GENERAL RELEASE AND SETTLEMENT AGREEMENT

In consideration of Thirty-Two Thousand Five Hundred ($32,500.00) Dollars and other

considerations, I, ADAM MUELLER, (hereinafter plaintiff) hereby remise, release, and
forever discharge, TODD M. DODGE, CHAD SUMNER, WILLIAM GORDON, JESSE
SINCLAIR, STEVEN HICKEY, S. DANIEL McCARTHY, OTHER GREENFIELD
POLICE OFFICERS and the TOWN OF GREENFIELD, their current and former officers,
agents, directors, counsel, subsidiaries predecessors, successors, heirs, assigns and insurers, and
TRIDENT INSURANCE COMPANY, their officers, agents, directors, counsel, subsidiaries
predecessors, successors, heirs and assigns, (hereinafter the "Releasees"), from any and all debts,
demands, claims, actions, causes of action, suits, damages, costs, loss of service, expenses
(including attorneys' fees) and any other compensation of any kind whatsoever, both in law or in
equity, including, without limitation, personal injuries and property damage, loss of consortium,
(and all related claims) that they now had or ever had from the beginning of the world to this date
and more especially on account of the claims of/under 42 U.S.C. 1983, M.G.L. c. 12, 11I,
malicious prosecution, abuse of process, intentional infliction of emotional distress, First
Amendment to the United States Constitution, Fourth Amendment to the United States
Constitution, Sixth Amendment to the United States Constitution, Massachusetts Declaration of
Rights, for compensatory damages, punitive damages, for the costs of the action, for reasonable
attorneys fees and/or any other such relief as the Court may have deemed just, arising out of
events and circumstances involving the plaintiffs claims against the defendants as described in
the complaint entitled, Adam Mueller v. Todd M. Dodge, et al., U.S.D.C. CA No. 13-11566LTS, currently pending at the United States District Court for the District of Massachusetts.
THE CLAIMS RELEASED SPECIFICALLY INCLUDE ALL CLAIMS RESULTING
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FROM ANY INJURY OR LOSS, WHETHER KNOWN OR UNKNOWN AND

UNANTICIPATED, AND ALL CONSEQUENCES THEREOF, INCLUDING DEATH, AS
WELL AS ALL CLAIMS WHICH ARE ASSERTED OR WHICH COULD HAVE BEEN
ASSERTED IN LITIGATION FROM SAID CLAIMS.
The plaintiff hereby acknowledges that the Releasees have agreed to compromise this
claim to avoid the burden and expense of protracted litigation; therefore, neither the fact of
compromise nor any payment made pursuant to the GENERAL RELEASE shall be construed to
be an admission of liability by the Releasees.
The plaintiff hereby agrees to waive all attorneys fees and agrees to indemnify and hold
harmless the Releasees from any other claims, costs, charges, liens, expenses and attorneys' fees
arising from any one or more of the following and growing out of the events and circumstances
hereinbefore referred to above:
a.

Medical and/or hospital insurance benefits paid or hereinafter paid to or on

behalf of the Claimant and Medical and/or hospital services rendered to or
on behalf of the Claimant; Any Liens from any source;

b.

Any and all actions, causes of action, suits, claims, demands, proceedings,
that arise or may arise out of or in connection with said incident and events
which are the subject matter of Adam Mueller v. Todd M. Dodge, et al.,
U.S.D.C. CA No. 13-11566-LTS;

In consideration of the agreement made by Releasees in relation to this GENERAL

RELEASE, the plaintiff further agrees that all financial terms of the GENERAL RELEASE shall
be kept confidential (except for the fact of compromise) and such terms shall not be disclosed to
any person not a party to the compromise, nor shall such financial terms be disclosed by
plaintiffs representatives to any non-parties including, without limitation, disclosure to any
written publication.

The parties do not intend by any provision of this Agreement to create any rights in or
increase the rights of any third party beneficiaries, nor to confer any benefit upon or enforceable
rights under this Agreement or otherwise upon anyone other than Releasees and the Plaintiff.
Specifically, the parties acknowledge that nothing in this Agreement shall extend or increase the
rights of any third party claimants or the liability or obligations of Releasees
The plaintiff enters into this agreement with the understanding that this settlement is paid
to settle his personal injury claims, but that payment does not amount to, and is not to be
construed as, an admission by the defendants.
This Agreement constitutes the whole understandings, discussions, and agreements by and
between Defendants and Releasees. The terms and provisions of this Agreement are contractual
and not mere recitals. Releasees and Plaintiff acknowledge that there have been no oral, written,
or other agreements of any kind as a condition precedent to or to induce the execution and
delivery of this Agreement. Any written or oral discussions conducted prior to the effective date
of this Agreement shall not in any way vary or alter the terms of this Agreement.
This Agreement shall not be changed, amended, or altered in any way except in writing
and executed by both Releasees and Plaintiff.
This Agreement shall be governed by and controlled by the laws of the Commonwealth of
Massachusetts.
In the event that one or more provisions of this Agreement shall be declared to be invalid,
illegal, or unenforceable in any respect, unless such invalidity, illegality, or unenforceability shall
be tantamount to a failure of consideration, the validity, legality, and enforceability of the
remaining provisions contained in this Agreement shall not in any way be affected or impaired
thereby.