SETTLEMENT AGREEMENT AND UNILATERAL RELEASE (CONNECTICUT)

1. PARTIES AND BACKGROUND

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

• [RELEASOR LEGAL NAME] ("Releasor"), with its principal place of business at [address]; and
• [RELEASEE LEGAL NAME] ("Releasee"), with its principal place of business at [address]

Background. The Parties are involved in a dispute arising from [describe dispute]. Releasor agrees to release Releasee from certain claims in exchange for the consideration set forth herein.

2. SETTLEMENT PAYMENT AND TIMING

• Settlement Amount: [$AMOUNT] to be paid by Releasee to Releasor.
• 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. RELEASE OF CLAIMS BY RELEASOR

3.1 Release. Releasor hereby releases and forever discharges Releasee 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 Carve-Outs. The release does not extend to obligations of Releasee arising under this Agreement.

4. WAIVER OF UNKNOWN CLAIMS

4.1 Express Waiver. RELEASOR 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.

Releasor specifically waives any rights under any statute 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."

4.2 Initials. Releasor Initials: _______

5. NO RELEASE BY NON-RELEASING PARTY

Releasee does not release any claims against Releasor by entering into this Agreement.

6. NO ADMISSION OF LIABILITY

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

7. DISMISSAL OF ACTIONS

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

8. CONFIDENTIALITY AND NON-DISPARAGEMENT

8.1 Confidentiality. The terms of this Agreement shall be kept confidential.

8.2 Non-Disparagement. Releasor agrees not to make false or disparaging statements about Releasee.

9. TAXES AND ALLOCATION

• Tax Responsibility: Releasor is responsible for all tax obligations arising from the Settlement Amount.
• Indemnification: Releasor agrees to indemnify Releasee for any tax liability arising from the allocation.

10. REPRESENTATIONS AND AUTHORITY

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

11. REMEDIES

11.1 Injunctive Relief. The non-breaching Party shall be entitled to seek injunctive relief.

11.2 Breach of Release. If Releasor breaches the release, Releasor shall [return the Settlement Amount / indemnify Releasee].

11.3 Attorneys' Fees. The prevailing Party shall recover its reasonable attorneys' fees.

12. GOVERNING LAW AND DISPUTE RESOLUTION

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

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

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

Releasor Initials: _______ Releasee Initials: _______

13. MISCELLANEOUS

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

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

14. SIGNATURES

text
RELEASOR: RELEASEE:

__________________________ __________________________
Signature Signature

__________________________ __________________________
Printed Name Printed Name

__________________________ __________________________
Title (if applicable) Title (if applicable)

__________________________ __________________________
Date Date

WAIVER OF UNKNOWN CLAIMS INITIALS:

Releasor: _______

JURY WAIVER INITIALS:

Releasor: _______ Releasee: _______