An Open Letter to Gregory M. Meihn — TCR 22-12 Compliance

This letter was sent privately on October 1, 2026. It is published here after the 72-hour response window.

Sent: October 1, 2026 To: Gregory M. Meihn, Partner — Foley & Mansfield PLLP (gmeihn@foleymansfield.com) CC: MacDowell Preparatory Academy Board of Directors (info@macdowellprep.com); Artesia Washington, Board Treasurer Subject: MacDowell Preparatory Academy / Purpose Charter Academy — TCR 22-12 Compliance Concerns — Notice to Board of Directors Attachments: TCR 22-12 Final Decision and Order; MDE FOIA response documents; LARA entity filings

Mr. Meihn,

My name is Kevin Mok. I am the plaintiff in two civil cases filed in Ingham County Circuit Court: Case Nos. 2026-4301-CZ and 2026-4349-CZ. Case 4349-CZ names Brian Banks individually, Joseph Holland Jr., Tracey Ellis, The Purpose Group LLC, Purpose Charter Academy, and Purpose Foundation as defendants. I am writing to you in your capacity as legal counsel to the MacDowell Preparatory Academy Board of Directors, and I am copying the Board directly because this notice concerns the Board’s own compliance obligations.

I have reviewed the Final Decision and Order in TCR 22-12, issued August 4, 2023, by State Superintendent Michael F. Rice. I received this document directly from the Michigan Department of Education FOIA Coordinator on September 30, 2026. I have also reviewed your testimony at the hearing on February 9, 2023.

I am writing because your client’s superintendent, Brian Banks, has engaged in conduct since that hearing that directly contradicts the testimony you, and others, provided under oath — and that may place your client, the MacDowell Board, in breach of TCR 22-12’s conditions.

I. Your Testimony vs. Subsequent Conduct

At the hearing, you testified that Mr. Banks demonstrates “integrity, hard work, honesty, transparency, and compliance.” You called him a “rare find.” You testified that you meet with him weekly.

Since that testimony:

1. On September 9, 2026, Mr. Banks told Detroit Police officers “I am a lawyer” in a sworn police report (DPD Report #26-0909-0176). Mr. Banks has never been admitted to any bar. This is a false statement in a government document and constitutes unauthorized practice of law under MCL 450.681.

2. On August 29, 2026, Mr. Banks denied a legal father’s authorized representative access to Purpose Charter Academy, using this false legal authority to justify the denial. The Affidavit of Parentage is undisputed — the mother has acknowledged it in her own filings.

3. Mr. Banks’s Management Agreement between Purpose Group LLC and PCA contains a representation at Section 5.2 stating “No Related Parties or Common Control.” Mr. Banks is the sole member of Purpose Group LLC AND the superintendent of PCA. This representation is false on its face.

4. Mr. Banks is the sole member of Purpose Group LLC, which received $4,285,201 (72.67%) of MacDowell’s total revenue in FY2024-25. As sole member, Mr. Banks has sole authority over Purpose Group’s expenditures. Mr. Holland — Banks’s domestic partner, who resides at the same address and holds the positions of Secretary/Treasurer of Purpose Foundation, Treasurer of the Bank on Banks for Michigan PAC, and 1st Successor Trustee of the Brian Banks Living Trust — does not appear to provide any independent financial oversight of Purpose Group LLC. The entity structure concentrates all financial control in Banks and Holland, both of whom have criminal convictions. I respectfully ask whether this arrangement complies with Condition #4 of TCR 22-12, which provides that Mr. Banks “shall not be the sole individual responsible for approval of any expenditure of funds belonging to the school.”

II. The Other Witnesses

Your testimony was not the only basis for the certificate. Two other professionals testified:

• Terrence Shulman, LMSW — a licensed social worker and self-described recovering theft addict whose practice is built on the premise that theft is addiction, not character. His testimony that Mr. Banks is “not dishonest as a matter of character” is his therapeutic framework applied to every client — it is not an independent clinical assessment. Mr. Shulman cannot diagnose PTSD under the DSM-5. He is not a physician or psychiatrist.

• Michele Leno, Ph.D. — a psychologist whose doctorate is from Saybrook University, a low-residency program. Her clinical specialty is performance anxiety in athletes and social media effects on mental health — not PTSD, not forensic psychology, not criminal recidivism assessment. She assessed Mr. Banks in approximately 13 sessions over 2 months and concluded he is “a person of integrity” who will not reoffend. Three years later, Mr. Banks told police he is a lawyer. She provides court-ordered psychological evaluations in Wayne County.

The “diagnoses” offered by these professionals are not clinical diagnoses in the medical sense. No psychiatric evaluation by a physician was conducted. No standardized diagnostic instruments are referenced in the record. These are character references with clinical language — verbal agreements between professionals outside the medical diagnostic field.

III. Banks and Holland — The Enterprise, Not Just One Man

The conduct described above is not limited to Mr. Banks acting alone. Case 4349-CZ names six defendants because the evidence shows an interconnected enterprise:

• Banks individually committed the UPL, made false statements to police, and denied parental access.

• Banks through Purpose Group LLC controls 72.67% of MacDowell’s revenue as the LLC’s sole member. The Management Agreement’s false “No Related Parties” representation (Section 5.2) means Purpose Group LLC is Banks’s alter ego — the entity through which he exercises personal control over school operations while claiming corporate separation.

• Banks and Holland jointly control Purpose Foundation (Banks = President/Director; Holland = Secretary/Treasurer — two convicted felons holding all four officer positions with zero independent oversight). They co-own property, share the same residence, and Holland serves as 1st Successor Trustee of the Brian Banks Living Trust.

• Tracey Ellis is named as a financial officer of both Purpose Group LLC and Purpose Foundation. The Board should be aware that any financial officer participating in the flow of public school funds through these entities is a participant in the structure I have described.

This distinction matters because the Board’s exposure is not limited to Banks’s personal misconduct. If the entity structure through which Banks operates the school is itself fraudulent — if Purpose Group LLC is Banks’s alter ego, if the Management Agreement contains a false representation, if Condition #4 is being circumvented through corporate form — then the Board’s authorization of that structure creates its own liability.

IV. Your Obligation to the Board

Your client is the MacDowell Preparatory Academy Board of Directors — not Mr. Banks personally. The Board relied on your guidance when it voted unanimously to hire Mr. Banks as superintendent. You testified at the TCR 22-12 hearing to support that decision.

The conduct I have documented places the Board in a position of potential liability:

• If Condition #4 is being circumvented through the Purpose Group LLC structure, the Board’s compliance verifications to MDE (signed by Board President Nicole Wells-Stallworth every six months per Condition #7) may be inaccurate.

• If Mr. Banks made false statements to police while serving as superintendent, and the Board was not informed, the Board’s oversight of Mr. Banks is compromised.

• If the Management Agreement contains a false representation and the Board’s attorney reviewed or approved that agreement, the Board’s legal exposure extends beyond Mr. Banks’s personal conduct.

I am providing this notice so that you — as counsel to the Board — and to the Board members directly, so that you can make fully informed decisions about the Board’s compliance posture and exposure. I have no interest in harming MacDowell’s students. I have every interest in ensuring that the people responsible for their education are held to the standards they testified they would meet.

V. Attached Documents

Enclosed with this email:

1. TCR 22-12 — Final Decision and Order, State Superintendent Michael F. Rice, August 4, 2023 (received from MDE FOIA Coordinator, September 30, 2026)
2. MDE FOIA response documents including MOECS records and credentialing correspondence
3. LARA entity filings for Purpose Group LLC and Purpose Foundation

These are the same documents in my possession that form part of the evidence in the civil cases referenced above.

VI. Public Record

My investigation is documented at detroit.primals.eco. Every claim is sourced to public records. The site includes the TCR 22-12 decision, your testimony, and a side-by-side comparison of what was said at the hearing versus what has occurred since. The evidence repository is also available at git.primals.eco. This information is part of the evidence in both civil cases.

I am also filing a formal complaint with the Michigan Department of Education regarding these matters today.

I welcome a response from your office or from the Board directly. I can be reached at the contact information below.

Respectfully,

Kevin Mok 4422 Southgate Ave Lansing, MI 48910 (586) 453-7233 mokkevin@msu.edu

Evidence: detroit.primals.eco Source repository: git.primals.eco

Response Status

Any response from Mr. Meihn or the MacDowell Board of Directors will be published here in full.