SETTLEMENT AGREEMENT AND MUTUAL RELEASE (CONNECTICUT)

1. PARTIES AND BACKGROUND

This Settlement Agreement and Mutual Release (the "Agreement") is entered into as of [EFFECTIVE DATE] by and between:

• [PARTY A LEGAL NAME] ("Party A"), a [entity type], with its principal place of business at [address]; and
• [PARTY B LEGAL NAME] ("Party B"), a [entity type], with its principal place of business at [address]

Background. The Parties are involved in a dispute arising from [describe dispute, including case caption and docket number if applicable]. The Parties desire to settle and resolve all claims between them.

2. SETTLEMENT PAYMENT AND TIMING

• Settlement Amount: [$AMOUNT] to be paid by [PAYER] to [PAYEE].
• Payment Method: [Wire transfer / ACH / Certified check].
• Due Date: Payment due within [X] business days of the Effective Date.
• Late Payment Interest: Interest shall accrue at [X]% per annum or the maximum rate permitted by Connecticut law (12% per annum under Conn. Gen. Stat. Section 37-3a), whichever is less.

3. MUTUAL RELEASE OF CLAIMS

3.1 Release by Party A. Party A hereby releases and forever discharges Party B and its affiliates from any and all claims, whether known or unknown, arising out of or relating to [describe dispute/time period], from the beginning of time through the Effective Date.

3.2 Release by Party B. Party B hereby releases and forever discharges Party A and its affiliates from any and all claims, whether known or unknown, arising out of or relating to [describe dispute/time period], from the beginning of time through the Effective Date.

3.3 Carve-Outs. The releases do not extend to obligations arising under this Agreement or claims for enforcement of this Agreement.

4. WAIVER OF UNKNOWN CLAIMS

4.1 Acknowledgment of Unknown Claims. Each Party acknowledges that it may have claims against the other Party of which it is not currently aware and expressly assumes the risk of the existence of such unknown claims.

4.2 Express Waiver. EACH PARTY EXPRESSLY WAIVES AND RELINQUISHES, TO THE FULLEST EXTENT PERMITTED BY CONNECTICUT LAW, ANY AND ALL RIGHTS AND BENEFITS THAT IT MAY HAVE UNDER ANY LAW OR COMMON LAW PRINCIPLE THAT WOULD OTHERWISE LIMIT THE RELEASE TO CLAIMS KNOWN OR SUSPECTED TO EXIST AT THE TIME OF EXECUTING THIS AGREEMENT.

Each Party specifically waives any rights under any statute, rule, or common law principle (including any principles similar to California Civil Code Section 1542) that provides:

"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."

[// GUIDANCE: Connecticut follows common law principles regarding releases. An express waiver of unknown claims should be included. Connecticut courts generally enforce broad releases when the language is clear and unambiguous.]

4.3 Initials. Party A Initials: _______ Party B Initials: _______

5. NO ADMISSION OF LIABILITY

This Agreement is a compromise of disputed claims. Nothing herein shall be construed as an admission of liability.

6. DISMISSAL OF ACTIONS

Within [X] days of receipt of the Settlement Amount, the Parties shall file a [Stipulation of Dismissal with prejudice] of [Case Caption and Docket Number] in [Court Name].

7. CONFIDENTIALITY AND NON-DISPARAGEMENT

7.1 Confidentiality. The terms and existence of this Agreement shall be kept confidential.

7.2 Non-Disparagement. Each Party agrees not to make false or disparaging statements about the other Party.

8. TAXES AND ALLOCATION

• Allocation: [Specify allocation].
• Tax Responsibility: Each Party is responsible for its own tax obligations.
• Tax Reporting: [PAYER] shall issue IRS Form [1099 / W-2 / other] as required by law.

9. REPRESENTATIONS AND AUTHORITY

Each Party represents that it has full power and authority to execute this Agreement and has not assigned any claims released herein.

10. REMEDIES AND SPECIFIC PERFORMANCE

10.1 Injunctive Relief. The non-breaching Party shall be entitled to seek injunctive relief without the requirement of posting a bond.

10.2 Attorneys' Fees. In any action to enforce this Agreement, the prevailing Party shall recover its reasonable attorneys' fees.

11. GOVERNING LAW AND DISPUTE RESOLUTION

11.1 Governing Law. This Agreement shall be governed by the laws of the State of Connecticut.

11.2 Venue. Any dispute shall be resolved in the state or federal courts located in [Hartford County / Fairfield County / New Haven County], Connecticut.

11.3 Jury Waiver. TO THE FULLEST EXTENT PERMITTED BY CONNECTICUT LAW, EACH PARTY HEREBY WAIVES ANY RIGHT TO A TRIAL BY JURY.

Party A Initials: _______ Party B Initials: _______

12. MISCELLANEOUS

12.1 Entire Agreement. This Agreement constitutes the entire understanding between the Parties.

12.2 Amendments. This Agreement may not be amended except by written instrument signed by both Parties.

12.3 Severability. If any provision is held invalid, the remaining provisions remain in force.

12.4 Counterparts and Electronic Signatures. Electronic signatures are valid pursuant to the Connecticut Uniform Electronic Transactions Act (Conn. Gen. Stat. Section 1-266 et seq.).

13. SIGNATURES

text
PARTY A: PARTY B:

__________________________ __________________________
Signature Signature

__________________________ __________________________
Printed Name Printed Name

__________________________ __________________________
Title Title

__________________________ __________________________
Date Date

WAIVER OF UNKNOWN CLAIMS INITIALS:

Party A: _______ Party B: _______

JURY WAIVER INITIALS:

Party A: _______ Party B: _______