SETTLEMENT AGREEMENT
This Agreement is entered inte this day efSeptember, 2018 by and between 
Hausman ("Helusman") and the Vermont l-lernp Company LLC and Joel Bedard (together



 

WHEREAS the parties to this Agreement (the "Parties") are parties in an action entitled
Hammart vs Very/tort! Hemp Company, LLC and Joel sedan/t currently pending in the
Superior Court, Civil Division, Addison Unit. Docket No -18 Ach (the "Lillgalion'fie

WHEREAS the parties Io this Agreement are desirous et'reselving the claims asserted in
the Litigation and all other claims that could have been asserted in the Litigation,

NOW THEREFORE, in consideration oftlte mutual promises and undertakings herein,
Haueman and VTHC Covenant and agree as follows:

1. Grain Tran, er: Within seven (7) business days from the cxccutlott oflhis
Agreement, VTHC shall deliver to llausman at. --l3m-liitgton, VT the
grain from the hemp that was harvested from Hausman's property in 2017. le-lc
represents that the grain was stored in a commercially reasonable manner and that it has
been cleaned and compartmentalized for storage VTIIC estimates that the stored gram
weighs 1200-1400 lbs, and this rcpresenls the entirety ofwhal VTHC's harveslcd from
Hausman's property, The grain shall be delivered by VTIIC and accepted by Hausntan
in as is condition. The harvested grain is a protected variety material
that cannot be used for planting. In the event that Hausman plants the grain nfier
receiving the delivery from VTl-lc, she assumes all respensilnliry for such planting and

will indemnify and hold harmless from any action as a result oflhc planting.

Release: Upon execution of this Agreement, VTHC and Hausman will sign a general

release in the form annexed hereto as Exhibit A.

No Admission of Liability: The Parties agree that by entering into this Agreement

 

neither party admits fault or liability on their part and that the actions set forth in this
Agreement are an accord and satisfaction of a disputed claim. By af?xing each of their
signatures hereto, the Parties, do represent, acknowledge, and state that the consideration

recited herein is fair and reasonable under all circumstances involved.

Non Disnaragement: In consideration of the aforesaid grain transfer and the dismissal of

 

the counterclaims in the Litigation, each of the parties agree not to make any disparaging
statements (oral or written) concerning the other party, or any of the other party?s
predecessors, successors, or current or former agents or employees or to take any action
which is intended to, or could reasonably be expected to, injure the business, prospects,
or reputation of the other party, or its predecessors, successors, or current or former

agents or employees.

Stipulation of Dismissal: Upon execution of this Agreement, the Parties shall execute a

 

Stipulation of Dismissal with Prejudice of the Litigation in the form attached hereto as

Exhibit and VTHC shall cause that stipulation to be ?led forthwith with the Court.

Entire Agreement; Amendment. This Agreement and its Exhibits embodies the entire

 

agreement and understanding of the Parties relating to the subject matter hereof, and there
are no covenants, promises, agreements, conditions or understandings, oral or written,

except as herein set forth. This Agreement may not be amended, waived or discharged

except by an instrument in writing executed by the party against whom such amendment,

waiver or discharge is to be enforced.

Knowing and Voluntary: The Parties warrant that they have or have had the opportunity

 

to consult with counsel and that they fully understand, comprehend, and agree to the
terms, conditions, and meaning of this Agreement, that their respective counsel have
explained this Agreement to them, and that they enter into this Agreement knowingly and

voluntarily.

Warranty of Capacity to Execute Agreement: The Parties represent and warrant that no
other person or entity has, or has had, any interest in the claims, demands, obligations, or
causes of action referred to in this Agreement, except as otherwise set forth herein; that
the Parties have the sole right and exclusive authority to execute this Agreement and
receive or direct the apportionment of the sums speci?ed in it; and that Hausman has not
sold, assigned, transferred, conveyed or otherwise disposed of any of the claims,

demands, obligations, or causes of actions referred to in this Agreement.

Interpretation and Construction. The Parties have fully and equally participated in the
preparation, negotiation, review and approval of this Agreement. Should any provision
of this Agreement require interpretation or construction, this Agreement shall be
interpreted and construed without any presumption that the provisions of this Agreement
are to be construed against the party who personally or through agents or attorneys

drafted this Agreement.

10.

ll.

12.

l3.

l4.

Attorneys? Fees: Each party hereto shall bear all of its own attorneys' fees, costs, and
expenses (if applicable) arising from the negotiation and preparation of this Agreement

and all other related matters.

Change in Facts: The Parties and each of them acknowledge that the facts in respect of
which this Agreement is made may prove to be other than or different from the facts now
known or believed by the Parties or any of them to be true, and the Parties and each of
them accept and assume the risk of the facts being different and covenant and agree that
this Agreement will be in all respects enforceable and not subject to termination,

rescission, or variation by discovery of any difference in facts.

Non Waiver: The failure of any signatory to enforce, at any time, any of the provisions
of this Agreement or the failure of any signatory to enforce, at any time, performance by
the other signatory of any of the provisions herein, shall not be construed as a waiver of
such provisions nor in any way affect the validity of this Agreement or the right of a

claimant to thereafter enforce each and every provision.

Governing Law. This Agreement shall be interpreted and governed in accordance with
the laws of the State of Vermont, without giving effect to the principles of con?ict of

laws of that or any other jurisdiction.

Countemarts: Each signatory agrees that the faxed delivery of a counterpart signature
page to other signatories or their representatives shall constitute such signatory?s

execution and delivery thereof.

Dated:

 

 

Hausman

   

 

fie KW 

Dated;

 

 

ff

 

 

 

Vermont Hemp Company, LLC
By its duly authorized agent

EXHIBIT A
GENERAL RELEASE,

For valid consideration, the receipt of which is hereby acknowledged, Hausman
and her heirs, administrators, executors, employees, agents, successors and assigns (hereinafter
collectively referred to as ?Releasors? hereby remise, release and forever discharge, Vermont
Hemp Company, LLC and Joel Bedard and their directors, of?cers, principals, employees,
shareholders, trustees, administrators, parent companies, subsidiary companies, affiliated
companies and all of their respective past, present and future of?cers, directors, managers,
shareholders, employees, insurers, attorneys, contractors, representatives, masters, principals,
agents, servants, predecessors, successors, assigns and anyone acting or purporting to act on its
behalf (hereinafter collectively referred to as ?Releasees?), from any claims, actions, lawsuits
and demands whatsoever, known and unknown, foreseen, unforeseen or unforeseeable, that
Releasors ever had, now have or hereafter can, shall or may have against Releasees for, upon, or
by reason of any matter, cause or thing whatsoever, from the beginning of the world to the date
of this General Release including but not limited to any and all claims that were raised or that
could have been raised in the action entitled Housman 12. Vermont Hemp Company, LLC
and Joel Bedard, Vermont Superior Court, Civil Division, Addison Unit, Docket No. 16-1-18

Ancv (the ??Litigation?).

[signatures on following page]

Dated:

 

 

Hausman

STATE OF VERMONT
COUNTY, SS.

 

At Vermont, this day of 2018 personally
appeared Hausman and she acknowledged the foregoing instrument by her sealed and
subscribed to be her free act and deed.

 

Notary Public
Commission Expires: 02?10?19

 

EXHIBIT A
GENERAL RELEASE,

For valid consideration, the receipt of which is hereby acknowledged, Vermont Hemp
Company, LLC and Joel Bedard and their directors, officers, principals, employees,
shareholders, trustees, administrators, parent companies, subsidiary companies and af?liated
companies (collectively referred to as ?Releasors?) hereby remise, release and forever discharge,
Hausman and her heirs, administrators, executors, employees, agents, successors and
assigns (hereinafter collectively referred to as ?Releasees?), from any claims, actions, lawsuits
and demands whatsoever, known and unknown, foreseen, unforeseen or unforeseeable, that
Releasors ever had, now have or hereafter can, shall or may have against Releasees for, upon, or
by reason of any matter, cause or thing whatsoever, from the beginning of the world to the date
of this General Release including but not limited to any and all claims that were raised or that
could have been raised in the action entitled Hausman v. Vermont Hemp Company, LLC
and Joel Bedard, Vermont Superior Court, Civil Division, Addison Unit, Docket No. 16?1?18

Ancv (the ??Litigation?).

[signatures on following page]

 

 

 

COUNTY, SS

 

   

QMW ?Vermont this {aim day of ,2018 personally
appeared Joel Bedard and he acknowledged the foregoing instrument by him sealed and
subscribed to be his free act and deed.

 

    

Notary Public x? mm
Com 56311 Exp?f? 02 10%

 

 

 

 

 

 

Dated:
Vermont Hemp Company, LLC
BY: Duly authorized agent
STATE OF VERMONT
COUNTY, SS.
At Vermont, this day of 2018 personally
appeared and he acknowledged the foregoing instrument by him sealed and

subscribed to be his free act and deed and the free act and deed of Vermont Hemp Company,
LLC.

Notary Public
Commission Expires: 02?10?19

 

EXHIBIT 
STATE OF VERMONT

SUPERIOR COURT CIVIL DIVISION
Addison Unit Docket No. 16-1-18 Ancv

 

WIGHT HAUSMAN,
Plaintiff,

V.

THE VERMONT HEMP COMPANY, 
JOEL BEDARD
Defendant.

 

 

STIPULATION OF DISMISSAL
NOW COME the parties in the above?entitled matter, and stipulate, pursuant to V.R.C.P.
to the dismissal with prejudice, of all claims and counter claims in this action, each
party to bear its own fees and costs.
DATED at Burlington, Vermont this day of October, 2018.

LANGROCK SPERRY WOOL, LLP

 

Erin Miller Heins

PO Box 721, 210 College Street

Burlington, VT 05402

(802) 864-0217

Attorneys for Vermont Hemp Company, LLC and
Joel Bedard

DATED at Burlington, Vermont this day of October, 2018.

 

Hausman, Plaintiff Pro Se

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