Metro Property Group Detroit Vs Kathryn Llewellyn-Jones, Mark Llewellyn-Jones Lawsuit

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MICHIGAN

SOUTHERN DIVISION

KATHRYN LLEWELLYN-JONES, MARK LLEWELLYN-JONES, CAROLINE JONES, PETER GREEN, LESLEY GREEN, SAID FADEL a/k/a SAEED FADHL, WARREN GROVER, and MARGARET JOYCE GROVER, Civil Case No. 13-cv-11977 Plaintiffs, Hon. David M. Lawson vs. METRO PROPERTY GROUP, LLC, METROPROPERTY MANAGEMENT, LLC, GLOBAL POWER EQUITIES, LLC, APEX EQUITIES, LLC, SAMEER BEYDOUN, ALI BEYDOUN, TAREK MAHMOUD BAYDOUN, BAYDOUN LAW GROUP, PLLC, d/b/a THE MERIDIAN LAW GROUP, MIKE ALAWEIH, DAVID MAKKI, CHRIS PICCIURRO, KATHY MESSICS, GEORGE, ALLEN BROTHERS ATTORNEYS AND COUNSELORS PROFESSIONAL LIMITED LIABILITY COMPANY, JAMES ALLEN, and JOHN ALLEN, Defendants. METRO PROPERTY GROUP, LLC, Counter-Plaintiff, vs. KATHRYN LLEWELLYN-JONES, MARK LLEWELLYN-JONES Counter-Defendants. Deborah K. Schlussel (P56420) David H. Fink (P28235)) Law Office of Debbie Schlussel. Darryl Bressack (P67820) Attorneys for Plaintiffs/ Fink + Associates Law Counter-Defendants Attorneys for Metro Property Group, LLC, 29477 Laurel Woods Drive Metro Property Management, LLC, Global Southfield, Michigan 48034 Power Equities, LLC, Apex Equities LLC, (248) 354-1409 Sameer Beydoun, Ali Beydoun, Mike Alaweih, David Maki and Kathy Messics 100 West Long Lake Road; Suite 111

Bloomfield Hills, MI 48304 (248) 971-2500 [email protected] [email protected]

2:13-cv-11977-DML-RSW Doc # 8 Filed 07/30/13 Pg 1 of 28 Pg ID 159

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COUNTER-COMPLAINT

Counter-Plaintiff, Metro Property Group, LLC, by and through its attorneys,

Fink + Associates Law, for its Counter-Complaint against Counter-Defendants

Kathryn Llewllyn-Jones and Mark Llewellyn-Jones, states as follows:

JURISDICTION

1. This Court has original jurisdiction over this matter pursuant to 28

U.S.C. § 1332, due to the diversity of citizenship between the parties.

2. Counter-Plaintiff Metro Property Group, LLC is a limited liability

company formed under the laws of, and conducting business in the State of

Michigan. Metro Property Group has one member, Sameer Beydoun, who is a

citizen and resident of the State of Ohio.

3. Counter-Defendant Kathryn Llewellyn-Jones is a citizen of the United

Kingdom who resides in the United Arab Emirates.

4. Counter-Defendant Mark Llewellyn-Jones is a citizen of the United

Kingdom who resides in the United Arab Emirates.

5. The amount in controversy in this Counter-Complaint exceeds

$75,000.

GENERAL ALLEGATIONS

6. Metro Property Group, LLC, directly and through separate affiliates,

Metro Property Management, LLC, Global Power Equities LLC, Apex Equities,


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LLC (collectively and for purposes of this Counter-Complaint only, “Metro

Property Group”), has implemented a plan that has significantly contributed to the

beginning of the revitalization of residential neighborhoods throughout the City of

Detroit.

7. Metro Property Group is a global organization engaged in the

purchase, rehabilitation, sale and management of residential properties in Detroit,

working with investors throughout the world.

8. Since 2010, Metro Property Group has been the largest purchaser, by

unit volume, of single family houses in Detroit.

9. The business model developed by Metro Property Group is at once

highly complex—with proprietary formulas and analysis applied to the purchase

and rehabilitation of properties—and, at the same time, elegantly simple, with

operational teams dedicated to discrete tasks.

10. Metro Property Group performs a significant amount of due diligence

with respect to houses for sale, and generally limits its purchases to houses within

specific strong-performing neighborhoods that often have long-time residents, who

are intent on preserving the neighborhood’s property value. If a property is in tax

foreclosure—as is very often the case—Metro Property Group will perform an

exterior inspection of the house to determine, to the best extent possible, whether


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the house is structurally sound and could be rehabilitated at a cost that fits within

its models.

11. If the location, external features and price point of the property fit

within defined parameters, Metro Property Group will purchase the house,

generally at auction.

12. While Metro Property Group holds the property on its books, it pays

for expenses such as winterization, security—generally with steel anti-entry

systems—and property taxes.

13. Metro Property Group then thoroughly rehabilitates the house,

generally at a cost of between $10,000 and $20,000 per house. The rehabilitation

specifications have evolved over time, but, since 2012, Metro Property Group

requires its contractors to perform a 238-point inspection for each property.

14. Rehabilitation work varies based on the condition of the purchased

house, but generally includes the following major items:

a) Upgrading or replacement of the plumbing;

b) Upgrading of the electrical box;

c) New hot water tank;

d) New furnace;

e) Replacement of boilers and radiators with forced air heating

systems and related ductwork;


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f) Tiling of kitchen;

g) Painting of interior, with a stylish two-tone color scheme;

h) Refinishing of existing hardwood floors or carpeting of flooring

where the hardwood is too damaged or is non-existent.

15. Numerous other items are rehabilitated as necessary. Although Metro

Property Group’s inspection system is more comprehensive than that required by

the Building Code of the City of Detroit or by the federal requirements for

subsidized housing, Metro Property Group’s inspections include all items required

by the City of Detroit for compliance with its Building Code or required by the

federal government for subsidized housing.

16. Metro Property Group has spent millions of dollars for rehabilitation

work. In 2012 alone, Metro Property Group spent approximately $5 million on

such work. Payments to just one subcontractor, who installed hot water heaters

and furnaces at Metro Property Group properties, totaled over $400,000 in 2012.

(Exhibit 1).

17. Metro Property Group currently has more than 800 single family

residences in its portfolio. Metro Property Group sells approximately half of its

houses to investors, who generally pay approximately $50,000 for each

rehabilitated property. Metro Property Group has sold houses to more than 200

investors in more than 600 transactions, totaling over $30 million.


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18. The investors may—if they so choose—retain Metro Property Group

to manage the rental investment. Metro Property Group currently manages more

than 1,000 properties.

19. If a tenant is no longer paying rent, or if eviction is otherwise

warranted, Metro Property Group retains the services of a local law firm to handle

the process. Investors are billed for some of the required legal work.

20. As another service, Metro Property Group will appeal the property

taxes on properties it has sold. In 2012, Metro Property Group successfully

appealed the tax assessment on nearly all of the houses it sold, resulting in a

property tax reduction of approximately 50% for its investors.

21. Although real estate investment is not without risk, the vast majority

of investors who have purchased houses from Metro Property Group are satisfied

with their returns and the services provided. For example, on December 4, 2012,

Roy Rosenthal, citizen and resident of the United Kingdom provided the following

testimonial:

My association with Metro Properties LLC began in the Spring of 2011 when I purchased 3 properties in Detroit for investment purposes. I was delighted that these transactions went smoothly and the properties swiftly came under my ownership, but the MMP service did not end there. I needed to open a US bank account and this was made easy with the assistance of MMP. I needed to write a US Will and MMP introduced me to a lawyer who facilitated this important requirement. I needed a US accountant and again MMP came up trumps introducing me to an excellent accountant specialising in dealing with foreign purchasers and their tax situation.


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I visited Detroit in June 2012 to meet the team at Metro Properties and to see my properties and tenants. I was made welcome throughout my stay, meeting the various heads of department, to include Real Estate Services, headed up by David Makki; Accounts where Chris Picciurro is in charge; Maintenance headed up by Mike Alaweih and last but certainly not least, Sameer Baydoun who is CEO of Metro Properties. Sameer should be rightly proud of the company he leads and the people he has chosen to represent his company. Service is the name of their game, making it easy and simple for purchasers of properties to feel at ease in the knowledge that their interests are always the main priority. I am glad to have met these individuals who not only look after my interests but have become friends. I highly commend this company.

22. Edwin Schouten, of the Dutch real estate investment firm,

VastgoedAmerika/Americainvest, which has worked closely with Metro Property

Group, stated, in part:

My company has been METRO PROPERTY GROUP’S representative for over 2 years, during which period we have got joint clients who own up to more than 40 properties. Undersigned [Mr. Schouten] has seen each and every single house that was sold to our customers and can only confirm that all houses have been renovated at the usual high standards. Furthermore we have checked with all our customers individually about the level of satisfaction regarding the property management and the obtained results and everyone, without exception, is totally satisfied.

(Sic) (Exhibit 2) (emphasis in original).


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23. Local community stakeholders who have worked with Metro Property

Group have also related their positive experiences with the company. For

example, Larry Wright, managing partner of the Detroit Talent Hub, a “low profit”

corporation headquartered in Michigan with the explicit goal of helping Detroit

residents find sustainable employment, has written:

Quality, committed companies like Metro are key to the success of Detroit's turnaround and our goal to create 1,000 jobs for Detroiters in 2013. The visionary force in developing our partnership with Metro has been Sameer Beydoun. He is a hard working, intelligent entrepreneur who also recognizes the intrinsic value of providing opportunities for the residents in the communities he serves. Sameer has brought honor and integrity coupled with a true sensitivity to help the Detroit Talent Hub. On a personal level, I have gotten to know Sameer over the past 9 months and I consider him a friend as well. Detroit is a better place, The Detroit Talent Hub is a more successful enterprise and Detroit residents have proven sustainable job opportunities because of Sameer Beydoun and Metro Properties Group.

(Exhibit 3).

24. Orlando Woods, General Partner of Simply Building Solutions had

this to say about Metro Property Group and Sameer Beydoun:

Simply Building Solutions is the evolution of several successful enterprise initiatives of the partners that has resulted in the hiring of hundreds of metro Detroiters as well as the development of numerous small contractors and subs over the past twenty years. In short, SBS is an facilities and construction services firm that provides housing


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rehabilitation, facility, property maintenance and preservation services for business, corporate, non-profit, financial, real estate and residential clients. Our management team and partners are credentialed in energy efficiency, environmental and construction trades and we have an available, qualified and ready to work labor pool of hundreds of metro Detroit residents trained and credentialed through leading programs including the Regional Energy Efficiency Partnership Training Program and Detroiters Working for Environmental Justice among others. Significantly SBS is partnering with the Metro Property Group, the Detroit Talent Hub and Alkebu-Lan Village in a campaign to create 1,000 jobs for qualified workers over the next three years. The campaign is being launched through providing energy, housing rehabilitation and property preservation services for Atlas Construction and Metro Properly Group headed by Sameer Beydoun, a testimony to local entrepreneurial success. Over the past year we have grown to not only know but respect Sameer as a man of integrity who is committed to creating opportunities for all Detroiters to prosper through hard work and dedication.

Sameer’s story and passion for Detroit is an inspiration to others as he demonstrates his commitment though community partnerships, diversity in hiring, and investment in neighborhoods and people. In our dealings Sameer has always been a principled person and business partner that we are proud to be associated with in our quest to serve our community and build a successful company.

(Exhibit 4).

25. Reverend Stephen H. Bancroft, Retired Dean of the Cathedral of St.

Paul in Detroit has affirmed:

I am personally aware of Metro Property Group’s business model, activity and performance. I have seen the quality of their restoration work on seriously distressed property, and the accusation of failed performance or unfair business practices is not credible. […]


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I am a practicing and committed Christian (an Episcopal priest) and have no interest in supporting Islam. In addition, I do have concerns about the practice of radicalized Islam. […] Anyone who deals with Sameer and all of his partners and staff would find an accusation of religious or ethnic extremism absolutely absurd. This group is as American as they come. Their business practices are pristine. Their honesty and forthrightness are refreshing. Their commitment to their American heritage is unassailable. I wish to personally express my belief that Sameer Beydoun and Metro Property Group are fair-minded, honest, and hard-working business people who have a sincere desire to reinvigorate their home town; provide decent, affordable housing to everyone regardless of ethnic or religious heritage; and provide their investors with a fair return on investment; while making a good living for themselves. Whatever personal faith they may carry or practice as non-radical Muslims is a non-issue in both their business and the personal relationships as I have experienced it.

(Exhibit 5).

Purchases and Sales by the Llewellyn-Joneses

26. Kathryn Llewellyn-Jones and Mark Llewellyn Jones are plaintiffs in

the above-captioned lawsuit.

27. The Llewellyn-Joneses purchased three houses from Metro Property

Group, through USA Property Direct, a brokerage firm based in the United

Kingdom.

28. The other plaintiffs in the lawsuit—with the exception of Warren and

Margaret Grover—also purchased their houses through USA Property Direct, with


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plaintiff Kathryn Llewellyn-Jones acting as the sales agent, and receiving a

commission as the sales agent.

29. The houses at issue were acquired in a manner distinct from Metro

Property Group’s other acquisitions. The houses were purchased in 2011 in a bulk

purchase from an individual who owned a large number of houses in Detroit.

30. Most of the houses purchased in the bulk acquisition required less

rehabilitation than houses purchased at auction or through other sources.

31. These houses were not subjected to the 238-point inspection, because

of the nature of the acquisition and because they were sold prior to Metro Property

Group’s commencement of its current inspection program.

32. With the exception of the Grover plaintiffs, each of the houses at issue

was purchased from Metro Property Group in 2011 by the Llewellyn-Jones

plaintiffs or by individuals for whom Ms. Llewellyn-Jones served as the seller’s

agent.

33. Metro Property Group employees had limited or no contact with any

of the plaintiffs prior to purchase. Prior to her individual purchase of properties,

Ms. Llewellyn-Jones communicated primarily with USA Property Direct. Pre-sale

communications with the other plaintiffs (other than the Grovers) were primarily

between Kathryn Llewellyn-Jones and the plaintiff.


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34. In 2012, Kathryn Llewellyn-Jones started to raise complaints about

some of the properties and began alleging that some of the properties were not

rehabilitated, tenanted or managed to her expectations.

35. Metro Property Group employees disagreed with the bulk of Ms.

Llewellyn-Jones assertions, but made numerous attempts to address the issues she

raised.

36. Ultimately, irrespective of the work performed by Metro Property

Group, Ms. Llewellyn-Jones took the position that the company could not or would

not meet her increasingly inappropriate demands. Thus, the Llewellyn-Joneses

terminated Metro Property Group’s management services for their properties in

July, 2012.

37. Following the termination, although Metro Property Group no longer

had regular access to the properties and no longer had the ability to secure the

properties from vandalism or irresponsible tenants, the Llewellyn-Joneses

continued to complain of various alleged problems at the properties, including the

supposed lack of new roofs, windows, doors and PEX plumbing.

38. Metro Property Group attempted to address each of the concerns

raised by the Llewellyn-Joneses and even provided photographic evidence of the

rehabilitation work at the properties including the PEX plumbing.


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39. Despite Metro Property Group’s repeated attempts to resolve the

issues, the Llewellyn-Joneses were not satisfied.

Discussions to Resolve the Matter

40. The parties then engaged in discussions to amicably resolve the

issues.

41. Despite the good faith shown by Metro Property Group, the

Llewellyn-Joneses threatened Metro Property Group that if their demands were not

met, “we reserve the right jointly or separately to file Police reports and commence

civil and criminal proceedings which will include as stated above a claim for

damage to our professional reputations.”

42. Throughout the discussions, the Llewellyn-Joneses continued to make

wholly-unfounded assertions and allegations. The Llewellyn-Joneses even stated

that they were engaging in the discussions so that Metro Property Group could

“buy the silence of the investors/owners.”

43. Eventually, the parties agreed in principle that Metro Property Group

would repurchase the properties owned by the Llewellyn-Joneses and the other

plaintiffs in this matter. This resolution would have restored the parties to their

respective pre-transaction positions.

44. Despite the agreement in principle, after Metro Property Group

retained the services of outside counsel—the Allen Brothers Law Firm, who


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plaintiffs named as defendants in the Complaint—the Llewellyn-Joneses ceased

settlement discussions and blocked further emails from outside counsel.

The Llewellyn-Joneses Retain Counsel

45. At approximately the time the Llewellyn-Jones refused to deal with

outside counsel for Metro Property Group, the Llewellyn-Jones retained the

services of a Michigan-based attorney.

46. Attorney Deborah K. Schlussel is a television and radio personality

who has made appearances on numerous right-wing oriented shows.

47. Ms. Schlussel maintains a weblog on which she communicates with

her followers and others about various topics.

48. On her weblog, Ms. Schlussel often expresses disdain towards

followers of Islam. As just one example, when Osama Bin Laden was killed, Ms.

Schlussel used the occasion to attack all Muslims by writing:

Na-na-na-na, na-na-na-na, hey-hey, goood-b . . . oh, wait, Islam is still here and on our shores, and isn’t going away. *** Rot In Hell, Osama Bin Laden. One down, 1.8 billion to go . . . many of ‘em inside U.S. borders, with the U.S. government at all levels kissing their asses.

(http://www.debbieschlussel.com/36592/whoa-osama-bin-laden-dead-but-wont-

make-much-diff-amid-growin-islamic-threat-to-west/) (emphasis added).


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49. The principals of Metro Property Group are Muslim-American. They

grew up in the United States, went to high school in the United States and some

even played college and semi-professional football in the United States.

50. Upon information and belief, as successful Muslim-Americans, the

principals and some employees of Metro Property Group became targets of Ms.

Schlussel. On November 5, 2012—well-prior to date the Complaint was filed in

this matter—Ms. Schlussel wrote the following about Tarek Baydoun, who is

named as a defendant in the Llewellyn-Jones’ Complaint:

Tarek Baydoun … was also organizing and leading Muslim rallies throughout Dearbornistan in support of anti-blasphemy laws restricting the First Amendment in reaction to the anti-Mohammed video falsely blamed for the U.S. Embassy attacks. Oh, and he was tweeting in support of HAMAS terrorism and has participated in events supporting the boycott of Israel. Baydoun also worked for the charity, Al-Mabarat Charitable Organization in Dearbornistan, at the time it was raided by the FBI, and asked his Facebook friends to give money to its Hezbollah parent organization, Al-Mabbarat in Lebanon, for his 25th birthday. *** Baydoun is a lawyer and a Muslim activist for Islamic terrorist groups.

(Sic) (http://www.debbieschlussel.com/55947/fox-news-fake-pollster-is-Hezbollah

cair-activist-part-of-apparent-ponzi-scam-praised-hamas-terrorism-led-rally-to-

support-muslim-blasphemy-laws/).


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51. Ms. Schlussel has also made extremely negative comments on her

weblog about outside counsel retained by Metro Property Group, the Allen

Brothers law firm. (See e.g. “Turkia Mullin: What Happens When Muslims Run an

American County,” http://www.debbieschlussel.com/44038/who-is-turkia-awada-

mullin-what-happens-when-muslims-run-an-american-county/.

52. Ms. Schlussel’s personal bias has been publicly confirmed by her

clients. After locating Ms. Schlussel, the Llewellyn-Joneses sent an e-mail to at

least one other investor stating that “Our Attorney will charge two more investors a

total of $5k plus a third of what she gets back (less if she gets costs). She is

dedicated to bringing the Baydouns down which is why she is doing it for this

kind of deal.” (emphasis added).

Tortious Interference with Business Relationships and Business Expectations

53. Because the Llewellyn-Joneses served as agents for Metro Property

Group, they are aware of and have contact information for many of Metro Property

Group’s business partners and investors.

54. Although the Llewellyn-Joneses have not revealed their motives—

perhaps they intend to compete with Metro Property Group—the Llewellyn

Joneses have contacted many Metro Property Group investors and partners,

relaying inaccurate information and attempting to convince Metro Property

Group’s investors and partners to end their business relationships with Metro


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Property Group. For example, on November 29, 2012, Kathryn Llewellyn-Jones

sent an email to a Metro Property Group investor, stating, in part:

Let me explain our position to you so you can decide what to do. Highly confidential as before please. Long email I am afraid. *** None of the houses were refurbished, some were dangerous and almost derelict. *** This is all highly illegal and I believe we will get them locked up for it however, right now we are putting our civil case together and it will be filed very soon. *** We don't especially need any more evidence to prove our case however our Attorney says the more plaintiffs the better. Having given it some thought I do not want to jeapordise the chance of us getting our money back by making the claim so big Metro don't have ready funds. Our Attorney is suing for Conversion (Google it under Michigan law to explain) which entitles us to three times what has been stolen from us. With just the four of us the claim is over one million dollars, which is a lot of money. The reason I want to invite a couple of other victims to join us is so we can say to Metro, we used to be four, now we are six and if you don't settle very quickly we will grow in number month by month until the claim is in the tens of millions. *** Our Attorney will charge two more investors a total of $5k plus a third of what she gets back (less if she gets costs). She is dedicated to bringing the Baydouns down which is why she is doing it for this kind of deal.

(Sic).


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55. On May 11, 2013, Kathryn Llewellyn-Jones sent an e-mail message to

key individuals at a property investment firm that Ms. Llewellyn Jones knows to

be an important business partner of Metro Property Group. In that email Ms.

Llewellyn-Jones wrote:

I was appalled to receive an email from you promoting the houses of Metro Property Management in Detroit. This company has had a 116 page case filed in Federal Court detailing alleged Fraud and Racketeering. In addition I recognize some of the properties you are promoting and know their sordid history. If you continue to promote this companies properties knowing there is a law suit against them then I believe you can be held accountable in the future when investors discover they have been duped.

(Sic).

56. On May 13, 2013, Mark Llewellyn-Jones sent a longer email to the

same individuals at the property investment firm, stating, among other things, that:

The homes in most cases are completely un-refurbished. They are virtually worthless on the open market and some will never find tenants.

57. On May 14, 2013, Kathryn Llewellyn-Jones sent another email to the

property investment firm stating:

Photos attached of the reality of Metro Property Groups homes. All have been subject to massive fines from the Detroit Housing Commission. All were sold as fully refurbished and tenanted. All are virtually worthless on the open market. None of them have produced a genuine rental income. Ultimately of course you must decide if you want to continue selling these properties.


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58. On May 20, 2013, hoping to address these improper communications

without involving this Court, outside counsel for Metro Property Group sent a

letter to Ms. Schlussel asking her to direct her clients to cease and desist from

further contacting Metro Property Group’s business relations. In that letter,

counsel stated:

It has come to our attention that the Llewellyn-Jones plaintiffs, and others, have been publishing defamatory statements regarding the defendants in the above-referenced matter. *** [U]nless you affirmatively represent that your clients have confirmed that they will immediately cease and desist from contacting third-parties and will fully refrain from interfering in our clients' business relations, we will be compelled to seek relief from the Eastern District of Michigan. If you do not make this representation on your clients' behalf by May 24, 2013, we intend to seek appropriate relief from the Court.

59. The Llewellyn-Joneses refused to comply with the request that they

refrain from contacting third parties who they knew had business relationships with

Metro Property Group.

60. After Metro Property Group sent its communication asking for the

Llewellyn-Joneses to stop interfering with its business relationships, the

Llewellyn-Joneses continued their campaign. For example, Kathryn Llewellyn-

Jones sent a communication to a third party on May 23, 2013, stating, in part:

I write to inform you that Metro have engaged the services of a yet another attorney in order to yet again threaten action against


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ourselves. This time it is in regard to the communications we sent you advising you of the situation with Metro. Please note that the copy of the filed complaint which we sent you, and quoted from, is authentic, as are the photos we sent of the properties sold to us by Metro Property Group.

(Sic).

61. On June 28, 2013, Kathryn Llewellyn-Jones sent an email to local

politician and television journalist, Jonathan Kinloch, stating, in part:

I see that you interviewed Sameer Beydoun from Metro Property Group in Detroit recently. I am unable to listen to this interview but as it is featured on the Metro Property website I imagine that Sameer Beydoun was not asked about the law suit for fraud and racketeering which was recently filed against Metro Property Group, Sameer Beydoun, Ali Baydoun, Tarek Baydoun and other individuals involved. This is very disappointing indeed.

62. In addition to the direct communications from the Llewellyn-Joneses,

certain individuals who have cloaked their identity in anonymity, contacted other

investors and prospective investors, both directly and by comments on social

media sites, to make the same allegations as those made by the Llewellyn-Joneses,

often referring to and quoting directly from the Complaint filed in the case at bar.

63. The actions of the Llewellyn-Joneses have resulted in the loss of

business relationships and business expectations for Metro Property Group. As

just one example, Metro Property Group received an email from a broker stating:

[Investor] just called me to inform that for the time being he will not buy the 5 properties.


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After checking the internet and the upcoming lawsuit he prefers to wait until more is clear, notwithstanding the very good opinion he holds on Metro.

The Llewellyn-Jones Intentionally Misrepresented Facts to Interfere with Metro Property Group’s Business Relationships

64. Many of the statements in the Llewellyn-Jones’ communications—

like the allegations in their Complaint—will be shown, through discovery and

dispositive motions, to be false.

65. The claim by the Llewellyn-Joneses that “[a]ll [homes sold by Metro

Property Group] have been subject to massive fines from the Detroit Housing

Commission” is blatantly false.

66. The claims by the Llewellyn-Joneses that the houses sold by Metro

Property Grout “[a]ll are virtually worthless on the open market” and that “[n]one

of them have produced a genuine rental income” are also demonstrably false.

67. The claim by the Llewellyn-Joneses claim that “[n]one of the houses

[sold by Metro Property Group] were refurbished” is demonstrably false. For

example, the following are photographs showing the rehabilitation of two of the

properties which are identified in Plaintiffs’ Complaint:


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COUNT I – DAMAGES FOR TORTIOUS INTERFERENCE WITH CONTRACTS, BUSINESS

RELATIONSHIPS AND BUSINESS EXPECTANCIES

68. The preceding paragraphs are repeated and realleged as if fully set

forth herein.

69. Metro Property Group has a valid business relationship or valid

expectation of a business relationship with its investors, potential investors and

business partners.

70. Kathryn Llewellyn-Jones and Mark Llewellyn-Jones have knowledge

of those business relationships or expected business relationships.

71. Kathryn Llewellyn-Jones and Mark Llewellyn-Jones have

intentionally interfered with the existing or potential business relationships in such

a manner as to induce a termination of the business relationships or expected

business relationships.

72. Metro Property Group has valid contractual relationships with

investors, potential investors and business partners.


of those contractual relationships.

74. Kathryn Llewellyn-Jones and Mark Llewellyn-Jones have

intentionally interfered with those contractual relationships in such a manner as to

induce third-party termination of the contracts.


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75. The actions of Counter-Defendants are wrongful and include

statements that are demonstrably false.

76. Metro Property Group has suffered damages as a result of Counter-

Defendants’ actions.

WHEREFORE, Metro Property Group respectfully requests that this

Honorable Court enter a judgment in the amount to which it is found to be entitled,

plus interest, costs, and attorney fees, as well as any other relief the Court deems

appropriate.

COUNT II – INJUNCTIVE RELIEF RELATING TO ONGOING TORTIOUS INTERFERENCE WITH CONTRACTS, BUSINESS RELATIONSHIPS AND BUSINESS EXPECTANCIES

77. The preceding paragraphs are repeated and realleged as if fully set

forth herein.

78. Metro Property Group has a valid business relationship or valid

expectation of a business relationship with its investors, potential investors and

business partners.


of those business relationships or expected business relationships.

80. Kathryn Llewellyn-Jones and Mark Llewellyn-Jones continue to

intentionally interfere with the existing or potential business relationships in such a


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manner as to attempt to induce a termination of the business relationships or

expected business relationships.

81. Metro Property Group has valid contractual relationships with

investors, potential investors and business partners.


of those contractual relationships.

83. Kathryn Llewellyn-Jones and Mark Llewellyn-Jones continue to

intentionally interfere with those contractual relationships in such a manner as to

induce third-party termination of the contracts.

84. The actions of Counter-Defendants are wrongful and include

statements that are demonstrably false.

85. Metro Property Group will incur additional damages and irreparable

harm if Counter-Defendants are not enjoined from further interference with Metro

Property Group’s extant and potential contracts and business relationships.

WHEREFORE, Metro Property Group respectfully requests that this

Honorable Court enter an Order barring Kathryn Llewellyn-Jones and Mark

Llewellyn-Jones from contacting, directly or indirectly, whether through direct

contact or by any means of publication, any individual or company with whom

Metro Property Group has a contract, a business relationships or an expectation of


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a business relationship, including Metro Property Group’s current and potential

business partners and investors.

Respectfully submitted,

Fink + Associates Law

/s/ David H. Fink _______ David H. Fink (P28235) Darryl Bressack (P67820) 100 West Long Lake Road; Suite 111 Bloomfield Hills, Michigan 48304

Dated: July 30, 2013 (248) 971-2500


CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on July 30, 2013, I electronically filed the

foregoing document with the Clerk of the Court using the ECF system, which will

send notification of such filing to all attorneys of record registered for electronic

filing.

FINK + ASSOCIATES LAW By: /s/David H. Fink David H. Fink (P28235)

100 West Long Lake Road, Ste. 111 Bloomfield Hills, MI 48304 (248) 971-2500/Fax: (248) 971-2600 [email protected]


IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF MICHIGAN

SOUTHERN DIVISION

KATHRYN LLEWELLYN-JONES, MARK LLEWELLYN-JONES, CAROLINE JONES, PETER GREEN, LESLEY GREEN, SAID FADEL a/k/a SAEED FADHL, WARREN GROVER, Civil Case No. 13-cv-11977 and MARGARET JOYCE GROVER, Plaintiffs, Hon. David M. Lawson vs. METRO PROPERTY GROUP, LLC, METROPROPERTY MANAGEMENT, LLC, GLOBAL POWER EQUITIES, LLC, APEX EQUITIES, LLC, SAMEER BEYDOUN, ALI BEYDOUN, TAREK MAHMOUD BAYDOUN, BAYDOUN LAW GROUP, PLLC, d/b/a THE MERIDIAN LAW GROUP, MIKE ALAWEIH, DAVID MAKKI, CHRIS PICCIURRO, KATHY MESSICS, GEORGE, ALLEN BROTHERS ATTORNEYS AND COUNSELORS PROFESSIONAL LIMITED LIABILITY COMPANY, JAMES ALLEN, and JOHN ALLEN, Defendants. METRO PROPERTY GROUP, LLC, Counter-Plaintiff, vs. KATHRYN LLEWELLYN-JONES, MARK LLEWELLYN-JONES Counter-Defendants. Deborah K. Schlussel (P56420) David H. Fink (P28235)) Law Office of Debbie Schlussel. Darryl Bressack (P67820) Attorneys for Plaintiffs/Counter-Defendants Fink + Associates Law 29477 Laurel Woods Drive Attorneys for Metro Property Group, LLC, Southfield, Michigan 48034 Metro Property Management, LLC, Global (248) 354-1409 Power Equities, LLC, Apex Equities LLC,

Sameer Beydoun, Ali Beydoun, Mike Alaweih, David Maki and Kathy Messics

100 West Long Lake Road; Suite 111 Bloomfield Hills, MI 48304

(248) 971-2500 [email protected] [email protected]

2:13-cv-11977-DML-RSW Doc # 8-1 Filed 07/30/13 Pg 1 of 2 Pg ID 187

COUNTER-PLAINTIFF METRO PROPERTY GROUP’S MOTION FOR PRELIMINARY INJUNCTION

INDEX OF EXHIBITS

Exhibit 1: Declaration of Kahlil Assad Exhibit 2: Letter from Edwin Schouten Exhibit 3: Letter from Larry Wright, Sr. Exhibit 4: Letter from Orlando Woods Exhibit 5: Letter from Reverend Stephen H. Bancroft Exhibit 6: Unpublished Opinions






June 24th, 2013

To Whom It May Concern:

My company has been METRO PROPERTY GROUP’S representative for over 2 years, during which period we have got joint clients who own up to more than 40 properties.

Undersigned has seen each and every single house that was sold to our customers and can only confirm that all houses have been renovated at the usual high standards.

Furthermore we have checked with all our customers individually about the level of satisfaction regarding the property management and the obtained results and everyone, without exception, is totally satisfied.

In addition we have seen the complete renovation pictures of the houses involved in the announced lawsuit and witnessed these houses were renovated at the usual high Metro standards as well.

Last but not least: during each and every visit, regardless of the (sometimes difficult) visitors, Metro staff has always been fully professional, cooperative and dedicated even in cases that a visit would not result in sales. Therefore we can without hesitation recommend METRO PROPERTY GROUP as a reliable and professional partner in business.

It goes without saying that we are at all times available for further clarification.

With kind regards,

Edwin Schouten

[email protected]

VastgoedAmerika / Americainvest (agent Netherlands, Belgium and others)



June 13, 2013 To Whom It May Concern: Re: Sameer Beydoun and Metro Properties My name is Larry Wright, Sr. and I am the managing partner of the Detroit Talent Hub. The Detroit Talent Hub is a limited, low profit corporation headquartered in Michigan with the explicit goals of helping Detroit residents to find sustainable employment. The DTH is a demand driven solution for connecting Detroiters to job opportunities in partnership with quality companies and organizations such as Metro Property Group. Together we are committed to Detroit's renaissance. We operate as an extension of these companies to help them meet a need for quality products or services. Our role is to develop a pipeline of qualified workers who can perform the work through local businesses like Metro Property Group as the talent Hub's employer partner. The Talent hub was launched in 2012 through an initial grant provided by the Detroit Regional Workforce Fund of United Way. I am proud to be part of a team of dedicated professional men and women who have spent the last two years developing a solution to creating jobs for our community, and now implementing the Talent Hub. In this case the Talent Hub is partnering with Metro and collaborating with local training organizations like WCCCD, DWEJ or others that have trained hundreds of workers for careers in energy, construction, health IT or other emerging fields to provide "finishing touch" training to qualify and hire trainees to perform the required work. We are also working to increase the number of small local contractors through providing training and technical assistance such as our work with over 25 contractors and entrepreneurs to boost their capacity for Metro work and create more jobs. Training is taught by our team of highly credentialed & licensed trades including electrical, mechanical, plumbing and carpenters who also coordinate and manage the work of subcontractors for Metro housing rehab projects.


Quality, committed companies like Metro are key to the success of Detroit's turnaround and our goal to create 1,000 jobs for Detroiters in 2013. The visionary force in developing our partnership with Metro has been Sameer Beydoun. He is a hard working, intelligent entrepreneur who also recognizes the intrinsic value of providing opportunities for the residents in the communities he serves. Sameer has brought honor and integrity coupled with a true sensitivity to help the Detroit Talent Hub. On a personal level, I have gotten to know Sameer over the past 9 months and I consider him a friend as well. Detroit is a better place, The Detroit Talent Hub is a more successful enterprise and Detroit residents have proven sustainable job opportunities because of Sameer Beydoun and Metro Properties Group. If you have any additional questions or desire any other information, please call me at 248-262-7617. Sincerely, Larry D. Wright, Sr Managing Partner Detroit Talent Hub



To Whom It May Concern:

Simply Building Solu Ions 32700 Northwestern H

Suite 640 Southfield, Michigan 48 75

248-262-7167

Re: Sameer Beydoun and Metro Property Group

Simply Building Solutions is the evolution of several succe sful enterprise initiatives of the partners that has resulted in the hiring of hundreds of m9tro Detroiters as well as the development of numerous small contractors and subs over thr past twenty years. In short SBS is an facilities and construction services .firm that prov des housing rehabilitation, facility, property maintenance and preservation services fI r business, corporate, nonprofit, financial, real estate and residential clients.

Our management team and partners are credentialed in ener y efficiency, environmental and construction trades and we have an available, qualified a d ready to work labor pool of hundreds of metro Detroit residents trained and credential d through leading programs including the Regional Energy Efficiency Partnership Train ng Program and Detroiters Working for EnvirOllli1entai Justice among others.

Significantly SBS is partnering with the Metro Property Gr up, the Detroit Talent Hub and Alkebu-Lan Village in a campaign to create 1,000 job for qualified workers over the next three years. This campaign is being launched throug providing energy, housing rehabilitation and property preservation services for Atl s Construction and Metro Property Group headed by Sameer Beydoun, a testimOl y to local entrepreneurial success. Over the past year we have grown to not only kn w but respect Sameer as a man of integrity who is committed to creating opportunities or all Detroiters to prosper through hard work and dedication.

Sameer' s story and passion for Detroit is an inspiration to 0 ers as he demonstrates his commitment though community partnerships, diversity in hiring, and investment in neighborhoods and people. In our dealings Sameer has alwa s been a principled person and business pminer that we are proud to be associated wi in our quest to serve our community and build a successful company.

We look forward to the opportunity to continue to make a dif erence in our community and the lives of others in partnership with Sameer and his ent rprise family.

Sincerely,

Orlando Woods, General Partner



The Very Rev’d Stephen H. Bancroft Dean, Cathedral Church of St Paul, Retired Detroit, Michigan

May, 30, 2013

To whom it may concern:

It has been brought to my attention by Sameer Beydoun that his company, Metro Property Group, is being sued by some former investors, claiming that he failed to perform the rehabilitation of the properties they bought from him. Furthermore, that the attorney of record is one Ms Debbie Schlussel, who doubles as a right-wing talk show host and blogger, who has made scurrilous, undocumented claims against Mr. Beydoun, insinuating that he supports radical Islamic terrorism.

While I am not privy to the particulars of the case, my experience with and investigation into Metro Property Group and their work, leads me to believe the law-suit is unfounded and is being pursued for reasons not related to their actual contractual performance.

I am personally aware of Metro Property Group’s business model, activity and performance. I have seen the quality of their restoration work on seriously distressed property, and the accusation of failed performance or unfair business practices is not credible. The idea that he could be managing a unique set of properties for a particular set of investors that has not been rehabbed to the level that all of the rest of Metro properties have been is ludicrous.

I am a practicing and committed Christian (an Episcopal priest) and have no interest in supporting Islam. In addition, I do have concerns about the practice of radicalized Islam. However, my experience with standard Americans who happen to hold to a traditional Islamic faith coupled with American principles and ideals (which is extensive) is far different from the scare-mongering image projected by certain political or religious extremists. Anyone who deals with Sameer and all of his partners and staff would find an accusation of religious or ethnic extremism absolutely absurd. This group is as American as they come. Their business practices are pristine. Their honesty and forthrightness are refreshing. Their commitment to their American heritage is unassailable.

I wish to personally express my belief that Sameer Beydoun and Metro Property Group are fair-minded, honest, and hard-working business people who have a sincere desire to reinvigorate their home town; provide decent, affordable housing to everyone regardless of ethnic or religious heritage; and provide their investors with a fair return on investment; while making a good living for themselves. Whatever personal faith they may carry or practice as non-radical Muslims is a non-issue in both their business and the personal relationships as I have experienced it.


Documents

Metro Property Group Detroit Vs Kathryn Llewellyn-Jones, Mark Llewellyn-Jones Lawsuit