Otherwise, without a party must bring any claim or counterclaim to enforce this Agreement in a court of competent jurisdiction. This provision does not constitute a waiver of either Parties’ right to argue that sovereign immunity or any other defense the other terms in the Agreement are materialUnited States might have against a claim for enforcement or counterclaims asserted against it. 1913. The Parties agree that, as of the Effective DateDate of this Agreement, litigation concerning the alleged violations of 8 U.S.C. § 1324b that IER has found Investigation is not reasonably foreseeable. To the extent that any If either party previously implemented a litigation hold to preserve documents, electronically stored information, or things related to this matter, the party is no longer required to maintain such a litigation hold. Nothing in this paragraph relieves either party of any other obligations imposed by this Agreement. 2014. Should any provision of this Agreement be declared or determined by any court to be illegal or invalid, the validity of the remaining parts, terms terms, or provisions shall not be affected and the term or provision shall be deemed not to be a part of this Agreement. The Parties agree that they will not, individually or in combination with another, seek to have any court declare or determine that any provision of this Agreement is invalid. 2115. The Parties agree to bear their own costs, attorneys’ fees fees, and other expenses incurred in the IER Investigationthis action. 16. This Agreement may be executed in multiple counterparts, each of which together shall be considered an original, but all of which shall constitute one agreement. The Parties agree to be bound by electronically transmitted signatures.