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Multidisciplinary Expert for Greenwood Associates

Location:
Chicago, IL
Salary:
$60/70 k
Posted:
May 26, 2026

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Resume:

As more fully described in Section * below and subject to the terms of this Confidential Agreement, to settle your claims, Uber has agreed pay you a Net Settlement Amount of $369.55. This is the actual amount you will receive after deduction of the settlement costs and the fees owed to your attorneys. To be eligible to receive this payment, you must sign and return this Confidential Agreement no later than October 7, 2026.

This is a legally binding contract, so please read it carefully. CONFIDENTIAL INDIVIDUAL SETTLEMENT AGREEMENT AND

RELEASE OF ALL CLAIMS

This Confidential Individual Settlement Agreement and Release of All Claims (“Confidential Agreement”) is entered into by and between Manuel Esqueda (“Eligible Claimant”), on the one hand, and Uber Technologies, Inc. (“Uber”) on the other (each individually a “Party” and collectively the “Parties”). In consideration of the mutual covenants and promises in this Confidential Agreement, the Parties agree as follows.

1. Claims.

(a) Eligible Claimant has filed, is prepared to file, and/or could file arbitration demands with the American Arbitration Association (“AAA”), JAMS, ADR Services, Inc., any other arbitration service, or litigation in any court, asserting claims that Uber misclassified Eligible Claimant as an independent contractor and thereby violated certain federal, state, and local laws, and any other claims arising from their relationship with Uber as applicable. All such claims are referred to herein as the “Claims.”

(b) Eligible Claimant represents that except for the Claims referenced above, Eligible Claimant has no other charges, lawsuits, or claims of any kind against Uber or any other Released Party

(as that term is defined in Section 5 below) presently pending before any state, federal or other court, any state or federal agency, any other governmental entity, or any arbitration provider. Eligible Claimant is not aware of any Claims Eligible Claimant has or could have against Uber or any other Released Party except for those Released Claims as described in Section 5. If, arguendo, any such charges, lawsuits, claims, or arbitration demands are pending, Eligible Claimant agrees to immediately dismiss or withdraw the same with prejudice.

2. No Admission of Wrongdoing or Liability. By entering into this Confidential Agreement, neither Eligible Claimant nor Uber admit any liability as to the other, and none of the Parties admit the allegations or contentions of any other Party. Each Party is entering into this Confidential 2

Agreement for the sole purpose of resolving the Claims and avoiding the expense incident to protracted litigation and/or arbitration.

3. Consideration. In exchange for the promises contained herein, including Eligible Claimant’s release of all Claims against Uber as set forth in Paragraph 6, and provided that all conditions precedent to payment described herein have been satisfied, Uber shall pay to Eligible Claimant a settlement payment of $369.55 (the “Net Settlement Amount”), which is exclusive of attorney’s fees and settlement costs. As payment for the contingency fee and settlement costs Eligible Claimant owes Zimmerman Reed pursuant to Eligible Claimant’s agreement with Zimmerman Reed, attorneys’ fees in an amount of $246.36 shall be separately paid on your behalf to Zimmerman Reed. No deductions or withholding for taxes or otherwise shall be taken from these amounts, for which the Settlement Administrator will issue an IRS Form 1099(s) (if required). Eligible Claimant shall, at the same time Eligible Claimant executes this Confidential Agreement and delivers it to the Settlement Administrator, provide to the Settlement Administrator information necessary for the transfer of the Net Settlement Payment to Eligible Claimant and for IRS Form(s) 1099 to be issued (if required). Eligible Claimant agrees that, absent this Confidential Agreement, Eligible Claimant would not be entitled to this payment. Eligible Claimant agrees to timely pay in full any federal, state, or local tax owed on such payments made in this Section. Eligible Claimant and Uber agree that the consideration set forth in this Section is sufficient consideration for the Release given by Eligible Claimant in Section 5 and Eligible Claimant’s other promises in this Confidential Agreement. 4. Taxes. Eligible Claimant understands and expressly agrees that in the event any income or other taxes, including any interest and/or penalties, are determined to be owed by Eligible Claimant as a result of the payments described in Section 3 above or as a result of violation by Eligible Claimant of any reporting obligations arising from or attributable to said amounts, Eligible Claimant is solely responsible for the payment of such amounts. Eligible Claimant agrees to indemnify Uber for any amounts Eligible Claimant should have paid if Uber is required to pay such amounts on Eligible Claimant’s behalf.

Eligible Claimant’s counsel, Uber, and its counsel have made no representations regarding the taxability of the payments to be made pursuant to this Confidential Agreement. Eligible Claimant represents that Eligible Claimant has had an opportunity to receive independent tax advice regarding the taxability of any sums payable to Eligible Claimant and has not relied upon any representation of Uber or its counsel, or Eligible Claimant’s counsel, on that subject. 5. Aggregate Settlement. Claimant understands that Claimant is being offered the Gross Settlement Payment in Section 3 as a result of an aggregate settlement of multiple claimants represented by Claimant’s Counsel. Certain terms and conditions must be met under the aggregate settlement before Uber is required to make any payments, including the Gross Settlement Payment contemplated in this Confidential Agreement. Claimant understands that if the terms and conditions of the aggregate settlement are not met, even if Claimant signs this Confidential Agreement, Uber is not obligated to issue, and Claimant is not entitled to receive, the Gross Settlement Payment. If that is the case, Claimant will return to the position Claimant was in prior 3

to signing the Confidential Agreement, and none of the terms or conditions set forth in this Confidential Agreement will be enforceable against Claimant or Uber. 6. Release by Claimant. Eligible Claimant, on behalf of Eligible Claimant and Eligible Claimant’s executors, legatees, devisees, administrators, successors and assigns, does hereby and forever release and discharge Uber and its predecessor, successor, parent, subsidiary, sister and affiliated corporations, divisions and other related entities, as well as the successors, predecessors, owners, investors, officers, directors, partners, heirs, assigns, agents, employees, attorneys and representatives of each of them (each released party individually a “Released Party,” and all of the released parties collectively, the “Released Parties”), from any and all causes of action, judgments, liens, indebtedness, costs, damages, obligations, attorneys’ fees, losses, claims, liabilities and demands of whatever kind and character arising out of or in any way related to Eligible Claimant’s relationship with Uber, use of the Uber platform, classification as an independent contractor, or the allegations in the Claims through December 16, 2020 for all mileage driven in California and/or through the date the Release is signed and returned to Uber for mileage driven in all other states.

Eligible Claimant releases any and all past, present and future claims, demands, actions, suits, causes of action, obligations, damages, rights or liabilities, of any nature, kind or description whatsoever, regardless of the legal or equitable theory, that Eligible Claimant has or may have against Uber or any of the Released Parties which arise or arose at any point in time beginning from the date of Eligible Claimant’s first interaction with Uber and continuing through, up to, and including December 16, 2020 for all mileage driven in California and/or through the date the Release is signed and returned to Uber for mileage driven in all other states. This Release includes without limitation all assigned and derivative claims, whether known or unknown, asserted or unasserted, foreseen or unforeseen, contingent or absolute, suspected or unsuspected, disclosed or undisclosed, apparent or unapparent, pursuant to any theory of recovery, including whether based in tort, contract, statute, common law, public policy, or other legal theory and including unknown claims covered by California Civil Code Section 1542. Eligible Claimant’s released claims include, but are not limited to, any claims against Uber or any Released Party arising directly or indirectly, out of, relating to, or in any way connected to any alleged act, omission, misconduct, misrepresentation, transmission, breach, breach of contract, or occurrence. The Released Claims further include, but are not limited to, claims under the Fair Labor Standards Act, 29 U.S.C. §§ 201, et seq.; claims relating to any screening conducted by Uber pertaining to background screening, including under the Fair Credit Reporting Act, 15 U.S.C. §§ 1681, et seq., and any state analogues; claims arising out of related to any Independent Contractor Agreement and any other express or implied agreements between Eligible Claimant and Uber, including any demand for arbitration and any right to invoke any arbitration agreement contained therein, and any other express or implied agreements between Eligible Claimants and Uber; claims under any law pertaining to employment, misclassification (including any allegations regarding Uber’s tipping policy related in any way to misclassification), hours of work, payment of wages, unpaid compensation, wage and hour violations, unpaid costs, reimbursement of expenses, or any other perquisites of employment; claims under any other federal, state, county, city, or local law, ordinance, rule, or regulation regarding employment, wages or compensation, or payment, provision or contribution of any amount or benefit owed to Eligible Claimant or on behalf of Eligible Claimant, e.g., paid sick 4

leave, health care costs, etc. (and all of their implementing regulations and interpretive guidelines), including but not limited to (i) the California Labor Code (including §§ 132a, 200 et seq., 300 et seq., 400 et seq., 500 et seq., 1174, 1174.5, 1182.12, 1194, 1194.2, 1194.3, 1197, 1197.1, 1198, 1280, 1281.96, 1281.97, 1281.98, 1281.99, 2753, 2802, 2804, 2810.5, 2698 et seq., 4553 et seq.), (ii) California Code of Civil Procedure section 1021.5; (iii) California Business and Professions Code sections 17200 et seq., (iv) California Code of Regulations, title 8, sections 11010, 11040 and 11090, (v) any applicable California Industrial Welfare Commission Wage Orders, (vi) the Los Angeles Office of Wage Standards Ordinance, the San Francisco Admin. Code Minimum Wage Ordinance and Health Care Security Ordinance; (vii) N.J. Stat. §§ 34:11-4.2, 24:11- 4.4 (New Jersey Wage Payment Law); (viii) N.J. Stat. §§ 34:11-56a(4) (New Jersey Wage and Hour Law); (ix) N.J. Stat. § 34:19-1, et seq. (the New Jersey Whistleblower Act; (x) M.G.L c. 149 §§ 148, 148B, and 150; (xi) Mass. G.L. 151B (Massachusetts Payment of Wages Law); (xii) M.G.L c. 149 § 148C (Failure to Pay Sick Time); (xiii) Mass. Gen Laws Ch. 151, § 1A (Massachusetts Overtime Law);

(xiv) the Massachusetts Payment of Wages Law ch. 149, § 148; (xv) the Massachusetts Minimum Fair Wages Law; (xvi) the Massachusetts Equal Pay Act; (xvii) the Massachusetts Labor and Industries Act; (xviii) the Massachusetts Privacy Act; (xix) the Massachusetts Independent Contractor statute; (xx) the Massachusetts Earned Sick Time Law; (xxi) 820 ILCS 105/1, et seq.

(Minimum Wage & Overtime); (xxii) and any other similar state or local ordinances, (xxiii) any claims for employee benefits under any state or federal law, including without limitation, (xxiv) any claims under the Employee Retirement Income Security Act of 1974, 29 U.S.C. §§ 1001 et seq., all as amended; and (xxv) any claims of discrimination on any basis under any state, federal, or local law, including without limitation, (a) Title VII of the Civil Rights Act of 1964, 42 U.S.C. §§ 2000 et seq.; (b) the Civil Rights Act of 1866, 42 U.S.C. § 1981; (c) the Civil Rights Act of 1991; (d) the Americans with Disabilities Act, 42 U.S.C. §§ 12101 et seq.; (e) the Family and Medical Leave Act of 1993, all as amended; (f) the California Fair Employment and Housing Act; (g) the California Family Rights Act; (h) N.J. Stat. §§ 10:5-5, 10:5-12 (New Jersey Law Against Discrimination); (i) N.Y. Exec. Law § 290 et seq. (the New York State Human Rights Law); (j) the Massachusetts Civil Rights Act; (k) the Massachusetts Equal Rights Act; (l) the anti-discrimination provisions of the Massachusetts Paid Family and Medical Leave Act; (m) New York City Adm. Code § 8-101, et seq.;

(n) 755 Ill. Comp. Stat. Ann. 5/1-103, 5/2-101, 5/2-102, 5/2-103, 5/2-104 (Illinois Human Rights Act) and 56 Ill Adm. Code 5210.110; and (o) any other similar state or local laws, regulations or ordinances, in any jurisdiction, all as amended. The Released Claims further include, but are not limited to, claims for any form of damages or relief, including liquidated damages, and claims for restitution, statutory or other penalties (including under California’s Private Attorneys General Act (“PAGA”)), punitive damages, equitable relief, litigation costs, interest, attorneys’ fees, or any other form of relief. All claims covered by this release are collectively referred to in this Confidential Agreement as the “Released Claims.” The Released Claims do not include any personal injury claims arising from any personal injury accident Eligible Claimant may have been in that is unrelated to any transportation service Eligible Claimant provided. This Confidential Agreement (a) shall not affect any claims that Eligible Claimant may have which arise solely after 5

the Effective Date of this Confidential Agreement and (b) shall not serve as a release of any claims that cannot be released as a matter of law.1

Each Released Party is an intended beneficiary of the releases and agreements set forth in this Confidential Agreement, and on that basis is entitled to enforce this Confidential Agreement to the extent he, she or it is benefited by any release, covenant or provision of this Confidential Agreement.

Eligible Claimant expressly acknowledges and agrees that, by virtue of this Confidential Agreement, Eligible Claimant is not and cannot be an aggrieved employee under PAGA (and therefore has no standing under PAGA) to pursue any claim or action alleging California Labor Code violations against any Released Party on behalf of Eligible Claimant, any other individual, or the State of California.

7. No Future Claims. Eligible Claimant shall not file or cause to be filed and shall not prosecute in any manner any claims, charges, or actions against Uber or any other Released Party at any time with respect to any Released Claim. If any agency, tribunal, arbitration provider, or court assumes jurisdiction over any such claim, charge or action against any of the Released Parties, Eligible Claimant shall request and take all available actions to cause such agency, tribunal, arbitration provider, or court to dismiss the matter with prejudice. Eligible Claimant also agrees that Eligible Claimant shall not accept any remedy relating in any way to any Released Claim from any such agency, tribunal, arbitration provider, or court.

8. Express Waiver. Except as set forth above, Eligible Claimant expressly waives and relinquishes all rights and benefits afforded by Section 1542 of the Civil Code of the State of California, and any other relevant jurisdiction’s equivalent statute, and does so understanding and acknowledging the significance and consequence of such specific waiver of Section 1542. Section 1542 of the Civil Code of the State of California states as follows: A general release does not extend to claims that the creditor or releasing party does not know or suspect to exist in his or her favor at the time of executing the release and that, if known by him or her, would have materially affected his or her settlement with the debtor or released party.

Thus, notwithstanding the provisions of Section 1542, and for the purpose of implementing a full and complete release and discharge of all claims and disputes, except as otherwise provided herein, Eligible Claimant expressly acknowledges that this Confidential Agreement is intended to release, without limitation, all claims whether known or unknown, and all disputes which Eligible Claimant does not know or suspect to exist at the time of signature of this Confidential Agreement, and that this Confidential Agreement contemplates the extinguishment of any and all such claims and disputes. 1 Although this Template Release covers many federal, state, and local claims, for the avoidance of doubt, Uber reserves the right to enumerate additional specific federal, state, or local claims depending on the specific Claimant. 6

9. New Independent Contractor Agreement. Eligible Claimant agrees that Uber has the right to require Eligible Claimant to sign a new Platform Access Agreement in order to continue to use the Uber platform.

10. Confidentiality. The Parties agree that confidentiality is one of the most important terms of this Confidential Agreement and that the fact and terms of this Confidential Agreement are a private matter. Eligible Claimant agrees that Eligible Claimant will not directly or indirectly divulge or disclose the fact or terms of this Confidential Agreement, the amount of the settlement, or any of the settlement negotiations or communications leading to this Confidential Agreement

(collectively, “Confidential Information”) except as follows:

(a) Eligible Claimant may disclose Confidential Information in response to a valid subpoena or other legal process compelling disclosure of Confidential Information, on the condition that, upon receipt of a subpoena or other legal process compelling any disclosure of Confidential Information, Claimant (i) shall immediately notify and provide a copy of all relevant documentation by email to Counsel for Uber, Sophia Collins, Littler Mendelson, P.C., at ********@*******.***, and (ii) shall take all available actions to postpone disclosing Confidential Information to allow Uber a full opportunity to intervene and otherwise act to protect its rights in the Confidential Information.

(b) Eligible Claimant may disclose the terms of this Confidential Agreement to Claimant’s spouse or domestic partner, on the condition that Eligible Claimant’s spouse or domestic partner is informed of Eligible Claimant’s obligation to keep this Confidential Agreement confidential and promises to comply with the terms of this Confidential Agreement, and Eligible Claimant instructs his/her spouse or domestic partner not to disclose the fact or terms of this Confidential Agreement.

(c) Eligible Claimant may disclose the terms of this Confidential Agreement to Eligible Claimant’s tax advisors and attorneys, but only to the extent that it is required for the rendering of professional services, and on the condition that the person is informed of Eligible Claimant’s obligation to keep this Confidential Agreement confidential prior to the disclosure of the information, and promises to comply with the terms of the Confidential Agreement, and Eligible Claimant instructs them not to disclose the fact or terms of this Confidential Agreement.

(d) If Eligible Claimant is ever asked about the resolution of this matter, Eligible Claimant (and Eligible Claimant’s counsel and/or tax advisor) may say only “The matter has been resolved,” or “The matter is over with,” without elaboration, and without stating or implying payment of settlement funds.

Eligible Claimant represents that Eligible Claimant has not discussed this Confidential Agreement, its contents, the amount of the settlement or the existence or contents of the settlement negotiations leading to this Confidential Agreement with any person except with their spouse or domestic partner, the attorneys and employees of Zimmerman Reed, their counsel, or 7

as necessary to obtain tax advice from a tax advisor. Eligible Claimant represents and agrees Eligible Claimant has instructed and will continue to instruct Eligible Claimant’s spouse or domestic partner, employees, and tax advisors to hold all Confidential Information confidential and to comply with the provisions of this Section. Eligible Claimant agrees that Eligible Claimant will not issue or make any press release or press statement, respond to any press inquiry, or initiate or respond to media coverage or other publicity regarding Uber, the Released Parties, or this Confidential Agreement, nor post any notice on any website, listserv or social media, nor otherwise publicize any aspect or term of this settlement. Eligible Claimant agrees Eligible Claimant shall not disclose or communicate, directly or indirectly, with any other attorneys, any past, present or future driver any information about this settlement or any terms of this Confidential Agreement. Eligible Claimant agrees that any material breach or threatened breach of this Section shall entitle Uber and all Released Parties to damages and immediate injunctive relief to prevent further breach and injury. The Parties acknowledge and agree that the time and expense involved in proving actual damages resulting from violation of this Confidentiality provision render any breach appropriate for liquidated damages. Accordingly, in lieu of requiring actual proof of damages or losses, the Parties agree that, for each breach by Eligible Claimant, Uber will receive

$500 per incident up to a maximum of $2,000 or the amount of the Net Settlement Payment paid to the particular Claimant, whichever is lesser.

Eligible Claimant agrees that Uber and Released Parties shall also be entitled to recover reasonable attorneys’ fees for any action taken in response to Eligible Claimant’s knowing breach of this Section.

The Parties intend that this confidentiality provision be construed as broadly as possible in order to provide the maximum confidentiality.

Nothing in this Confidential Agreement, including this confidentially provision, shall have the purpose or effect of requiring Eligible Claimant to conceal the details relating to any claim of discrimination, harassment, or retaliation, provided that Eligible Claimant shall not reveal proprietary information consisting of non-public trade secrets, business plans, and customer information.

11. Arbitration. Any dispute arising out of this Confidential Agreement shall be resolved exclusively by final and binding arbitration, before a single arbitrator, in San Francisco, California pursuant to the then-applicable ADR Services, Inc. rules, policies, and/or procedures for employment-related disputes provided, however, that any claims, which by law may not be submitted to arbitration are not covered by this arbitration provision. The arbitration provided for herein shall be in lieu of any civil action, and any decision resulting from such arbitration shall be final and binding, and enforceable by any competent court of law. Judgment upon any such arbitration award may be entered by any state or federal court of competent jurisdiction. In the event any Party to this Confidential Agreement initiates any arbitration action or proceeding in connection with enforcement of this Confidential Agreement, the prevailing party in such action or proceeding shall be entitled to recover its reasonable costs, arbitration administration and arbitrator’s fees, and attorneys’ fees from the non-prevailing party. This Confidential Agreement shall be 8

admissible in any proceeding to enforce its terms. Notwithstanding the mandatory arbitration procedures set forth in this Confidential Agreement, Claimant or Uber may seek emergency, temporary or preliminary injunctive relief from a court of competent jurisdiction to seek enforcement of Section 9 and/or in aid of arbitration or pending final adjudication of a claim in arbitration where the arbitration award may be rendered ineffectual without such relief. To the extent permitted by law, the Parties further agree that any dispute subject to the arbitration provision in any Platform Access Agreement between Eligible Claimant and Uber shall be subject to the then-applicable ADR Services, Inc. rules. Should Eligible Claimant enter into a new arbitration agreement pursuant to a new Platform Access Agreement with Uber, such arbitration agreement shall govern and supersede this Section to the extent that there are any inconsistencies between the two agreements.

12. Governing Law. This Confidential Agreement shall be governed by the substantive law of the State of California.

13. Severability. If any provision of this Confidential Agreement is determined to be invalid or unenforceable, all of the other provisions shall remain valid and enforceable notwithstanding, unless the provision found to be unenforceable is of such material effect that this Confidential Agreement cannot be performed in accordance with the intent of the Parties in the absence thereof.

14. No Assignment. Eligible Claimant represents and warrants that no other person or entity has or has had any interest in any of the claims or matters being resolved by this Confidential Agreement, and that Claimant has the sole right and exclusive authority to execute this Confidential Agreement and receive the sums specified in it; and that Claimant has not sold, assigned, transferred, conveyed or otherwise disposed of any interest in any claims, demands, obligations, or causes of action released in this Confidential Agreement. Claimant represents and warrants that Eligible Claimant has the authority to enter into this Confidential Agreement and that no approval or consent of any third party is either necessary or a condition precedent to the formation or the enforcement of this Confidential Agreement. 15. Each Side To Bear Own Legal Fees and Costs. The payment described in Section 3 includes any and all costs and attorneys’ fees to which Eligible Claimant may be entitled. Accordingly, each Party hereto shall bear all of its or Eligible Claimant’s own attorneys’ fees and costs/expenses including any fees and costs/expenses owing to or incurred by its or his own counsel in connection with this matter, this Confidential Agreement, and all related matters, except as provided in Section 9.

16. Cooperation. Each Party agrees to cooperate fully and execute and deliver any and all supplementary documents and to take all additional actions, which reasonably may be necessary or appropriate to give full force and effect to the terms and intent of this Confidential Agreement without the receipt of further consideration.

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17. Entire Agreement. No promise, inducement or agreement other than that expressed in this Confidential Agreement has been made by either Party. This Confidential Agreement constitutes a single integrated contract expressing the entire agreement of the Parties hereto and supersedes all previous understandings, whether written or oral. There are no other agreements, written or oral, express or implied, between the Parties concerning the subject matter of this Confidential Agreement.

18. Modification. This Confidential Agreement can be amended, modified or terminated only by writing executed by Eligible Claimant, Eligible Claimant’s counsel, and the Chief Legal Officer of Uber.

19. No Implied Waiver. The waiver of any breach or failure of any Party to enforce any provision of this Confidential Agreement shall not operate as or be construed to be a waiver by that Party of any other breach or provision of this Confidential Agreement. 20. No Prejudice to the Drafter. Each Party has had a full and complete opportunity to review this Confidential Agreement, and make suggestions or changes, as has counsel for each Party. Accordingly, this Confidential Agreement is deemed to have been drafted jointly by the Parties and the Parties agree that the principle of construing ambiguities against the drafter shall not apply to this Confidential Agreement.

21. Execution in Counterparts and by Facsimile. This Confidential Agreement may be executed in one or more counterparts, all of which shall constitute one and the same document. Counterparts may be exchanged by email directed to counsel for the Parties. Each counterpart, whether bearing an original signature or an electronically scanned or DocuSign/Pandadoc signature, shall be deemed an original as against any party who signed it. 22. Consideration Period. Eligible Claimant has at least 21 days from the date Eligible Claimant receives this Confidential Agreement and any attached information to consider the terms of this Confidential Agreement, including whether to sign this Agreement (Consideration Period). If Eligible Claimant chooses to sign this Confidential Agreement before the Consideration Period ends, Eligible Claimant represents that it is because Eligible Claimant freely chooses to do so after carefully considering its terms. Eligible Claimant agrees Uber has made no threats or promises to induce Eligible Claimant to sign earlier.

23. Revocation Period: Eligible Claimant shall have seven (7) calendar days from the date Eligible Claimant signs this Confidential Agreement to revoke this Confidential Agreement by delivering a written notice of revocation to the same person as you returned this Confidential Agreement

(Revocation Period). If the Revocation Period expires on a weekend or holiday, Eligible Claimant will have until the end of the next business day to revoke. This Confidential Agreement will



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