Free Motion to Dismiss - District Court of Connecticut - Connecticut

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F Case 3:03-cv-00069-CFD Document 38-2 Filed 1 1/29/2004 Page 1 of 2 ,
UNITED STATES DISTRICT COIEJRT ‘D · Q 2 I
DISTRICT OF CONNECTICUT
_ KEITH JOHNSON, · : NO. 3:03CV-0069 (CFD)(WIG)
plaintgjf :
JAMES KEENEY,
defendant. : NOVEMBER 15, 2004 ‘

RELEASE OF LIABILITY i
KNOW ALL MEN BY THESE PRESENTS that the plaintiff, Keith Johnson, on behalf I
of himself his heirs, successors and assigns, for and in consideration of the payment of the sum
of one thousand dollars ($1,000.00) and other valuable considerations, the receipt of which is
hereby acknowledged, does herewith release and forever discharge James Keeney, John
O’Connor and Daniel McCarthy, 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 attomey’s fees and costs, which Keith Johnson, 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 circumstances .
which fonned 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 i
before the Claims Commissioner pursuant to Conn. Gen. Stat. § 4-141 et seq. Said release of
liability includes, but is not limited to, all causes of action alleging violations of the plaintiffs
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N " Case 3:03-cv-00069-CFD Document 38-2 Filed 11/29/2004 Page 2 of 2
constitutional rights, his rights arising under the statutes and laws of the United States and/or the `
i State of Connecticut, and such causes of action as may be available under the common law. This i
release of liability shall be applicable also to the pending action entitled Keith Johnson v. Daniel
McCarthy, Docket No. CVO4-40008078, and as to the State Police defendant, John O’Connor, to ·
the pending action entitled Keith Johnson v. John O ’Connor·, et al., Docket No. CV03— _ i
08265678, both cases pending before the Connecticut Superior Court. I
It is expressly understood and agreed that the payment of the aforesaid 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(s), but I
rather constitutes the compromise settlement of the claims made in the action set forth above. F
IN WITNESS WHEREOF, the plaintiff, Keith Johnson, does herewith set his hand and - R
seal this ZL day of Qoveiuber , Zoej . ` . j
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i `gw `° _ [1......-.. I
eith Johnson i ' R
STATE OF CONNECTICUT ) l E
) JURAT ‘
COUNTY OF £Aq,,; Q )
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Personally appeared, Keith Johnson, signer ofthe foregoing instrument, and acknowledged the
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same to be his free act and deed, before me this Qgn day of Mgx/gm in Er , - .
= _ »~—a·£-.,;
Notary Fu lic! _, ` '

W RENE E HASKINS
2 NOTARY PUBLIC
- MY COMMiSS¤tT=t·i: ¥*iF~?.E$? t2/31/2005 ‘ ;
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