the promise to seek reassignment could not be “construed to create a substantive right to money damages.” Id. at 519. Ms. Patterson seeks damages for the Agency’s alleged breach of a promise that “[a]ll standard operating procedures will apply to when and how the complainant will be eligible for advancement to her next career ladder promotion to grade 12.” Compl. If 8. Thus, the remedy in this context is money. Plaintiffs damages would be the difference between what she was paid and what she would have been paid had she been promoted earlier. The Government argues that the administrative procedure referenced in the settlement agreement is the exclusive remedy available to plaintiff for breach of her settlement agreement. See Doe v. United States, 513 F.3d 1348, 1355-56 (Fed.Cir.2008) (<HOLDING>). The Doe court held that rights granted to
holding that an employees state law claim against employer for breach of settlement agreement arrived at by virtue of grievance process established by the collective bargaining agreement was preempted by labor management relations act holding that a procedure established by collective bargaining agreement was the exclusive process available to employees where the dispute was grievable holding dispute under collective bargaining agreement not arbitrable as delegation of nondelegable authority without reference to whether provision was consented to by parties holding that a debtorinpossession could reject a collective bargaining agreement holding that a collective bargaining agreement to arbitrate is binding upon individual employees even when dispute involves federal cause of action