Butler v. The Vons Companies
Where labor union's grievance against employer on behalf of employee relating to specific altercation with manager concluded with release agreement stating that employee was waiving all rights to then-unknown claims; employee prior to signing release had made discrimination allegations to employer pertaining to a different incident; negotiation of release had only included discussion of altercation matter with manager and not possible discrimination claims; and principal parties to release were union and employer, with employee referred to merely as "grievant," intended scope of waiver was ambiguous, and question of fact existed as to whether it effectively waived employee's right to sue employer for discrimination.
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