NEGOTIATED SETTLEMENT AND RELEASE OF ALL CLAIMS
This Confidential Negotiated Settlement and Release of All Claims ("Agreement") is made and entered into
between David G. Mell ("Employee") and Imation Corp. ("Imation"). EMPLOYEE UNDERSTANDS THAT
EMPLOYEE CANNOT SIGN THIS AGREEMENT UNTIL AT LEAST TWENTY-ONE (21) DAYS
AFTER EMPLOYEE HAS RECEIVED THIS AGREEMENT, WHICH WAS ON DECEMBER 1, 1998.
1. WHAT IMATION AGREES TO DO
In return for this Agreement and for Employee's termination from Imation as described herein and in full and final
settlement, compromise, and release of all of Employee's employment-related claims (as described in section 2
below), but not as earnings used to calculate retirement benefits, Imation agrees to provide Employee
consideration as follows:
A. Imation agrees to pay Employee the amount of Five Hundred Fifty Five Thousand and no/100 Dollars
($555,000.00) less applicable deductions, such as federal, state, local and FICA payroll tax deductions.
Payment processing will begin following the expiration of fifteen (15) days after Employee signs this Agreement,
so long as Employee does not exercise Employee's right to rescind this Agreement pursuant to section 3.K.
B. Employee will be offered the opportunity to participate in Imation's Pre-Retirement Leave Program, by
voluntarily electing this status. Employee understands that the duration and terms of the Pre-Retirement Leave
Program are governed by Imation's Pre-Retirement Leave Policy. If Employee elects Pre-Retirement Leave,
Imation agrees to pay Employee's portion of benefit costs only for medical and dental insurance coverage for a
period of 26 weeks beginning immediately after Employee's termination. Thereafter, Employee will receive
medical and dental insurance benefits at the same rates and under the same coverages as other similarly situated
employees on Pre-Retirement Leave.
C. If Imation establishes a retiree medical program for any of its former employees that is effectiv