SETTLEMENT AGREEMENT BETWEEN THE UNITED STATES OF AMERICA AND ILLINOIS STATE POLICE

III. SPECIFIC REMEDIAL RELIEF

24. The ISP has reinstated the following applicants, and enrolled them in Cadet Class 119. The ISP will provide each ISP cadet applicant identified in this paragraph with remedial relief upon graduation from Cadet Class 119. Remedial relief includes retroactive seniority from the date listed below, and placement at a salary step congruent to their modified seniority date. The ISP will submit the applicant to the State Employees Retirement System (SERS) for inclusion in the Tier 1 pension plan with the starting employment date listed below. The ISP cannot compel SERS to accept the applicant into the Tier 1 plan, but will fully support inclusion. As with all state employees, any necessary employee contributions required by SERS are the responsibility of the applicant. This offer will be made to the following individuals:

25. Prior to their reinstatement into Cadet Class 119, ISP required each of the reinstated applicants identified in paragraph 24 to execute a document entitled "Settlement Agreement and General Release." The United States is not a party to this document.

26. It is acknowledged by the United States that once the ISP has offered settlement to all identified Claimants, any Claimant who has declined reinstatement to the CC-119 selection process will have waived his rights to further employment as a result of this Agreement.