A model settlement agreement and release of claims for Merit Systems Protection Board/Equal Employment Opportunity Commission (EEOC) cases commonly referred to as mixed cases, including a release of claims against the agency employer. It can be used in mixed case appeals filed with the MSPB alleging that the agency's action was taken because of discrimination based on race, color, religion, sex, national origin, disability, age, or genetic information. This Standard Document is based on federal law and applies to federal agency workplaces. It is drafted in favor of the agency. This Standard Document has integrated notes with important explanations and drafting tips.