State of North Carolina In the General Court of Justice
Superior Court Division
County of Jones Case No: 21 CvS 134 510
Carolina Lease Management Group, LLC v. Charles Greene
Charles Greene, on behalf of himself and all others similarly situated,
v. Carolina Lease Management Group, LLC
Class Action Notice
Authorized by the Superior Court for Jones
County, North Carolina
Did you enter a There is a 1 If you want to be
rent-to-own million dollar part of the class
agreement for a settlement of a action, you do not
storage building lawsuit. need to do
with Carolina anything.
Lease You may be
Management entitled to If not, you need to
Group & they money. opt out by January
tried to collect 7, 2026.
from you on or
after April 8,
2017, and on or
before March 9,
2018?
Important things to know:
• If you take no action, you will be bound by the settlement, and your rights
will be affected.
• You can learn more and find Court documents at: www.greene-
clmgsettlement.com.
Table of Contents
Table of Contents ....................................................................................................... 2
About This Notice ...................................................................................................... 3
Why did I get this notice? ................................................................................................. 3
What do I do next? ............................................................................................................ 3
What are the most important dates? ............................................................................. 3
Learning About the Lawsuit ..................................................................................... 4
What is this lawsuit about? .............................................................................................. 4
Why is there a settlement in this lawsuit? ..................................................................... 4
What happens next in this lawsuit?................................................................................ 4
Learning About the Settlement ............................................................................... 5
What does the settlement provide? ............................................................................... 5
How much will my payment be? ..................................................................................... 6
Deciding What to Do .................................................................................................. 6
How do I weigh my options? ........................................................................................... 6
What is the best path for me? ......................................................................................... 7
How do I get a payment if I am a class member?......................................................... 8
Do I have a lawyer in this lawsuit? .................................................................................. 8
Do I have to pay the lawyers in this lawsuit? ................................................................ 8
Opting Out .................................................................................................................. 9
What if I don't want to be part of this settlement?....................................................... 9
How do I opt out? ............................................................................................................. 9
Objecting..................................................................................................................... 9
What if I disagree with the settlement? ......................................................................... 9
Key Resources .......................................................................................................... 10
How do I get more information? .................................................................................. 10
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About This Notice
Why did I get this notice?
A class action counterclaim was filed, Greene v. Carolina Lease
Management Group, LLC., brought on behalf of people who entered
rent-to-own contracts with Carolina Lease Management Group (CLMG)
and from whom CLMG tried to collect money. You received this
notice because you may be a member of the group of people
affected, called the “class.” This notice gives you a summary of the
terms of the proposed agreement, explains what rights class members
have, and helps class members make decisions about what action to
take.
What do I do next?
Read this notice to understand the settlement and to determine if you
are a class member. Then, decide which of these actions you want to
take:
Options What each option means:
Do Nothing (or You will receive a check at the address where you
provide specific received this notice. You will be bound by the
payment info) settlement. If you’d like payment in another form, you
can submit that information on the website.
Opt Out Get no payment. Allows you to bring another lawsuit
against Carolina Lease Management Group about the
same issues.
Object Tell the Court why you don’t like the settlement.
Read on to understand the specifics of the settlement and what each
choice would mean for you.
What are the most important dates?
Your deadline to object: January 2, 2026.
Your deadline to opt out: January 7, 2026.
Settlement approval hearing: January 22, 2026 at 10:00 a.m.
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Learning About the Lawsuit
What is this lawsuit about?
When Carolina Lease Management Group,
Where can I learn
LLC sued Charles Greene to recover a shed
more?
he was buying under a rent-to-own
You can get a complete
agreement, he filed a class counterclaim
copy of the proposed
asserting that Carolina Lease Management
settlement and other key
Group, LLC, violated North Carolina laws
documents in this lawsuit
regarding how much they could charge on his
at: www.greene-
and similar agreements.
clmgsettlement.com
Carolina Lease Management Group denies
that it did anything wrong.
Why is there a settlement in this lawsuit?
In April 2025, the parties agreed to settle,
What is a class action
which means they have reached an
agreement to resolve the lawsuit. Both sides
settlement?
want to avoid the cost and risk of continuing A class action settlement is
the case in court. an agreement between
the parties to resolve and
The settlement is for Mr. Greene and all end the case. Settlements
members of the settlement class. The Court can provide money to
has not decided this case in favor of either class members and
side. changes to the practices
that caused the harm.
What happens next in this lawsuit?
The Court will hold a Fairness Hearing to decide whether to approve
the proposed settlement. The hearing will be held at:
Where: Jones County Courthouse, Superior Court, at 101 Market
Street, Trenton, North Carolina, 28585.
When: 10:00 a.m. on January 22, 2026.
The Court has directed the parties to send you this notice about the
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proposed settlement. Because the settlement of a class action decides
the rights of all members of the proposed class, the Court must give
final approval to the settlement before it can take effect. Payments will
only be made if the Court approves the settlement.
You do not have to attend the hearing, but you may at your own
expense. You may also ask the Court for permission to speak and
express your opinion about the settlement. If the Court does not
approve the settlement, it will not take effect and the lawsuit will
continue. The date of the hearing may change without further notice
to members of the class. To learn more and confirm the hearing date,
go to www.greene-clmgsettlement.com.
Learning About the Settlement
What does the settlement provide?
Carolina Lease Management Group has agreed to pay $1,001,671.13
into a settlement fund. This money will be divided among the class
members and will also be used to pay for costs and lawyer fees
approved by the Court, and for the cost of administering this
settlement. Members of the settlement class will “release” their claims
as part of the settlement, which means they cannot sue Carolina Lease
Management Group for the same issues and legal violations raised in
this lawsuit. The full terms of the release can be found at www.greene-
clmgsettlement.com.
The settlement also requires Carolina Lease Management Group to
stop all debt collection and lawsuits on class member accounts related
to this case and to cancel any judgments on these accounts.
The settlement also provides that the Court will be asked to approve
payments of $10,000 to Charles Greene, who brought this lawsuit, to
compensate him for his work on the case. This payment is called a
"service payment."
If there is money left over after all payments are made, it will be
distributed in accordance with G.S. § 1-267.10.
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How much will my payment be?
Your payment amount will depend on the following factors:
• The amount you paid to CLMG between April 8, 2017, and March 9,
2018, on the rent-to-own contract.
• The amounts that other class members paid to CLMG during those
same dates, on their rent-to-own contracts.
• The amount of the lawyer fees, costs, and service payments
approved by the Court.
Deciding What to Do
How do I weigh my options?
You have three options. You can do nothing and stay in the settlement,
you can opt out of the settlement, or you can object to the settlement.
This chart shows how your rights are affected by each option:
Do
Opt out Object
nothing
Can I receive settlement
YES NO YES
money if I . . .
Am I bound by the terms
YES NO YES
of this lawsuit if I . . .
Can I pursue my own
NO YES NO
case if I . . .
Will the class lawyers
YES NO NO
represent me if I . . .
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What is the best path for me?
Are you satisfied with the
proposed settlement?
Yes
No
Do nothing & receive Do you want to file
a payment your own lawsuit or
not be bound by this
lawsuit?
Yes No
Opt out of
the I don't like the
settlement proposed
settlement
Object in
writing*
*You can object to the settlement AND receive payment.
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How do I get a payment if I am a class member?
If you wish to receive a check mailed to the address where you
received the postcard letting you know about this settlement, you can
do nothing. If you wish to receive a payment by some other method,
you can make that request on www.greene-clmgsettlement.com by
January 22, 2026.
Do I have a lawyer in this lawsuit?
In a class action, the court appoints lawyers to work on the case and
represent the interests of all the class members. For this settlement,
the Court has appointed the following lawyers.
Your lawyers: Adrian Lapas, Lapas Offices, PLLC and Charles Delbaum
and Jennifer Wagner, National Consumer Law Center. These are the
lawyers who negotiated this settlement on your behalf.
If you want to be represented by your own lawyer, you may hire one at
your own expense.
Do I have to pay the lawyers in this lawsuit?
Lawyers' fees and costs will be paid from the Settlement Fund. You
will not have to pay the lawyers directly.
To date, your lawyers have not been paid any money for their work or
the expenses they have paid for the case. To pay for some of their
time and risk in bringing this case without any guarantee of payment
unless they were successful, your lawyers will request, as part of the
final approval of this Settlement, that the Court approve a payment of
up to $330,551.47 total in attorneys’ fees plus the reimbursement of
out-of-pocket expenses.
Lawyers' fees and expenses will only be awarded if approved by the
Court as a fair and reasonable amount. You have the right to object to
the lawyers' fees even if you think the settlement terms are fair.
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Opting Out
What if I don't want to be part of this settlement?
You can opt out. If you do, you will not receive payment and cannot
object to the settlement. However, you will not be bound or affected
by anything that happens in this lawsuit and may be able to file your
own case.
How do I opt out?
To opt out of the settlement, you must complete the opt out form
available on the case website, www.greene-clmgsettlement.com and
mail it by January 7, 2026 to the Settlement Administrator at:
Greene v. CLMG Class Action
c/o Settlement Administrator
PO Box 23680
Jacksonville, FL 32241-3680
(800) 501-9615
Be sure to include your name, address, telephone number, and
signature.
Objecting
What if I disagree with the settlement?
If you disagree with any part of the settlement (including the lawyers'
fees) but don’t want to opt out, you may object. You must give reasons
why you think the Court should not approve the settlement and say
whether your objection applies to just you, a part of the class, or the
entire class. The Court will consider your views. The Court can only
approve or deny the settlement — it cannot change the terms of the
settlement. You may, but don’t have to, hire your own lawyer to help
you.
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To object, you must mail your letter to the Clerk of Court. Your letter
must:
(1) be postmarked or filed with the Clerk of Court by January 2, 2026;
(2) include the case name and number: Greene v. Carolina Lease
Management Group, LLC, 21 CvS 134 510;
(3) include your full name, address and telephone number, and email
address (if you have one);
(4) state the reasons for your objection;
(5) say whether you or your lawyer intend to appear at the final
approval hearing and your lawyer's name;
(6) be signed by you.
Mail the letter to:
Jones County Clerk of Superior Court
Attn: Civil Division
Post Office Box 280
Trenton, NC 28585
Key Resources
How do I get more information?
This notice is a summary of the proposed settlement. The complete
settlement with all its terms can be found on the case website. To get a
copy of the settlement agreement or get answers to your questions:
• contact the Settlement Administrator (information below)
• visit the case website at www.greene-clmgsettlement.com
Resource Contact Information
Case website www.greene-clmgsettlement.com
Settlement Greene v CLMG Class Action
Administrator PO Box 23680
Jacksonville, FL 32241-3680
(800) 501-9615
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Your Lawyers Adrian M. Lapas
Lapas Law Offices, PLLC
P.O. Box 10688
Goldsboro, NC 27532
Charles Delbaum
Jennifer Wagner
National Consumer Law Center
7 Winthrop Square
Boston, MA 02110
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