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OSAGE COUNTY • CJ-2026-00038

Johnny L. Jackson v. Misty Lynn Cowan

Filed: Feb 13, 2026
Type: CJ

What's This Case About?

Let’s cut straight to the drama: a woman in Oklahoma allegedly took $75,000 from a guy in Kansas to build houses, promised to pay it back with interest, then ghosted—and now owes nearly $95,000 because of a $50-a-day late fee that’s been ticking like a financial time bomb. This isn’t The Wolf of Wall Street—this is The Woman Who Thought She Could Skip Out on a Hard Money Loan and Just… Not Pay It.

Meet Johnny L. Jackson, a resident of Wichita, Kansas, and self-styled private lender with a taste for real estate deals that live just outside the traditional banking system. Then there’s Misty Lynn Cowan, of Skiatook, Oklahoma—entrepreneur, property flipper, or possibly just someone who really, really believed she could stretch a deadline into oblivion. The two weren’t family. They weren’t business partners. They were connected by one thing: cold, hard cash and a piece of paper called a promissory note—the financial world’s version of “I pinky swear I’ll pay you back.”

Here’s how this house of cards got built. On October 15, 2024, Misty signed a promissory note agreeing to borrow $75,000 from Johnny. The terms? Pay back $84,000—yes, that’s 12% interest—by June 15, 2025. Eight months. Not a lifetime. The money was supposed to go toward building two single-family homes in Hominy, Oklahoma—304 S. Regan and 1002 S. Tinker, in case you’re thinking of driving by and checking for progress. Johnny wired the cash. Misty, according to the filing, bought a property in Hominy on March 13, 2025, for $43,500. So… half the loan? Maybe she was building dollhouses. Or maybe she just bought the land and ran out of steam—or money.

Then came June 15, 2025. The due date. The big day. The day Misty was supposed to hand over $84,000 and close the deal. Instead? Crickets. Not a dime. Not a wire. Not even a “Hey, can we push this back?” So Johnny, being the reasonable man he is (or perhaps just the man with a lawyer on speed dial), didn’t immediately sue. He gave her a second chance. On June 23, 2025—eight days late—Misty signed an addendum. A grace period. A lifeline. The new deadline? October 15, 2025. And for the privilege of extra time? An extra $4,500. So now the total owed? $88,500. Still no monthly payments. Still one lump sum. Still a ticking clock.

But October 15 came and went too. And this time, the late fees kicked in—$50. Per day. That’s not a typo. Fifty bucks. Every. Single. Day. Like a parking ticket from hell. By the time Johnny’s lawyer sent the demand letter on December 29, 2025, 75 days of late fees had piled up—$3,750—bringing the total to $92,250. And by the time the lawsuit was filed on February 13, 2026? $94,500. That’s right—$19,500 in interest and penalties on a $75,000 loan. And the meter’s still running.

Johnny, through his attorney Cameron A. Combs (of the Combs Law Group, because yes, the name is real and no, we’re not making that up), is now suing Misty for breach of contract—specifically, breach of the promissory note. In plain English? She borrowed money. She promised to pay it back. She didn’t. That’s the lawsuit. The legal claim is as straightforward as it gets: you said you’d pay, you didn’t, now we’re in court. The promissory note even has a clause saying Misty will cover attorney fees and collection costs if she defaults—so Johnny’s not just after the principal and interest, he wants every penny he’s spent trying to collect, plus interest on those costs. It’s like financial compound interest from the dark side.

And what does Johnny want? $94,500. Plus $50 more for every day that passes until she pays. Plus attorney fees. Plus interest on all of it. Is $94,500 a lot? For a private loan? Absolutely. But context matters. Misty borrowed $75,000—hardly chump change. She had eight months, then got an extension. She didn’t pay a cent. Meanwhile, Johnny’s sitting in Kansas, presumably not thrilled that his investment turned into a game of “Where’s Misty?” The $50-a-day fee might seem outrageous—like something out of a mob movie—but it was in the contract. She signed it. Twice. Once for the original note, once for the extension. And let’s not forget: she also agreed to a $250 loan setup fee, which she also never paid. So even the small stuff adds up.

Now, here’s where it gets juicy. The demand letter—sent December 29, 2025—gave Misty a final offer: pay $88,500 by January 5, 2026, and Johnny would forgive all late fees and legal costs. A clean slate. A mercy pass. But she didn’t. So now? Full penalties. Full enforcement. And the lawsuit is filed in Osage County District Court—where Misty lives, and where the property in question is located. Smart move. Jurisdiction? Check. Venue? Check. Paperwork? All in order. Even the verification is notarized. This isn’t some sketchy debt collector—it’s a legit claim with receipts, dates, and exhibits.

So what’s our take? Look, we’re not here to judge Misty’s life choices. Maybe she had a medical emergency. Maybe the construction fell through. Maybe the foundation cracked and the houses are now sinkholes. We don’t know. And the filing doesn’t say. But what we do know is this: she signed a contract. Twice. She got the money. She didn’t pay. And now she’s on the hook for nearly $100,000. The most absurd part? The $50-a-day late fee. That’s $1,500 a month—more than most people’s rent—for doing absolutely nothing. It’s the financial equivalent of being charged for breathing. But again—she agreed to it. In writing. With a notary.

Are we rooting for Johnny? Honestly? A little. He played by the rules. He funded the loan. He gave her extra time. He even offered a last-minute deal to save her from the fee avalanche. She ignored it. Are we judging Misty? Not really. But we are judging the idea that you can take tens of thousands of dollars from a private lender, use it for a real estate project, and then just… disappear. That’s not entrepreneurship. That’s financial freeloading.

At the end of the day, this case is a cautionary tale: promissory notes aren’t IOUs you scribble on a napkin. They’re binding contracts. And in the wild west of hard money lending, where banks won’t go and credit scores don’t matter, the penalties for breaking your word can be brutal. Misty Lynn Cowan may have thought she was buying time. But she was actually buying debt—$50 at a time. And now, the court’s about to decide whether she has to pay up… or if this house of cards collapses on someone else.

Case Overview

$94,500 Demand Petition
Jurisdiction
District Court, Oklahoma
Relief Sought
$94,500 Monetary
Plaintiffs
Defendants
Claims
# Cause of Action Description
1 breach of promissory note plaintiff seeks payment of $94,500.00 plus late fees

Petition Text

2,018 words
IN THE DISTRICT COURT IN AND FOR OSAGE COUNTY STATE OF OKLAHOMA JOHNNY L. JACKSON PLAINTIFF, vs. MISTY LYNN COWAN, DEFENDANT. District Court, Osage County, Okla. FILED FEB 13 2026 CASE NO: CJ-2026-38 JUDGE estes PETITION FOR BREACH OF PROMISSORY NOTE THIS COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. UNLESS YOU NOTIFY THIS OFFICE WITHIN 30 DAYS AFTER RECEIVING THIS NOTICE THAT YOU DISPUTE THE VALIDITY OF THE DEBT, OR ANY PORTION THEREOF, THIS OFFICE WILL ASSUME THE DEBT IS VALID. IF YOU NOTIFY THIS OFFICE, IN WRITING, WITHIN 30 DAYS FROM THE DATE YOU RECEIVE THIS NOTICE, THAT YOU DISPUTE THE VALIDITY OF THE DEBT, OR ANY PORTION THEREOF, OR THAT YOU REQUEST THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, THIS OFFICE WILL: SUSPEND COLLECTION EFFORTS UNTIL IT OBTAINS VERIFICATION OF THE DEBT, OR OBTAINS A COPY OF THE JUDGMENT AGAINST YOU AND MAILES TO YOU A COPY OF SUCH JUDGMENT OR VERIFICATION, OR UNTIL YOU ARE PROVIDED WITH THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM THE CURRENT CREDITOR, TO THE EXTENT SUCH INFORMATION HAS NOT ALREADY BEEN PROVIDED. Plaintiff, JOHNNY L. JACKSON ("Jackson"), and for his claim against Defendant, MISTY LYNN COWAN ("Cowan"), alleges and states as follows: 1. Plaintiff Jackson is a resident of Sedgwick County, State of Kansas. 2. Defendant Cowan resides in Skiatook, Osage County, State of Oklahoma and is an individual. 3. Plaintiff Jackson’s cause of action arises out of a business transaction that was executed and performed in Osage County, Oklahoma. 4. Plaintiff Jackson’s cause of action arises out of a Promissory Note that was executed and performed in Oklahoma County, Oklahoma. 5. Osage County District Court has subject matter jurisdiction to decide all issues related to this case. 6. Osage County District Court has in personam jurisdiction over all parties in this matter. 7. Osage County is the proper venue for this action to be filed and maintained. 8. On or about October 15, 2024, the parties entered into a hard money loan whereby Plaintiff Jackson would provide a $75,000.00 loan to Defendant Cowan and that Defendant Cowan would make repayment of $84,000.00 to be paid to Plaintiff Jackson in full by June 15, 2025. See Exhibit A, hereinafter referred to as the Promissory Note. 9. Plaintiff Jackson completely fulfilled his obligation to Defendant Cowan by providing Defendant Cowan with $75,000.00 on or about October 15, 2024. 10. The purpose of the Promissory Note was for Defendant Cowan to develop real property in Hominy, Oklahoma. 11. On or about March 13, 2025, Defendant Cowan purchased real property in Hominy, Oklahoma for $43,500.00. 12. On the date that the Promissory Note came due, June 15, 2025, Defendant Cowan had not made any payment to Plaintiff Jackson. 13. On June 23, 2025, the Parties entered into extension on the Promissory Note through an Addendum A to Promissory Note (the “Addendum”), hereto attached as Exhibit B. This Addendum granted Defendant Cowan an extension to complete repayment by October 15, 2025, and the total repayment increasing by an additional $4,500.00, bringing the total debt owed on the hard money loan to $88,500.00. 14. Both the Promissory Note and the Addendum provide for a daily late fee of $50.00 to be collected if the loan payment is not made on time. 15. Despite Plaintiff Jackson’s repeated demands, Defendant Cowan has failed, refused, or neglected to pay Plaintiff Jackson the amount in which Defendant Cowan is indebted. On December 29, 2025, Plaintiff Jackson’s Counsel sent a demand letter via USPS certified mail and email to Defendant Cowan. See Exhibit C. Despite Jackson’s demands and Defendant Cowan's repeated promises to pay, she has failed, refused, or neglected to pay Plaintiff Jackson the amount in which she is indebted. 16. The Defendant Cowan owes Plaintiff Jackson $94,500.00 as of the date of filing which is the Addendum amount of $88,500.00, plus $50.00 daily fees since October 15, 2025, amounting to $6,000.00. See Exhibit B. 17. The Promissory Note provides for collection costs and attorneys fees to Plaintiff. WHEREFORE, the Plaintiff Jackson demands judgment against the Defendant Cowan in the amount for the sum of $94,500.00; plus continuing late fees at $50.00 per day; plus all cost of collection, including the costs of this action; plus reasonable attorney fees as stated in the Promissory Note; plus interest on the full amount, costs, and attorney fees; and for such other and further relief as the Court deems just and equitable. Respectfully Submitted, COMBS LAW GROUP Cameron A. Combs, OBA #34566 500 West Rogers Blvd., Suite C Skiatook, Oklahoma. 74070 918.396.4600 [email protected] Counsel for Petitioner VERIFICATION ATTACHED PROMISSORY NOTE Loan Amount: $75,000.00 Date: 10/15/2024 For value received, the undersigned Misty Lynn Cowan (the “Borrower”), at 3496 W. 165th St. Nth. Skiatook, OK. 74070, promises to pay to the order of Johnny L. Jackson, (the “Lender”), at 2371 N Lighthouse Cv. Wichita, KS. 67205 the sum of $75,000.00 with interest from October 15, 2024, on the unpaid principal at the rate of 12%. Total loan repayment with interest is $84,000.00 with a one time payment of $84,000.00 on or before June 15, 2025 (8 months term). One payment of $84,000.00 on or before June 15, 2025. Money used to build single family residences at 304 S Regan and 1002 S Tinker, Hominy, OK. A. A Loan set up fee of $250.00 will be paid by borrower with-in 3 months of Money in the amount of 75,000.00 loaned to borrower (Misty) B. Late fee of $50.00 daily will be added to loan if payment not made on time by June 15, 2025 I. TERMS OF REPAYMENT C. Payments The unpaid principal and accrued interest shall be payable in full within 8 months of June 15, 2025. (the “Due Date”). D. Application of Payments All payments on this Note shall be applied first in payment of accrued interest and any remainder in payment of principal E. Acceleration of Debt If any payment obligation under this Note is not paid when due, the remaining unpaid principal balance and any accrued interest shall become due immediately at the option of the Lender. F. TERMS Lender cannot ask for the money deposited back before the 8 months term is up. II. PREPAYMENT The borrower reserves the right to prepay this Note (in whole) prior to the Due Date with no prepayment penalty. III. COLLECTION COSTS If any payment obligation under this Note is not paid when due, the Borrower promises to pay all cost of collection, including reasonable attorney fees, whether or not a lawsuit is commenced as part of the collection process. IV. DEFAULT If any of the following events of default occur, this Note and any other obligations of the Borrower to the Lender, shall become due immediately, without demand or notice: 1) The failure of the Borrower to pay the principal and any accrued interest in full on or before the Due Date; 2) The death of the Borrower; 3) The filing of bankruptcy proceedings involving the Borrower as a debtor; 4) The application for the appointment of a receiver for the Borrower; 5) The making of a general assignment for the benefit of the Borrower’s creditors; 6) The insolvency of the Borrower; 7) A misrepresentation by the Borrower to the Lender for the purpose of obtaining or extending credit. V. SEVERABILITY OF PROVISIONS If any one or more of the provisions of this Note are determined to be unenforceable, in whole or in part, for any reason, the remaining provisions shall remain fully operative. VI. MISCELLANEOUS All payments of principal and interest on this Note shall be paid in the legal currency of the United States. The Borrower waives presentment for payment, protest, and notice of protest and nonpayment of this Note. VII. GOVERNING LAW This Note shall be construed in accordance with the laws of the State of Kansas. No renewal or extension of this Note is authorized unless both parties agree on new terms in writing. Delay in enforcing any right of the Lender under this Note, or assignment by Lender of this Note shall affect the liability or the obligation of the Borrower. All rights of the Lender under this Note are cumulative and may be exercised concurrently or consecutively at the lender’s option. IN WITNESS WHEREOF, this Agreement has been executed and delivered in the manner prescribed by law as of the date first written above. Signed this [blank] day of ___________, 20__, at 10/15/2024 am or pm. Misty L Conner Johnny L Jackson Borrower: Misty Lynn Cowan By: Misty L Cowan Misty Lynn Cowan SSN Id# 508-21-7276 GUARANTY Misty Lynn Cowan unconditionally guarantees all the obligations of the Borrower under this Note. Date: 10/15/2024, 20________. By: ________________________________ Johnny L Jackson Last 4 SSN#: _4602________ Lender: Johnny L Jackson Address: 2371 N Lighthouse CV, Wichita, KS. 67205 Phone number: 316-519-3101 Sincerely, Johnny L. Jackson 316-519-3101 Borrower understand they need to make payments to: Meritrust Credit Union Routing Number: 301180292 Account Number: 66699045 Checking Account EXHIBIT B = – Combs Law Group Cameron A. Combs Licensed in: Oklahoma, Arizona, Osage Nation, and Cherokee Nation December 29, 2025 Via Certified and email to: Misty Lynn Cowan 3496 W. 165th St. N. Skiatook, OK 74070 [email protected] Re: Jackson/Cowan Promissory Note Dear Ms. Cowan: Please be advised that I represent Johnny L. Jackson ("my Client") regarding the loan issued to you to finance building single family residence(s) at 304 S. Regan and 1002 S. Tinker, Hominy, OK, that certain Promissory Note, dated October 15, 2024, and its Addendum A, dated June 23, 2025, that were executed between you and my Client. As you know, on or about October 15, 2024, my Client reached an agreement to provide a $75,000.00 loan to you. To effectuate this loan, a promissory note was signed by both parties stating that you would be loaned $75,000.00 and repay the loan to my Client at a 12% interest rate, amounting to $84,000.00 by June 15, 2025. See the Promissory Note attached hereto as Exhibit A (the "Promissory Note"). An Addendum A to the Promissory Note was approved by my Client, and signed by you on June 23, 2025, giving you an extension to October 15, 2025, for you to complete repayment of the loan. See the Addendum A to Promissory Note attached hereto as Exhibit B (the "Addendum"). In consideration for this extension, the amount to be repaid increased by $4,500.00 to $88,500.00. Both the Addendum and the Promissory Note provide for a late fee of $50.00 daily if the loan payment was not made on time. Id. Since October 15, 2025, my client has attempted to speak with you several times, and you have not resolved the account or attempted to take necessary steps to begin resolving the account in full. 75 days have now passed since the deadline to pay the Promissory Note and my Client now demands that this account be settled, along with the late fee payments. These late fees total $3,750.00 and are accruing daily. Including these late fees, the balance owed to my client is now $92,250.00, that is due immediately, failure to pay will result in more late fees, and the potential for litigation to be brought against you in order to receive the payment owed. Your failure to pay the Promissory Note has caused grievous harm to my Client, and he is immediately owed $92,250.00 for your breach of the Promissory Note and the Addendum, plus legal fees and costs to obtain your payment. As a compromise, my Client is willing to forgo the accruing late fees and the accruing attorneys’ fees in exchange for full and complete payment of $88,500.00. To effectuate this settlement, please provide certified funds to our Office, located at 500 W. Rogers Blvd., Suite C, Skiatook, OK 74070, on or before 5:00pm Monday, January 5, 2026. This offer will only remain open until said deadline this coming Monday. To avoid further legal action, including, but not limited to, the payment of all late fees and my Client’s attorneys’ fees and costs in litigation, your payment of the $88,500.00 is necessary. Please contact my office immediately to arrange this payment. Sincerely, Cameron A. Combs, esq. Exhibit A - Promissory Note, dated October 15, 2024 Exhibit B - Addendum A to Promissory Note cc: Johnny Jackson VERIFICATION STATE OF OKLAHOMA ) COUNTY OF OSAGE ) ss. Johnny Jackson, being first duly sworn upon his oath, states: That he has read the above and foregoing document and know the contents thereof, and that the statements, allegations and facts therein set forth are true and correct to the best of his information, knowledge and belief. Johnny Jackson Subscribed and sworn to before me on February 12, 2026. [SEAL] MARY Y. BURNETT NOTARY PUBLIC No. 15011121 EXP. 12/09/2027 IN AND FOR STATE OF OKLAHOMA Mary Y. Burnett Notary Public
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