This Settlement and Release Agreement (“Agreement”) is entered into as of the ___ day of __________, 2025, by and between EPAH and Nubian Queen (together, “Released Parties”), and [Dog Owner’s Full Legal Name] (“Releasing Party”).

WHEREAS, on or about ___________, 2025, an incident occurred in which the dog owned by EPAH and under the care of Nubian Queen allegedly caused injury to a dog owned by Releasing Party (the “Incident”); and

WHEREAS, the parties desire to fully and finally settle all claims, disputes, and causes of action related to the Incident without admission of liability or wrongdoing by any party.

NOW, THEREFORE, in consideration of the mutual promises and the payment described below, the parties agree as follows:

1. Payment. Within five (5) business days after execution of this Agreement, EPAH shall pay the Releasing Party the sum of One Thousand Dollars ($1,000.00) (the “Settlement Payment”) by Venmo.

2. Release of Claims. In consideration of the Settlement Payment, the Releasing Party, on behalf of themselves, their heirs, successors, and assigns, hereby fully and forever releases and discharges EPAH, Nubian Queen, and their respective heirs, executors, administrators, agents, and assigns, as well as EPAH’s dog, from any and all claims, demands, damages, actions, and causes of action, whether known or unknown, arising out of or relating to the Incident.

3. No Admission of Liability. This Agreement is a compromise of disputed claims and shall not be construed as an admission of liability or wrongdoing by any party. The Released Parties expressly deny any liability arising from the Incident.

4. General Matters. This Agreement shall be governed by and construed in accordance with the laws of the State of Hawaii. This Agreement constitutes the entire agreement between the parties relating to the subject matter hereof and supersedes any prior understandings or agreements, written or oral. This Agreement may be executed in counterparts, each of which shall be deemed an original, and all of which together shall constitute one and the same instrument. Electronic signatures shall be deemed as valid as originals.

IN WITNESS WHEREOF, the parties hereto have executed this Agreement as of the date first written above.

EPAH

__________________

Nubian Queen

_________________

[Dog Owner’s Full Legal Name]

____________________________

(http://www.autoadmit.com/thread.php?thread_id=5717571&forum_id=2#48887770)