GENERAL RELEASE AND SETTLEMENT AGREEMENT

It is hereby agreed by and between the Ansonia Board of Education (rereinafter

"Board"), Dr. Carol Merlone, the Board's Superintendent of Schools (hereinafter
('Superintendent") the Ansonia Administrators Association (hereinafber "AAA") and
Terui Goldson (rereinafter "Mr. Goldson") (collectively referred to as "the Parties") that;
WHEREAS, the Board employs Mr. Goldson in the position of high schooi
principal, a position covered by a collective bargaining agreement (*CBA') between the
Board and the AAA; and
WHEBEAS, the Parties have reached an agreement concerning Mr. Goldson's
separation from his employment with the Board; and
WHEREAS, the purpose of this General Release and Settlement Agreement
(hereinafter'Agreement") is to resolve all differences that may now exist, or may arise in the
future between the Parties under state, federal or contract law regarding Mr. Goldson's
employment with the Board or his separation there&om, and to avoid any unnecessary
expenditure of time and expense to all Parties regarding such matters; and
WHEREAS, the Parties agree that the following terms of agreement are in their
mutuaL best interest; and
WHEREAS, the Parties are desirous of reso-lving this matter without pursuing any
judicial, quasi-judicial, administrative, or arbitral proceeding or any other adversarial
proceedirrg
NOW TIIEREFORE, in consideration of all the terms, conditions and undertakings
by or relating to the AAA and Mr. Goldson in this Agreement and in consideration of the
payment by the Board as hereinafter provided, and the promises contained herein, the
Parties agree as follows:
1. Simultaneous with the execution of this Agreement, Mr. Goldson will submit to the
Board an irevocable letter of resignation effective February L, 20L8, and shall retire.
The Board's and Mr. Goldson's signatures hereto signifu Mr. Goldson's offer to
resign for the purpose of retiring effective February L2, 2018 and the Board's
acceptance of such offer. Mr. Goldson further agrees not to seek or accipt
reemployment with the Board at any time after February 12,2018;
2. The Board shall:
a. provide to Mr. Goldson (i) the sum of sixty thousand dollars ($60,000),
which represents payment of the balance of his current salary through
June 30, 2018 (five (5) months) for waivers as otherwise designated within
this Agreement and (ii) severance pay to which Mr. Goldson would be
entitled pursuant to Articie XI of the CBA upon retirement in the amount
of fifteen thousand dollars ($15,000), in form and fashion as foilows:
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Goldson Separation Agreement
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as much of the total of subparagraphs (i) and (ii) hereinabove as would be

lawfully permissible shall be contributed to Mr. Goldson's Section a03&)
account and the balance thereof paid to Mr. Goldson as regular salary, in
one lump sum, less any statutory payroll deductions such as state or
' federal income tax, within fifteen (15) days of the Board's notifieation of
the balance amount;

b. make no claims, nor provide any opinions regarding, the taxable effects of
these payment to, or on behaif of, Mr. Goldson;

c. continue to pay the Board's contribution, as specified in the CBA, for Mr.
Goldson's health insurance coverage in effect as of January 1, 2018, through
and including June 30, 2018, so long as Mr. Goldson pays to the Board five (5)
days prior to the lst of each month, commencing March l, 2OL8, his
contribution, as provided for in the CBA; and

d. agree that any inquiries received by its agents, officers and employees from
prospective employers or third parties regarding Mr. Goldson's employment
will be referred to the Superintendent who shall confirm Mr. Goldson's dates
of employment and the position in which he was employed by the Board and
that he has resigned/retired in good standing; further provide Mr. Goidson, a
Ietter of recommendation from the Superintendent, which is incorporated by
reference and attaehed hereto as if fully set forth herein, and will not disclose
additional information to prospective employers or third parties exeept upon
the expressed written authorization by Mr. Goldson. Neither Mr. Goldson
nor the Superintendent, or any member of the Administration, shall
disparage the other.
o. Mr. Goldson, for himse$ his heirs, executors, administrators and assigns, effective
with his execution of this Agreement, releases the AAA, its members, agents,
offi.cers, legal representatives, and employees from any and all claims he ma5, have
had, now has or may have against it under law, equity or contract, with regard to or
arising out of his employment with the Board or representation by the AAA and/or
the circumstanees surrounding this Agreement, including the duty of fair
representation.
4. This Agreement constitutes the eomplete understanding between the Parties
and shall have no precedential value in any other matter between the Parties,
including the interpretation of any provision of the CBA between the Board and
the AAA. No other promises or agreements shall be binding or of any effect unless
signed by the Parties. Other than the items provided for in Paragraphs 1 and 2 above,

and any other express promises contained in this Agreement, the Board sha-ll have no
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financial or other obligations to Mr. Goldson resulting from his employment and
separation of employment with the Board.
5. Neither the negotiation, undertaking nor signing of this Agreement, or the making
of any payments thereulder, constitutes or operates as an acknowledg:nent or
admission by the Board that either the Board, its present or former of6cers, direetors,
members, agents, or employees or any person acting on behalf of the Board have
violated or failed to comply, in either their official or individual capacities, with
any provision of federal or state constitutions or statutes, including but not limited
to, the Connecticut Fair Employment Practice Act, C.G.S. $46a-51 et seq., and
regulations issued thereunder; $$31-51m or 31-51q of the Connecticut General
Statutes; Title VII of the Civil Eights Act of 1964, as amended, 42 U.S.C. $2000e ef
seq., and regulations issued thereunder; the Civil Rights Act of L866,42 U.S.C. $1981;
the Equal Pay Act of 1963, 29 U.S.C. $206(d); the Age Discrimination in
Employment Act of 1967, as amended by the Older Workers Benefit Protection
Act, 29 U.S.C. $621 et seq.; the Americans with Disabilities Act, 42 U.S.C. $ 12101
et seq., and regulations issued thereundeq 42 U.S.C. Section 51983; the Municipal
Employees Relations Act, C-G.S- 57467 et seq., the Teachers' Tenure Act C.G.S. $10-
151, the Teachers' Negotiations Act 510-153 et seq., or with any and all principles of
common law, whether in contract, express or implied, oral or written, or in tort,
including, but not limited to, breach of contract, breach of an implied covenant of
good faith and fair dealing, the tortious or negligent violation or breach ofcontractual
duties, the tortious or wrongf.rl discharge from employment, misrepresentation,
defamation or the infliction of emotional distress. Nothing herein shall be considered
a waiver of any right Mr. Goldson may have under the Connecticut Teachers'
Retirement Act, Conneeticut Workers' Compensation Act, or Section 10-235 of the
Connecticut General Statutes.
6. Mr. Goldson and the AAA agree that by this Agreement they waive, release, promise,
and agree not to file, bring or pursue any judicial, quasi-judicial, administrative or
arbitral complaint, charge, claim or action brought in their name or on their behalf
against the Board, its present or former officers, directors, members, agents, or
employees or any person formerly or presently acting on behalf of the Board, in
either their official or individual capacities; and, waive and release their right to
recover any and all relief in any judicial, quasi-judicial, administrative or arbitration
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proceeding, suit or action frled or brought in their name or on their behalf against
the Board, its present or former offrcers, directors, members, agents, or employees or
any person formerly or presently acting on behalf of the Board, in either their official
or individual capacities, arising out of Mr. Goldson's employment with and

separation from employment with the Board for any reason, up to and including the
date of execution of this Agreement. Notwithstanding the foregoing, nothing herein
shall preclude Mr. Goldson from pursuing an action to enforce this Agreement.
7. The Board agrees that by this Agreement it waives, releases, promises and agrees not to
fiIe, bring or pursue any judicial, quasi-judicial, administrative or arbitral complaint,
charge, claim or action and waives and releases its right to recover any and all relief in
any judicial, quasi-judicial, administrative or arbitration proeeeding, suit or action
filed or brought in its name or on its behalf against Mr. Goldson and/or the AAA arising
solely out of Mr. Goldsons employment with and separation from employment with
the Board. Notwithstanding the foregoing, nothing herein shall preclude the Board
&om pursuing an action to enforce this Agreement.
8. Mr. Goldson and the AAA frrrther agree that by this Agreement, they do, for themselves
and anyone elaiming for or through them, release and forever discharge the Board,
its present or former officers, directors, members, agents, or employees or any person
formerly or presently aeting on behalf of them, of and from any and all liability from
any claims, in either their official or individual capacities, under federal and
state constitutions and laws, including, but not limited to, those statutes and
principles of common law set forth in paragraph 5 above, arising out of Mr. Goldson's
employment with and separation from employment with the Board.
9. Mr. Goldson and the AAA agree to withdraw and obtain dismissal, with prejudice,
of all charges filed., if any there be, with any state or federal court and any state,
federa-lor other governmental or administrative agency, which relate in any way to Mr.
Goldson employment with and separation from employment with the Board.
10. Mr. Goldson,the AAA, the Board, the Superintendent and the Board's
administration further agree that they will not make any statement or
representation, oral or written, that could adverseiy affect the reputation, image,
goodwill, or interest of the Parties, their members, successors and assigns, or anyone
formerly or presently employed by or formerly or presently acting on behalf of the
Parties, its members, successors or assigns as it concerns this Agreement or the
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employment and/or separation of employment of Mr. Goldson with the Board,

including negative responses to employment reference requests.

11. Mr. Goldson and the AAA accept the benefits set forth above as full and final

satisfaction for any past or present claim to damages or for back pay or any
compensatory or other reiie{ including attorney's fees, available und"er federal and state
constitutions and laws, or contract, including, but not limited to, those statutes
and principles of common law and contract set forth in paragraph 5 above, except that
there shall be no waiver of claims or rights that may arise after the date of signing
of this Agreement.
12- The Parties agree that these items constitute full, fair and adequate consideration
for the affirmations and promises made by Mr. Goldson, the AAA and the Board in
this Agreement.
13. The Parties agaee, to the extent possible under the law, not to make public or to
disclose to anyone in any manner the terms of this Agreement'
L4. Mr. Goldson and the AAA represent that they have had an adequate opportunity to
discuss all aspects of this Agreement with counsel of their own choosing and were, in
fact, advised in writing to do so by the Board prior to their signing of this
Agreement. Mr. Goldson and the AAA further represent that they in fact consulted
with their attorney(s) andlor other consultants of their choice prior to executing this
Agreement.
15. Mr. Goldson and the AAA represent that prior to their signing this Agreement they
had received all notices and waiting periods for consideration of this Agreement, and
specifi.cally the notices and waiting periods required for the waiver of all claims
under the Age Discrimination and Employment Act of 1967, as amended under the
Older Workers Benefrt Protection Act, 29 U.S.C. $62L et seq. Further, the Board, the
AAA and Mr. Goldson ag"ee that any Parby has seven (7) days from the signing of this
Agreement to rescind its agreement thereto and may do so by providing writben notice to
the other Parties to be received within the seven (7) day period.
16. Mr. Goldson and the AAA represent that they understand all the provisions of this
Agreement and are voluntarily entering the same.
17. Mr. Goldson, the Board and the AAA expressly acknowledge that this Agreement is
intended in its effect and does include, without limitation, all claims which they do not
know or suspect to exist in their favor at the time of the execution of this release, and that
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the agreed upon terms sonfgmFlate and eltinguish all such claims to the extent they deal
rpith 1\[r. Goldson s employment or separation of employment with the Board, except any
claim that a Party has violated. or breached this Ageement or any provision hereof.
18. If any term or provision of this Agreement is held invalid or unenforceable by any
court of competent jurisdiction, such holding shall apply only to the speeific term or
provision found invalid or unenforceable and shall not render invalid or
unenforceable any other term or provision in this Agreement'

IN WITNESS WHEREOF, the Parties have hereunto set their hands.

ANSONIA ADMINISTRATORS ANSONIA BOARD OF EDUCATION

ASSOCIATION

Board vote of.21812078

and sworn to before me Subscribed and sworn to before me

.")$15 ofFebruary 2078. this i5 day ofFebruary 2018.

TERRI GOLDSON