1200 FRANK MURPHY HALL OF JUSTICE

KYM L. WORTHY 1441 ST. ANTOINE STREET

PROSECUTING ATTORNEY DETROIT, MICHIGAN 48226-2302
TEL: (313) 224-5777; FAX: (313) 224-7412;
RICHARD M. HATHAWAY
FORFEITURE UNIT TEL: 313-224-5831;
CHIEF ASSISTANT
VSU TEL: 313-224-8045
COUNTY OF WAYNE WCPOWFU@waynecounty.com
DARYL M. CARSON
CHIEF OF STAFF OFFICE OF WCPOVSU@waynecounty.com
THE PROSECUTING ATTORNEY
DETROIT, MICHIGAN

[Page 1 of 2; PbK: 163- 2023871126] DATE: Mar. 16, 2023

OUT-OF-COURT SETTLEMENT AGREEMENT FOR RELEASE OF VEHICLE
SEIZED FOR ALLEGED USE IN VIOLATION OF
DRAG-RACING PUBLIC NUISANCE ABATEMENT LAWS
Vehicle Owner: Defrazio Hrant Morgan Jr., by & through attorney Ramy I. Hijazi (P82830)
Vehicle Description: 2017 DODGE CHARGER
VIN: 2C3CDXGJXHH606474 (MI Lic. Plate: EPB7404)
Seizing/Police Agency: Detroit Police Dept._ Seizure Date: Mar. 5, 2023
Police Case: 230305-0219; 23-DET/DRG-14906 [Citation: U659-418-23*] *for reference only
The above noted vehicle was allegedly used by you, Defrazio Hrant Morgan Jr., in a public street or
place in Wayne County according to police reports and seized on the above date by the above police agency for
an alleged violation of Michigan public nuisance abatement laws pursuant to MCL 600.3801, et seq., common
law public nuisance abatement, and/or Wayne County Ordinance No. 2000-328 Chapter 207 Sec. 6 which
forbid drag-racing or aiding and abetting drag racing (as defined therein) and subject the vehicle to nuisance
abatement, including forfeiture/sale.
You, Defrazio Hrant Morgan Jr., acknowledge you are owner of the seized vehicle with full
authority to enter into this settlement and have received notice of the vehicle seizure. You, as owner,
understand your rights, including the right to: obtain your own legal counsel at your own expense (as you
have done with Ramy I. Hijazi – P82830), contest the vehicle’s seizure, have the Wayne County
Prosecutor’s Office file a civil public nuisance abatement and/or forfeiture case with the court of
competent jurisdiction, obtain discovery and evidence pursuant to Michigan Court Rules, and have your
claims or defenses heard and present evidence in support thereof at a trial or hearing in a court of law and
equity. You, as owner, freely, knowingly, and voluntarily agrees to discharge, forego, release, relinquish,
and waive these rights, enter into this out-of-court settlement agreement, not contest the vehicle seizure,
and pay towing and storage charges subject to all terms herein for the vehicle’s release.
The Claimant/ Owner agrees to freely and voluntarily pay a final non-refundable/non-
returnable settlement fee of $450.00 made payable as instructed to the Wayne County Prosecutor’s
Office for Plaintiff/People of Michigan, to be remitted to the seizing agency. In exchange for this
settlement payment and all terms herein, the Wayne County Prosecutor’s Office authorizes release of the above
vehicle and related impound lien. The owner is responsible for costs of towing and storage to the
impound company/Police Dept., not to exceed the amount due as of/on Mar. 13, 2023.

OWNER’S/Attorney’s SIGNATURE: ___________________________________ Date: ___________ Page 1 of 2

 OUT-OF-COURT SETTLEMENT AGREEMENT FOR RELEASE OF VEHICLE
SEIZED FOR ALLEGED USE IN VIOLATION OF
DRAG-RACING PUBLIC NUISANCE ABATEMENT LAWS
[Page 2 of 2; PbK: 163- 2023871126]
Vehicle Owner: Defrazio Hrant Morgan Jr., by & through attorney Ramy I. Hijazi (P82830)
Vehicle Description: 2017 DODGE CHARGER
VIN: 2C3CDXGJXHH606474 (MI Lic. Plate: EPB7404)
Seizing/Police Agency: Detroit Police Dept._ Seizure Date: Mar. 5, 2023
Police Case: 230305-0219; 23-DET/DRG-14906 [Citation: U659-418-23*]* for reference only
Should another violation of said nuisance abatement laws for drag racing involving this or another
vehicle owned/leased by you and driven by you, or another person, any future settlement fee may be
increased or forfeiture of the vehicle sought.
This out-of-court settlement precludes any further legal action in this case regarding the vehicle and
the parties hereto and constitutes final terms of settlement and full accord and satisfaction in lieu of and in
closing of all civil claims of liability related to this matter upon the signing of this agreement. Furthermore,
in exchange for the release of the vehicle, you-the owner, for yourself and any successor and/or assign,
hereby waives, releases, relinquishes, and discharges Wayne County and its present and former employees,
officers, representatives, successors or assigns from any and all known or unknown claims, complaints,
appeals, grievances, liabilities, obligations, promises, agreements, damages, causes of action, debts,
demands, controversies, costs, losses and expenses whatsoever, under any local, state, or federal law,
common law or statutory, legal or equitable, related to, concerning, or arising out of any injury, damage,
loss, or expense incurred in connection with, or relating in any manner to, the seizure, towing or storage of
the vehicle and/or the validity of this Agreement and the final non-refundable/non-returnable settlement
payment. Nothing contained in this Agreement shall constitute an admission of liability by Wayne County,
its present and former employees, officers, representatives, successors or assigns. Both parties to this
agreement hold each other harmless and will defend this agreement against any claims or causes contrary
hereto. This vehicle seizure settlement is separate, distinct, and independent from, has no effect on, is
unaffected by, and is not an admission of guilt or liability for, any criminal charges or ordinance violations
related to or arising from the same incident.
The following parties freely, knowingly and voluntarily agree to all above terms/conditions:

Owner’s Signature: _______ ___ DATE: ____________

DEFRAZIO HRANT MORGAN JR., as Owner, owner [by and through Attorney Ramy I. Hijazi (P82830)]
16072 Ellsworth St., Detroit, MI 48227; 313-652-5849

Attorney’s Signature: ______________________________ DATE: _______________

RAMY I. HIJAZI (P82830), via rihijazi@trafficcourtbuddy.com ;
1348 N. Evangeline St., Dearborn Heights, MI 48127; 313-539-8844
WHEN SETTLEMENT FEE PAID, RELEASE VEHICLE FOR TOWING/STORAGE FEES
[Plaintiff Attorney fees of $50.00 will be reimbursed/paid for by seizing agency.]
Respectfully Submitted,
KYM L. WORTHY, Wayne County Prosecutor
JOE JANSEN, Chief, Special Operations
CHARLES DAVIS, Prin. Pros Atty., Forfeiture Unit
Wayne County Prosecutor’s Office Authorized Signature: ___________________________
[PbK: 163- 2023871126] Print Authorizing name: ___________________________

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