Notice of Proposed Class Action Settlement Agreement

Notice of Proposed Class Action Settlement Agreement To: All tenants and former tenants of Gadsden Manufactured Housing Communities, LLC, who were charged without proper notice, together with tenants and former tenants who were charged a fee for water and/or septic services without a contractual obligation to pay such charges. This includes tenants and former tenants of the following properties: Sontera Acres: 3901 Calle De Las Margaritas, Las Cruces, NM 88005 Rivas South- 3889 Calle De Las Margaritas, Las Cruces, NM 88005 JJ's Mobile Home Park: 1640-60 Burke Road, Las Cruces, NM 88007 J's Mobile Manor: 365 Karen Avenue, Las Cruces, NMM 88007 Notice is given that a settlement agreement has been reached in the class action case of Chavez v. Gadsden Manufactured Housing Communities, LLC Case No. D-307-CV-2023-00469 ("Lawsuit"). The Lawsuit, filed by Norma Chavez on behalf of herself and all similarly situated individuals, alleges that Gadsden charged tenants and former tenants late fees without proper notice and fees for water and/or septic services without a contractual obligation to pay such charges. The parties have reached a proposed settlement agreement, which the Court has preliminarily approved. The key terms of the settlement are as follows: Settlement Amount: Gadsden will pay a total of $330,000.00, distributed as follows: $50,000.00 to Norma Chavez. $105,000.00 to Holt & Mason, P.C. for attorneys' fees. $175,000.00 to the Class, with any unclaimed funds to be donated to Mesilla Valley Community of Hope. Release of Claims: Class members who do not opt out will release Gadsden from all claims related to the assessment of charges for water/septic services and late fees without proper notice, through June 10, 2025. Opt-Out Rights: Class members have the right to exclude themselves from the settlement. To opt out, you must submit a written request for exclusion, including your name, address, phone number, and a clear statement of your intent to be excluded, by the deadline set by the Court. The written request should be sent to Gadsden's counsel by regular mail to: Modrall Sperling Law Firm, P.O. Box 2168, Albuquerque, NM 87103-2168, or by email to: sle@modrall.com; or sent to class counsel by regular mail to: Holt & Mason, P.C., P.O. Box 16495, Las Cruces, NM 88004 or by email to: emma@legalmindsnm.com. A Fairness Hearing will be held on January 6, 2026, at 9:00 a.m. to determine the final approval of the settlement. Class members who do not opt out may object to the settlement and present evidence at the hearing. Your Rights and Options Do Nothing: If you do nothing, you will remain a part of the Class, and you will receive a share of the settlement funds if the Court grants final approval. You will also release your claims against Gadsden. Opt Out: If you do not wish to be bound by the settlement, you must opt out by submitting a written request for exclusion by the deadline. If you opt out, you will not receive any benefits from the settlement, and you will retain your right to pursue your own legal action against Gadsden. Object: If you wish to object to the settlement, you must file a written objection with the Court before the fairness hearing. You may also appear at the hearing to present your objection. If you wish to be represented by your own attorney, you have the right to do so. You may have an attorney enter an appearance in the case on your behalf. For more information about the settlement, including the full terms of the Settlement Agreement, please contact the attorneys representing the Class: Holt & Mason, P.C., P.O. Box 16495 Las Cruces, NM 88004, Telephone: (575) 288-5671, Email: emma@legalmindsnm.com. Para español, llama (575) 281-1332 o mande un correo electronico: office@legalmindsnm.com. This notice is intended to inform you of the proposed settlement and your rights as a potential class member. Please review this notice carefully and consider your options. If you have any questions, you may contact the attorneys listed above. Please note: This notice is a summary of the proposed settlement. The full terms of the Settlement Agreement are available for review upon request. MODRALL, SPERLING, ROEHL, HARRIS & SISK, P.A. By: /s/ Spencer L. Edelman Spencer L. Edelman Tomas J. Garcia Attorneys for Gadsden Post Office Box 2168 Albuquerque, New Mexico 87103-2168 Telephone: 505.848.1800 October 8, 15, 22 2025 LACO0382570