CJ-2025-5166 - Willa Mae Delgado v. Chirag Desai

What's This Case About?

Let’s get one thing straight: Willa Mae Delgado didn’t just survive a hotel fire—she survived a death trap disguised as a budget-friendly stay at the Homestay Inn & Suites in Tulsa, where the fire escape was permanently sealed shut like it was just another Tuesday, and the only working sprinkler system was the one in the owners’ imaginations. This isn’t negligence. This is arson by apathy.

Willa Mae Delgado, a 67-year-old woman with asthma and a cane, checked into the Homestay Inn & Suites on November 9, 2023, expecting a quiet night in a modest room. What she got instead was a front-row seat to horror. She wasn’t just a guest—she was an invitee, legally entitled to a safe environment, and instead found herself trapped in a building that had all the fire safety of a cardboard box in a bonfire. The defendants? A tangled web of individuals and shell companies with names you’d expect in a real estate LLC bingo game: Chirag Desai, Ravina Desai, Pramodkumar B. Patel, Smitaben P. Patel, Neil Shah, Sabarmati, Inc., Manvear, LLC, and Kiana, LLC. On paper, they’re a corporate maze. In reality, they’re the people who allegedly turned a three-story hotel into a human pressure cooker.

Here’s how the night went: Around 8 or 9 p.m., flames erupted somewhere in the building. Smoke began to pour into the hallways and stairwells. Willa Mae, already compromised by her asthma and mobility issues, joined other guests trying to flee down the stairs from the second floor. They all headed toward what should’ve been the emergency exit—the fire door at the bottom of the stairwell. But when they got there? Locked. Sealed. Permanently. According to the petition, the owners had boarded it up to keep vagrants out. Never mind that it also kept paying guests in. In a fire. With no other way out. The stairwell became a smoke-filled chokehold. Willa Mae couldn’t breathe. Panic set in. And then, in the chaos, she was shoved—violently—into that sealed door by other desperate guests, leaving her with deep bruising on her arms. She was trapped. Not by the fire, not by the smoke, but by a decision—a cold, calculated choice to block off the one path that could’ve saved lives.

Eventually, the Tulsa Fire Department arrived and got everyone out through the main lobby. But the trauma didn’t end there. Once outside, Willa Mae saw her friend—another guest who had been staying on the third floor—on fire. He died later in the hospital. She didn’t just lose her sense of safety that night. She lost a friend. And she’s now left with smoke inhalation, emotional distress, physical injuries, and a story so gut-wrenching it should come with a trigger warning.

So why is she suing? Two reasons, spelled out in legalese but screaming through the pages: premises liability and punitive damages. Let’s break that down like we’re explaining it to your cousin at a BBQ. Premises liability means: if you own or operate a place where people come and pay to stay, you have a legal duty to keep them safe. That includes making sure fire escapes work, and that you don’t disable them because you’re annoyed by homeless people. It also includes having a fire sprinkler system—yes, that’s required in most hotels, especially multi-story ones. According to the filing, this place had neither. No working fire escape. No sprinklers. Just a “good luck” vibe and a “do not disturb” sign on the exit door.

And then there’s the second claim: punitive damages. This isn’t about just covering medical bills. This is about punishment. The kind of damages courts award when someone doesn’t just mess up—they act with reckless disregard for human life. Sealing a fire escape in a hotel isn’t an oversight. It’s not a typo. It’s a choice. And when you make that choice, knowing full well that a fire could happen (because, newsflash: fires do happen), you’re not just cutting corners—you’re building a coffin with a credit card machine at the front desk.

Willa Mae is asking for at least $75,000 in compensatory damages—money to cover her medical bills, therapy, pain, and suffering. That number might sound high, but let’s be real: she’s an elderly woman with preexisting conditions who was physically injured, emotionally shattered, and forced to watch a friend burn to death—all because the hotel owners treated fire safety like an optional upgrade. And on top of that, she’s asking for punitive damages, which could push the total payout into the hundreds of thousands, maybe even millions. Is $75,000 a lot? For a single night in a budget motel? On paper, maybe. But when you consider that the cost of a functioning fire door is about $200, and the cost of a sprinkler system is a few thousand, and the cost of human life is infinite—$75,000 starts to look like a rounding error.

Now, here’s our take: the most absurd part of this whole mess isn’t even the sealed fire door. It’s the excuse. “We blocked it to keep out vagrants.” Oh, so the solution to homelessness is to turn your hotel into a pyre? Because nothing says “secure property” like ensuring no one can escape when the building catches fire. It’s like installing a moat around your house to keep out raccoons—except the moat is full of alligators, and your kids sleep in the basement. This isn’t security. It’s self-sabotage with extra steps. And the fact that this allegedly happened at a hotel—a place where people pay for shelter, for safety, for peace of mind—makes it feel like a betrayal. You didn’t just fail to protect your guests. You engineered their entrapment.

We’re rooting for Willa Mae. Not just because she’s the victim, but because this case is a wake-up call. There are too many budget hotels out there run by faceless LLCs, owned by people who’ve never stepped foot in the building, managed by operators who treat safety codes like suggestions. And every time something like this happens, someone dies, and nothing changes. But if this case goes to trial—and it’s demanding a jury—then maybe, just maybe, a group of ordinary Tulsans will look at these facts and say: “No. This is not okay. You don’t get to profit off human shelter and then treat human life like a line item you can cut.”

And if the jury slaps these owners with a mountain of punitive damages? Well, let’s just say the next time someone thinks about sealing a fire escape to keep out “vagrants,” they might want to calculate the real cost first.

Case Overview

$787,500 Demand Jury Trial Petition

Jurisdiction

District Court, Oklahoma

Filing Attorney

Kymberli J. M. Heckenkemper

Haven Law Group, PLLC

Relief Sought

$75,000 Monetary

$1 Punitive

Plaintiffs

Willa Mae Delgado individual
Rep: Kymberli J. M. Heckenkemper

Defendants

Chirag Desai individual
Ravina Desai individual
Pramodkumar B. Patel individual
Smitaben P. Patel individual
Sabarmati, Inc. business
Neil Shah individual
Manvear, LLC business
Kiana, LLC business

Claims

#	Cause of Action	Description
1	premises liability/negligence	sealing shut fire escape door and lack of fire sprinkler system
2	punitive damages	reckless disregard for plaintiff's safety

Petition Text

1,265 words

IN THE DISTRICT COURT IN AND FOR TULSA COUNTY STATE OF OKLAHOMA 1. WILLA MAE DELGADO, an individual, Plaintiff, v. 1. CHIRAG DESAI, an individual; 2. RAVINA DESAI, an individual; 3. PRAMODKUMAR B. PATEL, an individual; 4. SMITABEN P. PATEL, an individual; 5. SABARMATI, INC., a domestic for-profit corporation; 6. NEIL SHAH, an individual; 7. MANVEAR, LLC, a domestic limited liability company, OR ITS SUCCESSOR; 8. KIANA, LLC, a domestic limited liability company; Defendants. JURY TRIAL DEMANDED ATTORNEY LIEN CLAIMED Case No. 2025-05166 PETITION COMES NOW the Plaintiff, WILLA MAE DELGADO, by and through her attorney, Kymberli J. M. Heckenkemper of HAVEN LAW GROUP, PLLC, and brings this action for damages against Defendants CHIRAG DESAI, RAVINA DESAI, PRAMODKUMAR B. PATEL, SMITABEN B. PATEL, SABARMATI, INC., NEIL SHAH, MANVEAR, LLC, and KIANA, LLC for damages for premises liability and punitive damages. PARTIES, JURISDICTION & VENUE 1. Plaintiff WILLA MAE DELGADO is an individual who resides in Tulsa County, State of Oklahoma. 2. Defendant CHIRAG DESAI is an individual who, upon information and belief, resides in McClain County, State of Oklahoma. 3. Defendant RAVINA DESAI is an individual who, upon information and belief, resides in McClain County, State of Oklahoma. 4. Defendant PRAMODKUMAR B. PATEL is an individual who, upon information and belief, resides in Cleveland County, State of Oklahoma. 5. Defendant SMITABEN P. PATEL is an individual who, upon information and belief, resides in Cleveland County, State of Oklahoma. 6. Defendant SABARMATI, INC. is a domestic for-profit corporation which owns property at 8181 E. Skelly Dr. in Tulsa County, State of Oklahoma. 7. Defendants CHIRAG DESAI, RAVINA DESAI, PRAMODKUMAR B. PATEL, SMITABEN P. PATEL, and SABARMATI, INC., at all relevant times, has owned the real estate located at 8181 E. Skelly Dr. in Tulsa, Oklahoma. 8. At all relevant times, the Homestay Inn & Suites was located at 8181 E. Skelly Dr. in Tulsa, Oklahoma. 9. Upon information and belief, at all relevant times, MANVEAR, LLC operated the Homestay Inn & Suites at 8181 E. Skelly Dr. in Tulsa, Oklahoma. 10. Upon information and belief, at all relevant times, NEIL SHAH was a principal of MANVEAR, LLC. 11. Defendant NEIL SHAH is an individual who, upon information and belief, resides in Tulsa County, State of Oklahoma. 12. Defendant NEIL SHAH was, at all relevant times, the President of Defendant MANVEAR, LLC. 13. Defendant MANVEAR, LLC is a domestic limited liability company which does business as Homestay Inn & Suites in Tulsa County, State of Oklahoma. 14. Defendant MANVEAR, LLC, upon information and belief, was an agent of the Defendant Owners of the property located at 8181 E. Skelly Dr. in Tulsa, Oklahoma. 15. Alternatively, Defendant KIANA, LLC is a domestic limited liability company which does business as Homestay Inn & Suites in Tulsa County, State of Oklahoma. 16. This cause of action arose in Tulsa County, State of Oklahoma. 17. Venue is proper in this Court pursuant to 12 O.S. § 134. 18. The Court has jurisdiction over this matter. STATEMENT OF FACTS 19. Plaintiff incorporates by reference the preceding paragraphs as if fully restated herein. 20. On or about November 9, 2023, Plaintiff was a paying guest at the Homestay Inn & Suites ("Hotel") located at 8181 E. Skelly Dr. in Tulsa, Oklahoma ("Premises"). 21. Plaintiff was staying on the 2nd floor of the three-story building. 22. On or about November 9, 2023, around 8 or 9 p.m., the Premises caught fire and smoke spread throughout the building. 23. Upon information and belief, prior to the fire, Defendants had sealed shut the fire escape door at the bottom of the stairwell leading from the 2nd floor to the 1st floor to prevent vagrants from entering the Premises. 24. During the fire, Plaintiff, who walks with a cane, and others on the 2nd floor of the building began descending the stairs to get to the fire exit on the 1st floor, not knowing nor being warned that the door was sealed shut. 25. The stairwell was filled with smoke and Plaintiff, who is asthmatic, had trouble breathing while trying to escape the fire. 26. When Plaintiff and the other guests of the Hotel arrived at the fire exit door, the door was sealed shut, preventing a safe and timely escape. 27. While the Hotel occupants were frantically trying to escape through the fire exit door, Plaintiff was violently pushed up against the door by other occupants. 28. As a result of being pushed up against the door, Plaintiff suffered significant bruising on her arms. 29. Additionally, as a result of being trapped inside the Premises and unable to escape through the fire exit door, Plaintiff suffered smoke inhalation and a panic attack. 30. Upon information and belief, there was no functioning fire sprinkler system on the Premises. 31. With the help of the Tulsa Fire Department, Plaintiff and the other occupants were eventually able to exit through the main lobby. 32. However, once outside, Plaintiff observed her friend, who had been staying on the third floor of the Premises, actively on fire. 33. Her friend later died at the hospital of the injuries sustained in the fire. 34. At all relevant times, Plaintiff was an invitee of the Hotel/Premises. CLAIM #1: PREMISES LIABILITY/NEGLIGENCE Including, but not limited to, direct liability and/or respondeat superior 35. Plaintiff incorporates by reference the preceding paragraphs as if fully restated herein. 36. Defendants and/or their agents owed a duty to Plaintiff to keep the Hotel/Premises in a reasonably safe condition for Plaintiff's use. 37. Defendants and/or their agents also owed a duty to Plaintiff to warn of any hidden danger Defendants and/or their agents knew or should have known of with the exercise of reasonable care, or that was created by Defendants and/or their agents working within the scope of their employment. 38. Defendants and/or their agents breached this duty by failing to keep the fire escape door on the 1st floor in proper working order. 39. Defendants and/or their agents further breached this duty by failing to warn Plaintiff of the defective condition of the door. 40. Likewise, Defendants and/or their agents breached this duty by failing to maintain a fire sprinkler system in proper working order. 41. As a direct and proximate result of Defendants' and/or their agents' breach, Plaintiff suffered damages including, but not limited to, pain & suffering, emotional distress, and medical expenses. CLAIM #2: PUNITIVE DAMAGES 42. Plaintiff incorporates by reference the preceding paragraphs as if fully restated herein. 43. In sealing shut the fire door on the Premises, Defendants and/or their agents acted in reckless disregard to the rights and safety of Plaintiff and the other Hotel occupants. 44. Defendants and/or their agents either knew, or did not care, that sealing shut the fire door both created a substantial and unnecessary risk that others would be seriously injured as a result. 45. Defendants’ and/or their agents’ decision to seal shut the fire door was both unreasonable under the circumstances and created a high probability that a Hotel occupant would be seriously harmed in the event of a fire. 46. Plaintiff is therefore entitled to punitive damages. PRAYER FOR RELIEF Plaintiff prays that this Honorable Court will enter judgment in her favor and against the Defendants and award her the following: 1. All damages suffered by Plaintiff, including, but not limited to, those emanating from physical pain & suffering, emotional distress, and medical expenses both heretofore incurred and to be incurred in the future, in excess of $75,000.00; 2. Punitive damages to the extent permitted by law; 3. Pre- and post-judgment interest; and 4. Any and all further relief this Court deems just and equitable under the circumstances. WHEREFORE, premises considered, Plaintiff respectfully requests that the Court enter judgment in her favor and against Defendants and award her the relief prayed for herein. Respectfully submitted, Kymberli J. M. Heckenkemper, OBA No. 33524 HAVEN LAW GROUP, PLLC 1874 S. Boulder Ave., Ste. 4 Tulsa, Oklahoma 74119 (918) 796-5738 (Office) (918) 796-5724 (Facsimile) [email protected] Attorney for Plaintiff Willa Mae Delgado