University of Iowa reaches separation agreement with Chris Doyle

CEDAR RAPIDS, Iowa (KCRG) - The University of Iowa reached a separation agree with Executive Director of Football and Head Strength and Conditioning Coach Chris Doyle on June 15.

The UI Office of General Counsel said it engaged Husch Blackwell, a Kansas City law firm, to conduct an independent review of issues and allegations relating to racial disparities within the football program.

UI says Raimond Braithwaite will continue to serve as interim director of the football strength and conditioning program.

Leaders at the University of Iowa will be meeting with media at 1 p.m.

The separation agreement says Doyle will voluntarily resign on June 15, and the University and Doyle will release mutually acceptable statements regarding the resignation.

The agreement also says the University will pay Doyle 15 months of base salary for fiscal year 2020-2021, in two separate lump sum payments of $556,249.50 on August 1 and January 1, 2021.

Gary Barta’s statement:

“The University of Iowa has reached a separation agreement with Executive Director of Football and Head Strength and Conditioning Coach Chris Doyle. We wish Chris the best moving forward in his career.”

Chris Doyle’s statement:

“Iowa City has been home to our family for 21 years. I am grateful Iowa football provided an opportunity to work with incredible players, coaches, and support staff. I have worked diligently to make a positive impact on the lives of student-athletes, support them as they speak out, and look forward to continued growth. I am confident that my record and character will be confirmed in the course of the independent review. The University and I have reached an agreement and it is time to move on from Iowa football. My family and I are looking forward to the next chapter.”

The rest of the agreement is as follows:

This SEPARATION AGREEMENT AND GENERAL RELEASE (“Agreement”) is entered into by Christopher F. Doyle (“Employee") and the State University of lowa and the Board of Regents, State of lowa, their current and former agents, officers, and employees, whether acting in either their official or individual capacities (“University”).

WHEREAS, Employee was employed by the University beginning July 1, 1999; and,

WHEREAS, Employee and University wish to resolve all matters relating to Employee's employment with University;

NOW, THEREFORE, in exchange for their mutual promises and for other good and valuable consideration, the sufficiency of which is acknowledged, the parties agree as follows:

1. Resignation. Employee shall voluntarily resign from employment with the Department on June 15, 2020 (last day worked), hereinafter "Separation Date." This is not a resignation in lieu of termination. Employee will receive current salary and all applicable University benefits for the duration of Employee's employment and at separation will be paid for accrued but unused vacation time in accordance with University policy.

2. Release of Mutually Agreeable Statements. University and Employee agree they will each release mutually acceptable public statements regarding Employee's voluntary resignation and will communicate at all times in a manner consistent with those mutually acceptable statements. (see Exhibits A and B).

3. Consideration. In consideration for Employee's execution of, non revocation of, and compliance with this Settlement Agreement, including Employee's waiver and release of claims in this Agreement, University shall pay Employee fifteen (15) months of base salary for FY2020-2021, subject to all applicable withholdings in two separate lump sum payments of $556,249.50 on August 1, 2020 and January 1, 2021.

4. Benefits. After Mr. Doyle's resignation, University shall pay health and dental premiums for Employee (and dependents) at his current coverage levels for fifteen (15) months following his last month of employment (from July 2020 through September, 2021) or until Employee obtains employment with health benefits elsewhere, whichever is earlier.

5. Tax Liability. Should any tax liability, interest, or penalties be imposed under federal or state law or regulations as a result of the settlement payment made pursuant to this Agreement, Employee agrees to be solely responsible for, and to timely pay, any and all such obligations.

6. Unemployment Benefits. University agrees not to contest Employee's claim for unemployment benefits after his separation from employment.

7. Future Employment. Employee agrees he will not seek employment with the University in the future. Additionally, Employee agrees he will no longer host strength and conditioning camps on the University of Iowa campus or use the University of lowa name going forward. Except, however, Employee is entitled to accurately state his employment experience with the University of lowa.

8. Employment Verification. The University agrees to provide employment verification limited to Employee's dates of employment and positions held, subject to compliance with University's open records obligations.

9. Personal Property. University agrees to provide Employee supervised access to his University computer and email to retrieve personal records and information and to his office to obtain any personal items/belongings/property owned by Employee

10. Waiver and Release. In consideration for the University's agreement to the terms set forth above, Employee hereby irrevocably and unconditionally releases, remises and forever discharges and covenants not to sue the University, the State of lowa, and the Board of Regents for the State of lowa, and each of their respective agents, directors, officers, employees, representatives, attorneys, divisions, subsidiaries, affiliates (and agents, directors, officers, employees, representatives and attorneys of such divisions, subsidiaries and affiliates), and their predecessor, successors, heirs, executors, administrators and assigns, and all persons acting by, through, under or in concert with any of them (collectively, the "Releasees"), or any of them, of and from any and all actions, causes of action, suits, debts, charges, claims, liabilities, obligations, promises, agreements, controversies, damages, and expenses (including attorneys' fees and costs actually incurred), of any nature whatsoever, in law or equity, which Employee ever had, now has, or Employee or Employee's heirs, executors and administrators hereafter may have, particularly against each or any of the Releasees, from the beginning of time to the date of this Agreement, arising from or related to Employee's employment relationship with the University (and compensation and benefits related thereto) or the end thereof, including, but not limited to, any claims arising from any alleged violation by the University of any federal, state or local statutes, ordinances or common laws, including but not limited to, the Rehabilitation Act of 1973 (29U.S.C.8701, et seq.), Title VII ofthe Civil Rights Actof 1964 (42U.S.C.$ 2000, et seq.), the Age Discrimination in Employment Act (29 U.S.C. $ 626 et seq.); the Equal Pay Act (29 U.S.C. & 206(d)); the lowa Civil Rights Act (Iowa Code Chapter 216); lowa Wage Payment and Collection Law (lowa Code Chapter 91A); the Americans with Disabilities Act (42 U.S.C. $12101 et seq. and related sections and amendments); and any claims in violation of common law or public policy of this state. Employee acknowledges this release includes all claims against employees of the University of lowa, the State of lowa, and the Board of Regents for the State of lowa in their official and individual capacities.

a. Employee has read this Agreement in its entirety and understands all of its terms.

b. Employee knowingly, freely, and voluntarily agrees to all of the terms and

conditions stated in this Agreement, including without limitation, the waiver, release, and covenants contained in it.

11. Legal Advice. Employee was represented at all times by attorney Amy L. Reasner of Lynch Dallas, P.C. prior to executing this Agreement. University was represented at all times by its General Counsel and the lowa Attorney General's office prior to executing this Agreement.

12. Extinguishment of All Claims, Known or Unknown. Employee expressly acknowledges that this Agreement is intended to include all claims, whether known or unknown to Employee, that have arisen prior to or as of execution of this Agreement, and that this Agreement contemplates the extinguishment of any such claims, including but not limited to equitable relief. This Agreement does not extinguish claims that cannot be lawfully waived, the Employee's lowa Code Chapter 669 rights, or claims arising after the execution of this Agreement, such as an enforcement claim.

13. Waiver of Right to Damages. Employee further agrees Employee has no entitlement to or right to recover damages against University relating to the subject matter of the Agreement.

14. No Admission of Liability. This Agreement is not, and shall not in any way be construed as an admission of liability by University or by the State of lowa or the Board of Regents of the State of lowa or any of the Releasees that it engaged in any wrongful acts against Employee or that it violated any federal, state or local law. This Agreement is not and shall not in any way be construed as an admission of liability by Employee or the Additional Releasees that Employee engaged in any wrongful acts or violated any federal, state or local law.

15. Public Record. The parties specifically acknowledge that this Agreement is subject to disclosure in response to a request under lowa's public records law.

16. Approvals. The parties acknowledge that this Agreement is subject to lowa Code 22.13A and, as such, must be approved by the Executive Director of the Board of Regents and the President of the University and be reviewed by the Attorney General or his designee. This Agreement is not effective until it has received all necessary review and approvals. This Agreement will be posted to the Board of Regents website.

17. Governing Law and Venue. This Agreement is made and entered into in the State of lowa and shall in all respects be interpreted, construed, enforced, and governed under the laws of the State of Iowa. In the event any proceeding of a quasi-judicial or judicial nature is commenced in connection with this Agreement, the exclusive jurisdiction for the proceeding shall be in Johnson County District Court for the State of Iowa. This provision shall not be construed as waiving any immunity to suit or liability, including without

limitation sovereign immunity in state or federal court, which may be available to the State of Iowa and the University as its instrumentality.

18. Construction and Severability. The language of all parts of this Agreement shall in all cases be construed as a whole, according to its fair meaning, and not strictly for or against any of the parties. Should any provision, sentence, term, or word in this Agreement other than the release and covenant not to sue 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 said illegal or invalid part, term, provision, sentence, or word shall be deemed not to be a part of this Agreement.

19. Entire Agreement. This Agreement contains the entire agreement between the parties and supersedes any and all prior agreements, understandings, arrangements, and communications, whether oral or written, pertaining to the subject matter of this Agreement.

20. Modification of Agreement. This Agreement shall not be modified or amended except by written agreement of the parties.

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