UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MICHIGAN

SOUTHERN DIVISION

NATALIE JAMES, individually, and on

behalf of all others similarly situated,
JEROME DAY, individually, and on behalf of Hon. Sean F. Cox
all others similarly situated,
CARL AUSTIN, individually, and on behalf of Civil Action No. 18-cv-13601
all others similarly situated,
VERONICA SHERRELL, individually and
on behalf of all others similarly situated, Mediator: Dennis M. Barnes
ANDRE MACK, individually and on behalf of
those similarly situated,
ERIC INGRAM, individually and on
behalf of all others similarly situated,
SHANON COBB, individually and on SETTLEMENT AGREEMENT
behalf of all others similarly situated, and TERM SHEET
JAZMINE COBB, individually and on behalf
of all others similarly situated.

Plaintiffs,
v.

DETROIT PROPERTY EXCHANGE, a

Michigan Corporation,
SUENA HOMES REALTY LLC, a Michigan
Limited Liability Company,
HOMES OF DETROIT, LLC, a Michigan
Limited Liability Company,
GREATER DETROIT, LLC, a Michigan
Limited Liability Company,
AMERICAN TAX REFUND LLC, a
Michigan Limited Liability Company,
MONTLIEU, LC, a Michigan Limited
Liability Company,
DETROIT LEASING, INC., a Michigan
Corporation,
SUNRISE HOMES REALTY LLC, a
Michigan Limited Liability Company,
HOMES OF DETROIT LLC, a Michigan
Limited Liability Company,
CLEAR SKY REALTY LLC, a Michigan
Limited Liability Company,
DOBEL PRIZE LLC, a Michigan Limited
Liability Company,

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MIDTOWN HOMES REALTY LLC, a
Michigan Limited Liability Company,
BELMONT PROPERTIES OF MICHIGAN
INC., a Michigan Corporation,
WOODLAWN PROPERTIES INC., a
Michigan Corporation,
DETROIT, MI LLC, a Michigan Limited
Liability Company,
PARTY CITY LC, a Michigan Limited
Liability Company,
DAKOTA KIDS GROUP, a Michigan Non-
profit corporation,
ACRE ESTATE LLC, a Michigan Limited
Liability Company,
13540 MANSFIELD, LLC, a Michigan
Limited Liability Company,
CHEROKEE LAND LC, a Michigan Limited
Liability Company,
9527 WHITCOMB, LLC, a Michigan Limited
Liability Company,
CHASE LOAN SERVICES, INC., a
Michigan Limited Liability Company,
BEBA’S BUILDINGS, LLC, a Michigan
Limited Liability Company,
CHASE DETROIT LLC, a Michigan Limited
Liability Company,
GOOD HOMES REALTY, LLC, a Michigan
Limited Liability Company,
LATINO HOUSING, LLC, a Michigan
Limited Liability Company,
CRYSTIAN SEGURA, an individual,
MICHAEL KELLY, an individual,
ALMA ALMONT, LLC, a Michigan Limited
Liability Company,
AMERICAN EQUITY PARTNERSHIP,
LLC, a Michigan Limited Liability Company,
THE ANGEL GROUP, LLC, a Michigan
Limited Liability Company,
DEVONSHIRE HILLS, LC, a Michigan
Limited Liability Company,
LA CASA GRANDE COMPANY, a
Michigan Corporation,
REAL TC, LLC, a Michigan Limited Liability
Company,
GERARD BROTHERS, LLC, a Michigan
Limited Liability Company,

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DREAM REALTY COMPANY, a Michigan
Corporation, and
John Doe Entities, 1-20, jointly and severally,

Defendants.

SETTLEMENT AGREEMENT TERM SHEET

1. The parties agree that Plaintiffs will be appointed as representatives of a class of individuals
similarly situated to Plaintiffs as it relates to claims that could be raised against the
Defendants (the “Class Members” or “Class”) and that Mantese Honigman, P.C. and
Michigan Legal Services are appointed as Class counsel.

2. Defendants will agree to stipulate to certification of the following Class for purposes of
settlement of this dispute: any individual who entered into an agreement to acquire real
property with any Defendant from November 19, 2015 to present and who signed the
following documents in the same year:

a. an agreement (commonly titled “Residential Lease with Option Agreement” or

“Residential Lease Agreement”) that requires the individual to make monthly
payments for a set number of months or period of years, and

b. an agreement (commonly titled “Option to Purchase Agreement”) providing that

the individual has the option to purchase the subject property for a set price.

3. Defendants Michael Kelly, Crystian Segura, and the Entity Defendants (defined as Detroit
Property Exchange, Suena Homes Realty LLC, Homes Of Detroit, LLC, Greater Detroit,
LLC, American Tax Refund LLC, Montlieu, LC, Detroit Leasing, Inc., Sunrise Homes
Realty LLC, Homes Of Detroit LLC, Clear Sky Realty LLC, Dobel Prize LLC, Midtown
Homes Realty LLC, Belmont Properties Of Michigan Inc., Woodlawn Properties Inc.,
Detroit, MI LLC, Party City LC, Dakota Kids Group, Acre Estate LLC, 13540 Mansfield,
LLC, Cherokee Land LC, 9527 Whitcomb, LLC, Chase Loan Services, Inc, Beba’s
Buildings, LLC, Chase Detroit LLC, Good Homes Realty, LLC, Latino Housing, LLC,
Alma Almont, LLC, American Equity Partnership, LLC, The Angel Group, LLC,
Devonshire Hills, LC, La Casa Grande Company, Real TC, LLC, Gerard Brothers, LLC,
Dream Realty Company and any Detroit Property Exchange related entity that contracted
with a class member as listed in the Exhibit A agree as follows:
a. $175,000 in cash to be allocated as follows:
i. $10,000 in service fees for each named Plaintiff;
ii. Defendants will not object to attorney fees and costs that are less than 20%
of the total value of this settlement;

b. The balance of the funds shall be paid to class members.

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 c. The cash payment shall be paid within 15 days of the Court’s granting preliminary
approval to the settlement and shall be held in Mantese Honigman, P.C.’s IOLTA
pending final approval.

d. For the purposes of allocating any payment to any Class Member, any Class
Member that invalidated a release during the pendency of this litigation is deemed
to have received a value of $250 that will reduce any consideration under this
agreement.
e. Any consideration received by a Class Member in exchange for a release that was
invalidated will not be returned to Defendants and these amounts are not included
in the above listed amounts.
f. Any Class Member that was evicted or moved out prior to the conclusion of their
contract shall be released from any and all liability to any of the Defendants related
to the contract.
g. This agreement encompasses the full consideration to be paid to the Class.
h. Plaintiffs’ counsel may, but are not required to, use a class action administration
company to administer the settlement and payment therefore shall be made out of
the settlement proceeds.

i. Defendants agree to assist in good faith with obtaining contact information for any
Class Members who no longer reside in their home and provide the same to
Plaintiffs’ counsel or the class action administration company.

j. Defendants will not object to these terms.

4. Judgment will be entered declaring that the Class documents as set forth above are land
contracts.

5. Defendants agree that each Plaintiff and Class Member who does not opt out of the
settlement will be issued a land contract that is in recordable format. Defendants will
produce recordable land contracts having substantially the same terms as their current
agreements to each Class Member within 60 days after final approval. Counsel to this case
will negotiate and agree on the terms of these land contracts before issuance and any issues
or disputed will be resolved by Dennis Barnes. Unless the parties subsequently agree
otherwise, Defendants will not file any proceedings, including collection, eviction, or
forfeiture, against any Class Member, until providing that Class Member with the
consideration provided for herein.

6. This is a binding settlement. This agreement binds and benefits the parties, the class
members, their principals, heirs, beneficiaries, agents, successors, and assigns.

7. This agreement, and any formal settlement agreement that follows, is not subject to
confidentiality.

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 8. Any controversy or claim (including all legal and equable claims including claims for a
temporary restraining order, injunctive relief, and specific performance) arising out of or
relating to this Agreement, or the breach thereof, shall be settled by binding arbitration
pursuant to the Michigan Uniform Arbitration Act, MCL 691.1681 et. seq., and the Parties
appoint Dennis M. Barnes as the sole arbitrator. As arbitrator, Mr. Barnes is empowered to
award any equitable or legal relief. The award rendered by the arbitrator may be entered in
any court having jurisdiction thereof. Defendants shall each be responsible for one-half of
the arbitrator’s fees and costs in connection with any arbitration, except as otherwise
decided by the arbitrator.

9. This settlement agreement that will encompass the terms of this term sheet is subject to
Court approval.

AGREED AND ACCCEPTED:

_____________________________ _____________________________
MANTESE HONIGMAN, P.C. THE MILLER LAW FIRM, P.C.
Attorneys for Plaintiffs and the Class Attorneys for Defendants except Segura
Gerard V. Mantese (P34424) David B. Viar (P43479)
gmantese@manteselaw.com dbv@miller.law
Theresamarie Mantese (P53275) Eric J. Minch (P80926)
tmantese@manteselaw.com ejm@miller.law
Kathryn Regan Eisenstein (P66371) 950 W. University Drive, Suite 300
keisenstein@manteselaw.com Rochester, MI 48307
Emily S. Fields (P82047) (248) 841-2200
efields@manteselaw.com
1361 E. Big Beaver Rd. _____________________________
Troy, MI 48083 WILLIAM E. SEMAAN, JR. PLLC
(248) 457-9200 Attorney for Defendant Segura
William E. Semaan, Jr, (P80352)
Attorney.dpx@gmail.com
51 W. Hancock, Suite 407
Detroit, MI 48201
(313) 263-7771

Michael Kelly, Individually and on

behalf of the Entity Defendants and any
Detroit Property Exchange related entity