Settlement Agreement and Mutual Release - Connecticut

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JURISDICTION: Connecticut
LAST UPDATED: 2026-03-18
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SETTLEMENT AGREEMENT AND MUTUAL RELEASE

(STATE OF CONNECTICUT)

THIS SETTLEMENT AGREEMENT AND MUTUAL RELEASE (this "Agreement") is entered into as of [__/__/____] (the "Effective Date") by and between:

PARTY A:

PARTY B:

(Party A and Party B are each a "Party" and collectively the "Parties.")

TABLE OF CONTENTS

1. Recitals and Background
2. Definitions
3. Settlement Consideration
4. Payment Terms and Mechanics
5. Mutual Release of Claims
6. Waiver of Unknown Claims
7. Mutual Covenant Not to Sue
8. Release of Joint Tortfeasors
9. No Admission of Liability
10. Withdrawal / Dismissal of Pending Actions
11. Confidentiality
12. Non-Disparagement
13. Return of Property and Transition
14. Tax Provisions and Indemnification
15. Representations and Warranties
16. Remedies for Breach
17. Governing Law and Jurisdiction
18. Jury Trial Waiver
19. Miscellaneous Provisions
20. Execution and Signatures

1. RECITALS AND BACKGROUND

1.1 Dispute Background. The Parties are involved in a dispute arising from:

[________________________________]
[________________________________]
[________________________________]

(the "Dispute").

1.2 Pending Litigation. ☐ Litigation is pending:

• Case Caption: [________________________________]
• Docket Number: [________________________________]
• Court: ☐ Connecticut Superior Court, Judicial District of [________________________________] ☐ Connecticut Superior Court, Complex Litigation Docket at [________________________________] ☐ U.S. District Court for the District of Connecticut, [☐ Hartford ☐ New Haven ☐ Bridgeport] Division ☐ Other: [________________________________]

☐ No litigation is currently pending.

1.3 Cross-Claims and Counterclaims. ☐ The following cross-claims or counterclaims are pending:

[________________________________]

☐ No cross-claims or counterclaims are pending.

1.4 Desire to Settle. The Parties desire to settle all claims, counterclaims, and cross-claims between them and avoid further expense and uncertainty.

1.5 Adequate Consideration. The mutual releases, promises, covenants, and payment of the Settlement Amount constitute good and valuable consideration. This Agreement constitutes a valid accord and satisfaction under Connecticut common law and Conn. Gen. Stat. § 52-195a.

2. DEFINITIONS

2.1 "Agreement" means this Settlement Agreement and Mutual Release, including all exhibits.

2.2 "Claims" means any and all claims, demands, actions, causes of action, suits, proceedings, complaints, charges, grievances, liabilities, obligations, damages, losses, debts, judgments, liens, costs, expenses (including attorneys' fees), and rights of every kind, whether known or unknown, suspected or unsuspected, disclosed or undisclosed, matured or unmatured, accrued or unaccrued, contingent or fixed, arising under statute, common law, regulation, or otherwise.

2.3 "Effective Date" means the date first written above.

2.4 "Party A Released Parties" means Party A and its past, present, and future parents, subsidiaries, affiliates, officers, directors, managers, members, shareholders, partners, employees, agents, representatives, attorneys, insurers, predecessors, successors, and assigns.

2.5 "Party B Released Parties" means Party B and its past, present, and future parents, subsidiaries, affiliates, officers, directors, managers, members, shareholders, partners, employees, agents, representatives, attorneys, insurers, predecessors, successors, and assigns.

2.6 "Settlement Amount" means the amount specified in Section 3.1.

3. SETTLEMENT CONSIDERATION

3.1 Settlement Payment.

☐ Party A pays Party B: $[________________________________]
☐ Party B pays Party A: $[________________________________]
☐ Cross-Payments: Party A pays $[________________________________] and Party B pays $[________________________________]
☐ No monetary payment — mutual releases constitute sole consideration.
☐ Other consideration: [________________________________]

3.2 Allocation.

4. PAYMENT TERMS AND MECHANICS

4.1 Payment Schedule.

☐ Lump Sum: $[________________________________] due within [____] business days of the Effective Date.

☐ Installments:

4.2 Payment Method.

☐ Wire transfer ☐ ACH transfer ☐ Certified check payable to [________________________________]
☐ Check payable to counsel's trust account: [________________________________] ☐ Other: [________________________________]

4.3 Late Payment. Interest at [____]% per annum, or the statutory rate under Conn. Gen. Stat. § 37-3a (currently ten percent (10%) per annum), whichever is less. Written notice required; [____] business days to cure.

4.4 Default. If the payor fails to cure, the payee may: (a) declare the entire balance due; (b) seek enforcement, including entry of a stipulated judgment if applicable; and (c) recover costs and fees.

5. MUTUAL RELEASE OF CLAIMS

5.1 Release by Party A. Party A, on behalf of itself and all Party A Released Parties, irrevocably releases Party B Released Parties from all Claims arising out of, relating to, or connected with the Dispute and/or any events from the beginning of time through the Effective Date, including:

(a) All Claims asserted or assertable in the Dispute, including counterclaims;
(b) All Claims under Connecticut statutory law, including the Connecticut Fair Employment Practices Act (Conn. Gen. Stat. § 46a-58 et seq.), the Connecticut Wage Payment statutes (Conn. Gen. Stat. § 31-71a et seq.), the Connecticut Family and Medical Leave Act (Conn. Gen. Stat. § 31-51kk et seq.), the Connecticut Unfair Trade Practices Act (CUTPA) (Conn. Gen. Stat. § 42-110a et seq.), the Connecticut Whistleblower statute (Conn. Gen. Stat. § 31-51m), the Connecticut Trade Secrets Act (Conn. Gen. Stat. § 35-50 et seq.), and any other Connecticut statute;
(c) All federal law Claims;
(d) All common law Claims, including breach of contract, tort, fraud, misrepresentation, negligence, and unjust enrichment; and
(e) All Claims for damages and equitable relief.

5.2 Release by Party B. Party B, on behalf of itself and all Party B Released Parties, irrevocably releases Party A Released Parties from all Claims arising out of, relating to, or connected with the Dispute from the beginning of time through the Effective Date, including the same categories described in Section 5.1(a)-(e).

5.3 Excluded Claims. The mutual releases do NOT extend to:

(a) Obligations under this Agreement;
(b) Claims that cannot be released as a matter of law, including:

• Workers' compensation claims (Conn. Gen. Stat. § 31-275 et seq., subject to approval by a Workers' Compensation Commissioner under § 31-296);
• Vested ERISA benefits;
• Post-Effective Date claims;
  (c) [________________________________] (specify additional exclusions).

5.4 Scope. Each Party acknowledges its release is as broad as permitted by Connecticut law.

6. WAIVER OF UNKNOWN CLAIMS

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

6.2 Express Waiver. EACH PARTY EXPRESSLY WAIVES AND RELINQUISHES, TO THE FULLEST EXTENT PERMITTED BY CONNECTICUT LAW, ANY RIGHTS UNDER ANY LAW OR PRINCIPLE THAT WOULD LIMIT THE RELEASE TO KNOWN OR SUSPECTED CLAIMS, INCLUDING ANY STATUTE OR PRINCIPLE SIMILAR TO CALIFORNIA CIVIL CODE SECTION 1542, WHICH 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."

6.3 Assumption of Risk. Each Party assumes the risk that facts may differ from current knowledge.

6.4 Initials.

Party A: [____] Party B: [____] Date: [__/__/____]

7. MUTUAL COVENANT NOT TO SUE

7.1 Each Party covenants not to commence, maintain, or permit any action against the other's Released Parties with respect to any released Claim.

7.2 Neither Party shall participate in third-party actions against the other's Released Parties except as required by law.

7.3 Breach. The breaching Party shall: (a) immediately withdraw or dismiss the action; (b) indemnify the other for costs and fees; and (c) repay any Settlement Amount received.

8. RELEASE OF JOINT TORTFEASORS

8.1 Pursuant to Conn. Gen. Stat. § 52-572f, a release of one joint tortfeasor does not relieve others unless it so provides; but it reduces the claim against remaining tortfeasors by the consideration paid or any greater amount specified.

8.2 Scope.

☐ These releases apply ONLY to the identified Released Parties.
☐ These releases apply to ALL joint tortfeasors.

8.3 Contribution. Pursuant to Conn. Gen. Stat. § 52-572g, a released tortfeasor is discharged from all liability for contribution to any other joint tortfeasor.

8.4 Comparative Fault. The Parties acknowledge that under Conn. Gen. Stat. § 52-572h, Connecticut follows a modified comparative negligence system. Recovery is barred if a party's negligence is greater than the combined negligence of the other parties. The settlement value may be affected by the allocation of comparative fault.

9. NO ADMISSION OF LIABILITY

9.1 Compromise of disputed claims. No admission. Not admissible except to enforce, per Connecticut Code of Evidence § 4-8.

10. WITHDRAWAL / DISMISSAL OF PENDING ACTIONS

10.1 Within [____] business days of the Effective Date and receipt of any payment, the Parties shall:

☐ File a withdrawal of all claims, counterclaims, and cross-claims pursuant to Connecticut Practice Book § 17-44
☐ File a stipulated judgment pursuant to Connecticut Practice Book § 17-45
☐ File a stipulation of dismissal (if in federal court) pursuant to Fed. R. Civ. P. 41(a)(1)(A)(ii)
☐ Other: [________________________________]

10.2 With or Without Prejudice.

☐ With prejudice
☐ Without prejudice

10.3 Cooperation. Each Party shall cooperate fully.

11. CONFIDENTIALITY

11.1 The terms of this Agreement shall be kept strictly confidential, except:

(a) Attorneys, accountants, tax advisors, insurers, and financial advisors;
(b) Required by law, regulation, subpoena, or court order;
(c) Tax reporting;
(d) Immediate family who agree to confidentiality; and
(e) Mutual written agreement.

11.2 Permitted Statements. "The matter has been resolved to the mutual satisfaction of the parties."

11.3 Breach. Material breach; injunctive relief, damages, and fees available.

12. NON-DISPARAGEMENT

12.1 Each Party agrees not to make disparaging or defamatory statements regarding the other Party.

12.2 Exceptions. Truthful statements required by law, testimony, and communications with the CHRO or other government agencies are excepted.

13. RETURN OF PROPERTY AND TRANSITION

13.1 Within [____] business days of the Effective Date, each Party shall return all property, documents, records, and materials belonging to the other Party.

13.2 Specific Items.

By Party A to Party B: [________________________________]

By Party B to Party A: [________________________________]

☐ This Section does not apply.

13.3 Transition Cooperation. Each Party shall reasonably cooperate in any transition activities for [____] days following the Effective Date, including [________________________________].

14. TAX PROVISIONS AND INDEMNIFICATION

14.1 Each Party is responsible for its own federal and Connecticut state tax obligations.

14.2 Neither Party has made tax representations.

14.3 The payor shall issue required IRS forms per Section 3.2.

14.4 Each Party indemnifies the other from tax claims arising from the settlement.

15. REPRESENTATIONS AND WARRANTIES

15.1 Each Party Represents and Warrants:

(a) Full power and legal capacity;
(b) No assignment or transfer of released Claims;
(c) Has read and understood the Agreement;
(d) Had opportunity to consult with counsel;
(e) Enters voluntarily, without duress;
(f) Conducted sufficient investigation; and
(g) No outside promises or inducements.

15.2 Entity Representations. Execution duly authorized by all necessary organizational action.

16. REMEDIES FOR BREACH

16.1 Injunctive Relief. Breach of Sections 5, 6, 7, 11, or 12 would cause irreparable harm. Injunctive relief available without bond.

16.2 Prevailing Party Fees. The prevailing Party recovers reasonable attorneys' fees.

16.3 CUTPA Remedies. If a breach constitutes an unfair or deceptive trade practice, the non-breaching Party reserves CUTPA remedies, including treble damages and attorneys' fees under Conn. Gen. Stat. § 42-110g.

16.4 Stipulated Judgment. If the Parties elected a stipulated judgment under Section 10, breach may be enforced through contempt proceedings.

17. GOVERNING LAW AND JURISDICTION

17.1 Governing Law. Laws of the State of Connecticut, without choice-of-law principles.

17.2 Exclusive Jurisdiction.

☐ Connecticut Superior Court, Judicial District of [________________________________]
☐ U.S. District Court for the District of Connecticut
☐ Either of the above

18. JURY TRIAL WAIVER

18.1 TO THE FULLEST EXTENT PERMITTED BY CONNECTICUT LAW, EACH PARTY KNOWINGLY, VOLUNTARILY, AND IRREVOCABLY WAIVES ANY RIGHT TO TRIAL BY JURY IN ANY ACTION ARISING FROM THIS AGREEMENT.

18.2 Initials.

Party A: [____] Party B: [____]

19. MISCELLANEOUS PROVISIONS

19.1 Entire Agreement. Supersedes all prior negotiations and understandings.

19.2 Amendments. Written instrument signed by both Parties.

19.3 Severability. Invalid provisions modified to minimum extent necessary.

19.4 Waiver. Failure to enforce does not waive future enforcement.

19.5 Assignment. No assignment without consent, except to successors.

19.6 Notices. Written, deemed delivered upon personal delivery, overnight courier, three (3) business days after certified mail, or confirmed email.

19.7 Counterparts. May be executed in counterparts.

19.8 Electronic Signatures. Valid per Conn. Gen. Stat. § 1-266 et seq. and 15 U.S.C. § 7001 et seq.

19.9 Headings. Convenience only.

19.10 Construction. Construed as jointly drafted.

19.11 Third-Party Beneficiaries. Each set of Released Parties are intended beneficiaries.

19.12 Binding Effect. Binds Parties and heirs, executors, administrators, successors, and permitted assigns.

20. EXECUTION AND SIGNATURES

PARTY A:

Signature: [________________________________]

Printed Name: [________________________________]

Title (if applicable): [________________________________]

Date: [__/__/____]

PARTY B:

Signature: [________________________________]

Printed Name: [________________________________]

Title (if applicable): [________________________________]

Date: [__/__/____]

WAIVER OF UNKNOWN CLAIMS — SEPARATE ACKNOWLEDGMENT

We confirm that we have read, understand, and voluntarily agree to the waiver of unknown claims in Section 6.

Party A Signature: [________________________________] Date: [__/__/____]

Party A Initials: [____]

Party B Signature: [________________________________] Date: [__/__/____]

Party B Initials: [____]

JURY TRIAL WAIVER — SEPARATE ACKNOWLEDGMENT

Party A Initials: [____] Party B Initials: [____]

EXHIBIT A — SETTLEMENT PAYMENT DETAILS

SOURCES AND REFERENCES

• Conn. Gen. Stat. § 37-3a — Legal interest rate (10%)
• Conn. Gen. Stat. § 52-572f — Release of joint tortfeasors
• Conn. Gen. Stat. § 52-572g — Release — effect on contribution
• Conn. Gen. Stat. § 52-572h — Comparative fault
• Conn. Gen. Stat. § 52-195a — Accord and satisfaction by instrument
• Conn. Gen. Stat. § 1-266 et seq. — Uniform Electronic Transactions Act
• Conn. Gen. Stat. § 46a-58 et seq. — Fair Employment Practices Act
• Conn. Gen. Stat. § 31-71a et seq. — Wage payment statutes
• Conn. Gen. Stat. § 31-51kk et seq. — Family and Medical Leave Act
• Conn. Gen. Stat. § 42-110a et seq. — Unfair Trade Practices Act (CUTPA)
• Conn. Gen. Stat. § 42-110g — CUTPA remedies (treble damages, fees)
• Conn. Gen. Stat. § 31-51m — Whistleblower protection
• Conn. Gen. Stat. § 35-50 et seq. — Trade Secrets Act
• Conn. Gen. Stat. § 31-275 et seq. — Workers' compensation
• Conn. Gen. Stat. § 31-296 — Workers' compensation settlement approval
• Connecticut Practice Book § 17-44 — Withdrawal of actions
• Connecticut Practice Book § 17-45 — Judgment by stipulation
• Connecticut Code of Evidence § 4-8 — Compromise and offers
• Connecticut Constitution Art. I, § 19 — Jury trial right
• 15 U.S.C. § 7001 et seq. — E-SIGN Act