Settlement Draft Timeline¶

Summary of Settlement Agreement Versions 1. February 11, 2025 – Initial Draft Date: February 11, 2025 Drafter: Brett Ledermeier (MMAT Law) Details: This version was sent to Sarah Zeeman for review and revisions. It was also circulated to opposing counsel and Stewart Title. The draft included Stewart in the "Zeeman" defined term and was prepared for signature lines as needed. The agreement was lengthy and detailed, aiming to cover all bases. Reference: 25-02.11.25- Settlement and Mutual Release.docx RE: Zeeman Settlement.msg, RE: Updated Suvey.msg 2. March 19–20, 2025 – Redlined Revisions by Lisa Rose Date: March 19–20, 2025 Drafter: Lisa Rose (Rose Litigation, LLC) Details: Lisa Rose sent her redlined revisions to the draft settlement agreement, requesting comments from Brett Ledermeier. The survey was finalized, and obligations for fence relocation were highlighted. Reference: 25-02.11.25- Settlement and Mutual Release.v1 redlined LKR.docx RE: revisions to Settlement Agreement re: Sweatman v Zeeman.msg, Re: revisions to Settlement Agreement re: Sweatman v Zeeman.msg 3. April 4, 2025 – Redlined Version Date: April 4, 2025 Drafter: Brett Ledermeier (MMAT Law) Details: This redlined version incorporated comments and edits from both parties. It addressed the new boundary line, corrective conveyance deeds, lender notification, fence relocation, and an easement agreement. The agreement resolved all claims and disputes related to the boundary line and other issues. Reference: 25-04.04.25- Settlement and Mutual Release. Redlined.docx 25-04.04.25- Settlement and Mutual Release. Redlined.docx, RE: revisions to Settlement Agreement re: Sweatman v Zeeman.msg, RE: revisions to Settlement Agreement re: Sweatman v Zeeman.msg 4. June 23, 2025 – Additional Revisions Date: June 23, 2025 Drafter: Brett Ledermeier (MMAT Law) Details: This version included additional revisions and further clarified the parties’ obligations, including the execution of corrective quitclaim deeds, lender notification, fence relocation, and the easement agreement. It also included provisions for attorneys’ fees, modification, and binding effect. Reference: 25-06.23.25- Settlement and Mutual Release. Additional Revisions.docx 25-06.23.25- Settlement and Mutual Release. Additional Revisions.docx 5. June 24–25, 2025 – Revised Version (Version 4) Date: June 24–25, 2025 Drafter: Brett Ledermeier (MMAT Law), with input from Lisa Rose (Rose Litigation, LLC) Details: This version, referred to as "Version 4," included both a redlined and a clean version. It was circulated for final review and approval. Jonathan Sweatman approved this version, and Lisa Rose sent it to Brett Ledermeier for any final questions or concerns. The agreement included all prior revisions and was close to being finalized. Reference: 25-06.24.25- Settlement and Mutual Release. Revised.v4.docx, 25-06.24.25- Settlement and Mutual Release. Revised.v4 CLEAN VERSION.docx RE: revisions to Settlement Agreement re: Sweatman v Zeeman.msg, 25-06.24.25- Settlement and Mutual Release. Revised.docx, RE: revisions to Settlement Agreement re: Sweatman v Zeeman.msg, RE: Settlement Agreement Update Request - STGC: 328015 Zeeman.msg 6. June 25, 2025 – Final Revised Version Date: June 25, 2025 Drafter: Brett Ledermeier (MMAT Law) Details: This version was circulated as the most recent draft for review by all parties, including Stewart Title. It included all prior changes and was intended to be the final version pending any last comments or required revisions. Reference: 25-06.24.25- Settlement and Mutual Release. Revised.docx 25-06.24.25- Settlement and Mutual Release. Revised.docx, RE: Settlement Agreement Update Request - STGC: 328015 Zeeman.msg, RE: revisions to Settlement Agreement re: Sweatman v Zeeman.msg

Additional Notes Throughout the process, both Brett Ledermeier and Lisa Rose were actively involved in drafting, revising, and negotiating the terms of the settlement agreement. The versions reflect ongoing negotiations, with input from clients and third parties (such as Stewart Title and the City/County). The June 24–25, 2025, version (Version 4) and the June 25, 2025, revised version appear to be the most recent and comprehensive drafts, incorporating all prior revisions and feedback. If you need a more detailed breakdown of the substantive changes between versions, please specify which versions you would like compared.