20230807_settlement_agreement

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SETTLEMENT AGREEMENT AND GENERAL RELEASE OF ALL CLAIMS
This Settlement Agreement and General Release Of All Claims (hereinafter referred
to as the “Agreement”) is effective as of the last signature appearing below (“Effective Date”)
and is by and between Richard Partridge, on behalf of and in his capacity as legal guardian for
Ryan Partridge (hereinafter collectively referred to as “Plaintiff”), and Sheriff Joe Pelle in official
capacity as Boulder County Sheriff 1 (hereinafter referred to as “Defendant”). Plaintiff and
Defendant may be referred to hereinafter collectively as the “Parties”.
Erik Contreras, Christopher Mecca, Debbie Stevens, Bruce Haas, Christian Berringer,
Dale Greene, Shane McGurk, Pamela Levett, Jeff Goetz, T. Smith, Karemn Koger, Thomas
Groff, Eric Contreras, Robert Hicks, Dan Newcomb, Chuck Sisneros, Gregory Clem, Vili
Maumau, and Anthony Hollonds, are or were named as individual capacity parties in the Lawsuit
(defined below) employed by the Boulder County Sheriff and may be referred to collectively
hereinafter as “the Individual Employees.” Amanda Taylor (“Taylor”) and Mergen Mittleider
(“Mittleider”), who are named parties in the Lawsuit, and their then employer, Mental Health
Center of Boulder County, Inc., may hereinafter be referred to collectively as the “Mental Health
Professionals”.
Plaintiff filed a lawsuit in the United States District Court for the District of Colorado,
Civil Action No.: Case No. 1:17-cv-02941 (hereinafter “Lawsuit”), wherein Plaintiff asserts
claims against Defendant, the Individual Employees, and the Mental Health Professionals
alleging, inter alia: 1) Contreras, Mecca, Stevens, McGurk, Levett, Pelle, Goetz, and Taylor
acted with deliberate indifference to Plaintiff’s constitutional right not to be denied necessary
medical care because they knew or should have known of Plaintiff’s medical condition, but failed
to examine, treat, and care for Plaintiff’s condition and failed to send him for treatment,
1 Joe Pelle was the Boulder County Sheriff at the time of filing, but the Boulder County Sheriff is now Curtis Johnson

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