Free Stipulation of Dismissal - District Court of Connecticut - Connecticut

Case 3:00-cv-00261-TPS

Document 116-3

Filed 06/02/2006

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT MICHAEL BRAHAM v. JOHN ARMSTRONG, ET AL. : : : MAY 24, 2006 CIVIL NO. 3:00cv261 (TPS)

RELEASE OF LIABILITY KNOW ALL MEN BY THESE PRESENTS, that the plaintiff, MICHAEL BRAHAM, on behalf of himself, his heirs, successors and assigns, for and in consideration of the payment of the sum of Twenty Thousand dollars ($20,000.00), and other valuable considerations, the receipt of which is hereby acknowledged, does herewith release and forever discharge the defendants, Commissioner Theresa Lantz, former Commissioner John Armstrong, Correctional Officer Matthew Clancy, Captain Stephen Bates, Correctional Officer Kevin Brostek, Lieutenant Mark Bellaro, Lieutenant Benjamin Barbour, the Department of Correction, and all other present or former officers, agents and employees of the State of Connecticut, their heirs, successors and assigns, and the State of Connecticut itself, from all actions, causes of action, suits, claims, controversies, damages and demands of every nature and kind, including attorney's fees and costs, which MICHAEL BRAHAM, his heirs, successors and assigns ever had, now have or hereafter can, shall or may, have for, upon, or by reason of any matter, cause or thing whatsoever from the beginning of the world to the date of this Release of Liability arising out of or, in any way, related to the incident(s) or circumstance(s) which formed the basis for the above-captioned lawsuit, including such actions as have been or may, in the future, be brought in the federal courts, the courts of the State of Connecticut, or before the Claims Commissioner

Case 3:00-cv-00261-TPS

Document 116-3

Filed 06/02/2006

Page 2 of 2

pursuant to Conn. Gen. Stat. §§ 4-141, et. seq. Said Release of Liability includes all causes of action alleging violations of the plaintiff's constitutional rights, his rights arising under the statutes and laws of the United States and/or the State of Connecticut, and such causes of action as may be available under the common law as they relate to or involve the incident of October 4, 1999, in which plaintiff suffered physical injuries following an incident with another inmate that serves as the basis of this action. It is expressly understood and agreed that the payment of the aforementioned sum is not an admission of liability on the part of the defendants, or any other present or former officer, agent or employee of the State of Connecticut, or the State of Connecticut itself in said action, but rather constitutes the compromise settlement of the claims made in the action set forth above. IN WITNESS WHEREOF, the plaintiff, MICHAEL BRAHAM, does herewith set his free hand and seal this ____ day of ______________ 2006.

_________________/s/_______________________ Michael Braham

JURAT STATE OF CONNECTICUT COUNTY OF ) )s.s )

Personally appeared, Michael Braham, signer of the foregoing instrument, and acknowledge the same to be his free act and deed, before me, this _____ day of __________ 2006. _______________/s/__________________________ Notary Public / Commissioner of the Superior Court 2