Free Stipulation of Dismissal - District Court of Connecticut - Connecticut


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Date: January 11, 2005
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State: Connecticut
Category: District Court of Connecticut
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Case 3:02-cv-01663-RNC Document 80-2 Filed O1/12/2005 Pagei of4
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UNITED STATES DISTRICT COURT » »
DISTRICT OF CONNECTICUT
V LETROY HUNDLEY : PRISONER.
i : NO. 3:02CVl663(RNC)(DFM)
VS. :
OFFICER PAMELA CHRISTIE JANUARY L, 2005
SETTLEMENT AGREEMENT
WHEREAS, the above-captioned matter was brought by Letroy D. Hundley, as the
plaintiff, against the following persons: Captain L. Commono, Brian Murphy, and Officer
l Pamela Christie; and had already been dismissed as to all but Officer Christie; p
WHEREAS, the parties agree that settlement of all the issues raised by the above-
A captioned matter would best serve the interests of the parties:
U NOW THEREFORE, without further proceedings or adjudication of any issues of fact or
A . law raised by the disputed claim(s) herein, and for and in consideration of the promises,
T agreements, covenants and conditions herein contained, the adequacy and sufficiency of which
A are hereby acknowledged by each of the parties hereto, the parties stipulate and agree as follows:
p l. The Agreement constitutes as compromise and complete settlement of the .
following listed action:
I Letray D. Handley v. Captain Commono, Brian Murphy, Pamela Christie,
. 3:02CV1663(DFM)
· (the above-captioned matter)
_ and any other actions currently pending against the State of Connecticut, it agencies, agents,
and/ or current or former employee.

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Nothing contained herein, nor any actions taken by any party in connection herewith,
shall constitute, be construed as, or be deemed to be, an admission of fault, liability, or wrong-
doing, and is merely to avoid further litigation with the parties to this action.
2. The plaintiff shall immediately, and with prejudice and without any award of
costs or Attorneys fees, stipulate to dismiss this action, and shall execute the Release of Liability
which is attached hereto as Exhibit A. h
3. Upon the stipulated dismissal of this action and execution by the plaintiff of the
signed Release of Liability, the State of Connecticut shall, as soon as possible, pay to the
plaintiff the sum of $550.00 and the current Warden of the MacDougall—Walker Correctional
Institution shall review the separation order procedure at that facility for appropriate revision, if
any is said to exist, in full discharge, satisfaction and release of all the claims asserted in
connection with this action.
4. The parties expressly acknowledge that this settlement is intended to, and shall,
f constitute full and final settlement of all claims and/or rights of action which have arisen, or may
in the future arise, out of any of the circumstances which are the subject of this lawsuit, or in any
way connected to this lawsuit. In furtherance thereof, the undersigned plaintiff does now and i
forever release the defendant to this action and the former defendants to this action and any
present or former officers, agents, and employees of the State of Connecticut Department of
l Correction and the State of Connecticut itself form any and all further liability whatsoever in
· connection with the circumstances surrounding the above-captioned matter and other matters, if
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Case 3:02-cv-01663-RNC Document 80-2 Filed O1/12/2005 Page 3 of 4 .
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any, in accordance with the duly executed Release of Liability which is attached hereto as
Exhibit A. l ”
5. The parties further agree that the settlement terms and conditions described herein
represent the entire agreement of the parties concerning the settlement of this lawsuit, and the
‘ respective parties will each bear their own costs, fees, and expenses.
1 6. This Settlement Agreement may be executed in counterpart. A copy of facsimile
copy shall be valid as the original.
THE PLAINTIFF:
i Letroy D. Hun ley _
Date: é 40·0j
i WITNESS: I i
g Name: jggg ga:/1 EIQLQQKH
- Date: |"iO’2gD5
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Case 3:02-cv-01663-RNC Document 80-2 Filed 01/12/2005 Page 4 of 4 L
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DEFENDANT,
y Pamela Christie
RICHARD BLUMENTHAL
ATTORNEY GENERAL
E BY: it \ (Z
E L . `ttenbrink
Assistant Attorney General
A 110 Sherman Street
Hartford, CT 06105
Tel: (860) 808-5450 I
V Federal Bar No.: ct 08575
lynn.wittenbrink@,po.state.ct.us _
e
CERTIFICATION
I hereby certify that a copy of the foregoing was mailed to the following on this 1 /
day of January, 2005 to: V
Letroy D. Hundley, Inmate No. 274106 ·
Corrigan-Radgowski Correctional Center
Q 986 Norwich-New London Turnpike
Uncasvil1e,,CT 06382
to L n D ittenbrink
, Assistant Attorney General
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