SETTLEMENT AGREEMENT AND RELEASESettlement Agreement • May 20th, 2024 • New York
Contract Type FiledMay 20th, 2024 JurisdictionAgreement”) is made as of June 5, 2023 by and among: (i) Navien, Inc. (“Navien”), on the one hand; and (ii) Michael Diack (“Diack”), Pipe Doctor Plumbing, Heating, and Air Conditioning, Inc. and its successor, Pipe Doctor Home Services, Inc. (together, “Pipe Doctor”), Pipe Doctor IP Holder, Inc. (“Pipe Doctor IP”), and Pipe Doctor Plumbing, Heating & Air Conditioning, LLC and any other entity or proprietorship, whether presently known or unknown (“Pipe Doctor LLC,” and collectively with Diack, Pipe Doctor, and Pipe Doctor IP, the “Pipe Doctor Parties”), on the other. Navien, Diack, Pipe Doctor, Pipe Doctor IP, and Pipe Doctor LLC are sometimes collectively referred to in this 2023 Settlement Agreement as “the Parties” or individually as a “Party.”