Settlement Agreement and Release
NOW COMES the Human Rights Defense Center ("HRDC") and enters this Settlement
Agreement and Release ("Agreement") with Centurion of Vermont, LLC ("Centurion")
(collectively "Parties") as set forth below:
WHEREAS, Plaintiff filed a lawsuit in the Washington Superior Court, Civil Division on or
about December 15, 202 I, captioned Human Rights Defense Center, Plaintiff. vs. Centurion of
Vermont, Defendant, which was assigned docket number 21-cv-03976 [hereinafter "The
Lawsuit"] in which HRDC alleged that Centurion failed to provide it copies of documents that
the HRDC requested; and
WHEREAS, the Court entered judgment in Plaintifrs favor pursuant to Vt. R. Civ. P. 54 and 58
on August 13, 2024, and ordered the parties to meet and confer regarding payment of attorney fees
and costs; and
WHEREAS, Plaintiff filed a petition seeking an award of attorney fees and costs under
the Vermont Public Records Act; and
WHEREAS, the Parties desire to enter into a settlement and compromise of Plaintiffs claim
for attorney fees and costs in The Lawsuit; and
WHEREAS, this Agreement is entered into for the mutual convenience of the Parties
in recognition of the costs, risks and uncertain results associated with litigation or further appellate
review of Plaintiffs pending petition for attorney fees and costs; and
WHEREAS, HRDC affirms that this Agreement is supported by good and binding
consideration as set forth herein:
NOW THEREFORE, HRDC agrees as follows:
1. Concurrent with the execution of this Agreement, HRDC will execute a Release, which
is attached and fully incorporated herein.
2. Centurion shall provide HRDC with a payment in the gross amount of $61,750.00 (sixty-one
thousand seven hundred and fifty dollars) made payable to the Human Rights Defense Center-hereafter, the "Settlement Payment"-in complete and total compensation for any and all
attorneys' fees and expenses owed under the Vermont Public Records Act and in this Lawsuit, with
payment to be made within 30 days of the execution of this settlement agreement and HRDC's Release.
3. Centurion shall produce copies of the documents the Court reviewed in camera during the
pendency of this matter. Centurion, as a result of this Lawsuit and in accordance with the
negotiated terms included in the documents being produced, confirmed the other parties in
those actions agreed to waive the negotiated for confidentiality provisions.

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4. Within ten (I 0) days after HRDC's receipt of the payment of the attorneys' fees and costs
described in paragraph 2 and the production of documents described in paragraph 3, HRDC will
dismiss The Lawsuit with prejudice.
5. This Agreement, as a whole, sets forth all the terms of the Parties' understanding and there are
no other promises or obligations other than what is specifically stated herein. All prior agreements,
representations, statements and understandings regarding this matter shall have no effect.
6. HRDC acknowledges and agrees that it is not entitled to, nor shall it receive, any other form
of benefit, compensation, or relief other than that which is expressly stated herein.
7. This Agreement resolves all legal issues and disputes in this Lawsuit.
8. This Agreement resolves this Lawsuit only. It is not admissible evidence, and shall
not be introduced or referenced in, any other litigation by any of the parties hereto.
9. The HRDC certifies it understands all the terms contained in this Agreement, that its decision
to sign this Agreement is voluntary, and that it has been made knowingly, without coercion or
undue influence, and agrees to the terms after having had the opportunity to consult with its
representative and/or legal counsel and having had the terms explained to it by its representative
and/or legal counsel to the extent necessary.
10. This Agreement may not be amended or modified except by written instrument executed
by all of the Parties.
11. This Agreement is fully enforceable with signature provided by facsimile transmission,
or transmission by electronic mail.

Signatures

Date:

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RELEASE
THE HUMAN RIGHTS DEFENSE CENTER ("Releasor") for and in consideration
of the documents produced and that payment of$61,750.00 (Sixty-One Thousand Seven
Hundred Fifty Dollars and Zero Cents), lawful money of the United States, paid by
CENTURION OF VERMONT, LLC ("Centurion" or "Releasee" and, collectively "the Parties")
for Releasor's attorney fees and expenses, the receipt and sufficiency of which is hereby
acknowledged, and in consideration of agreement by Releasee to comply with the terms of the
Agreement executed by the Parties, does hereby remise, release and forever discharge, and by
these presents do for itself, executors, administrators, successors and assigns remise, release and
forever discharge Releasee and its current and former employees, officers, directors, agents,
contractors, adjusters, attorneys, representatives, members, heirs, executors, administrators,
parent companies, co-subsidiaries, subsidiary companies, affiliated companies, successors,
insurers and assigns, and each and every entity named in The Lawsuit described in this
paragraph, of and from any remaining demands for payment or records in the lawsuit in the
Washington Superior Court, Civil Division Human Rights Defense Center, Plaintiff, vs.
Centurion of Vermont, Defendant, which was assigned docket number 2 l-cv-03976 [hereinafter
"The Lawsuit"].
Releasor agrees that there are no collateral or outside agreements of any kind between
the Parties, other than the Settlement Agreement referenced herein and executed
contemporaneously herewith. It is also understood and agreed that this settlement is the
compromise, accord, and satisfaction of disputed claims, and that this Release and any
consideration therefore is not to be construed as an admission of liability on the part of the
parties released, by whom liability is expressly denied. It is further agreed and understood that
this compromise settlement is made to terminate further controversy with respect to all claims
that Releasor has asserted or might assert in the future.
Releasor acknowledges that it has had ample time to consult with its attorney(s) and others
prior to signing this release, is competent to sign this release, and does so voluntarily and
without duress.
Releasor affirms that it has the power under the Laws of the State of Vermont to enter into
this Agreement.

Signatures

t---,

ForHRDC:

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Date

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