CJ-2026-798 - Ward Morgan v. Synergy Motorworks, L.L.C.

What's This Case About?

Let’s cut right to the chase: a man paid $10,700 for a fancy electric off-road vehicle—think golf cart meets Batmobile—and now he’s suing because the company not only didn’t deliver the ride, but also ghosted him like a bad Tinder date who stole your AirPods. And no, they didn’t refund the money. They just… kept it. In 2024. In Oklahoma. This isn’t just a breach of contract—it’s a full-throttle betrayal of basic decency, and now it’s headed to court with enough legal fireworks to power that very same electric UTV.

Meet Ward Morgan, our plaintiff, a regular guy from Kansas with a dream: to own a 2024 Volcon Stag. For the uninitiated, the Volcon Stag isn’t your grandpa’s lawn mower. It’s a high-performance, all-electric utility task vehicle—basically a silent, eco-friendly beast built for tearing up trails without the fumes. Think of it as the Tesla of dirt bikes, if Tesla made something that could actually survive a mud pit. Ward wasn’t buying it on a whim. He did his homework, reached out to Synergy Motorworks, LLC—a Tulsa-based motorsports supplier that markets itself as your one-stop shop for off-road thrills—and started negotiating a purchase. Synergy wasn’t just some shady Facebook reseller; they presented themselves as a legit business with inventory, a website, and apparently, the ability to accept serious deposits from out-of-state buyers.

The deal seemed straightforward. On or around February 16, 2024, Ward and Synergy hammered out a contract for the Volcon Stag. Three days later, Ward did his part: he mailed a check for $10,700—yes, over ten grand—as a deposit. That’s not pocket change. That’s a used car, a vacation, or a lot of therapy. But Ward was playing by the rules. He trusted the process. And for a hot second, it looked like things were moving. Synergy confirmed in writing that they’d placed an order for the vehicle in Ward’s name. That’s important—because now we’re not just talking about a handshake deal. We’ve got paper. We’ve got promises. We’ve got expectations.

Then… nothing.

By February 26, Synergy had the money. But they didn’t have the vehicle. And they didn’t have an explanation. Worse, they didn’t have the decency to return the deposit when asked. Ward, realizing he was in danger of becoming the world’s most expensive cautionary tale, started making demands. “Hey, where’s my ride?” “Can I get my money back?” “Hello? Is this thing on?” Crickets. Radio silence. Synergy didn’t deliver the UTV, didn’t refund the cash, didn’t even offer a sad little “sorry, we messed up” email. They just sat on $10,700 like a dragon hoarding gold—except dragons at least have the excuse of being mythical. Synergy Motorworks is real. And allegedly, so is their failure to act like a functioning business.

So here we are, in the Tulsa County District Court, where Ward Morgan isn’t just asking for his money back—he’s bringing the legal cavalry. His lawsuit lays out four distinct claims, each one sharper than the last. First up: Breach of Contract. Simple enough—“We had a deal. I paid. You didn’t deliver. That’s a breach.” No mystery there. Second: Conversion, which sounds like a religious awakening but in legal terms means “you took my money and won’t give it back, so you’re basically stealing it.” Under Oklahoma law, once you wrongfully exert control over someone else’s property (yes, money counts), they can sue to get it back like you’re a kid refusing to return a stolen lunchbox. Third: Unjust Enrichment, which is the legal way of saying, “You can’t keep getting richer off my loss when you gave me nothing in return.” And finally, the big gun: a claim under the Oklahoma Consumer Protection Act, which is basically the state’s “don’t be a scammer” law. If Synergy engaged in “unlawful practices” while conducting business—like taking money and vanishing—they could be on the hook for more than just the deposit. They could be looking at penalties, fees, and the kind of public shaming only a court filing can provide.

Now, let’s talk numbers. Ward is suing for up to $75,000. But here’s the twist: the actual deposit was $10,700. So why the big number? Because he’s also asking for punitive damages—meaning, “punish them for being jerks.” He wants attorney’s fees, interest, and costs. And honestly? $75,000 isn’t crazy in this context. If a business routinely takes deposits and ghosts customers, letting them walk away with no consequences would be like giving a speeding ticket to a bank robber. The goal isn’t just to get Ward’s cash back—it’s to make sure Synergy doesn’t do this to five other people next month.

And that’s where we land on our take: the most absurd part of this case isn’t even the missing UTV. It’s the sheer audacity of keeping $10,700 and acting like nothing happened. This isn’t a dispute over paint color or delivery timelines. This is a total failure to perform. No vehicle. No refund. No communication. Just silence and a growing sense of betrayal. We’re not rooting for Ward because he wants a cool electric buggy—we’re rooting for him because he represents every person who’s ever trusted a business to do the right thing and gotten burned. We’re rooting for the guy who followed the rules in a world that increasingly rewards those who break them.

Is this petty? Maybe. Is it civil court over a deposit? Technically, yes. But beneath the surface, it’s about accountability. It’s about whether a company can take your money, ignore your emails, and just… keep it. And if the answer is “yes,” then we might as well start accepting Monopoly money as legal tender. So go ahead, Ward. Sue for every dollar you’re owed. And while you’re at it—maybe ask for a deposition. We’d love to hear Synergy Motorworks explain, under oath, why “we just didn’t feel like it” isn’t a valid refund policy.

Because in the wild world of civil court drama, sometimes the most thrilling cases aren’t about murder or mayhem—they’re about a man, his missing motorbike, and the $10,700 that should’ve bought him freedom, not a front-row seat to corporate ghosting.

Case Overview

$75,000 Demand Petition

Jurisdiction

District Court, Oklahoma

Filing Attorney

Deric J. McClellan and Jayci Jones

Crowe Dunlevy

Relief Sought

$10,700 Monetary

$1 Punitive

Plaintiffs

Ward Morgan individual
Rep: Deric J. McClellan, OBA #32827 and Jayci Jones, OBA #35652

Defendants

Synergy Motorworks, L.L.C. business

Claims

#	Cause of Action	Description
1	Breach of Contract	Plaintiff seeks damages for Defendant's failure to deliver a vehicle and refund a deposit.
2	Conversion/Thing in Action	Plaintiff alleges that Defendant converted a deposit and is seeking its return.
3	Unjust Enrichment	Plaintiff claims that Defendant was unjustly enriched by retaining a deposit and seeks its return.
4	Violation of the Oklahoma Consumer Protection Act	Plaintiff alleges that Defendant engaged in an unlawful practice under the Oklahoma Consumer Protection Act and seeks damages.

Petition Text

885 words

IN THE DISTRICT COURT OF TULSA COUNTY STATE OF OKLAHOMA WARD MORGAN, an individual, Plaintiff, v. SYNERGY MOTORWORKS, L.L.C., Defendant. Case No. PETITION Plaintiff Ward Morgan ("Plaintiff"), brings this action against Defendant Synergy Motorworks, L.L.C. ("Synergy" or "Defendant"), and in support thereof alleges and states as follows: PARTIES, JURISDICTION, AND VENUE 1. Plaintiff Ward Morgan is a citizen of the State of Kansas. 2. Upon information and belief, Synergy is a limited liability corporation formed under the laws of Oklahoma that can be served with process on its registered agent, Ryan Cost, 6810 E. 41 Street, Tulsa, Oklahoma, 74145; Synergy's principal place of business is in Tulsa County, Oklahoma. 3. Accordingly, jurisdiction and venue in this Court are proper pursuant to 12 O.S. § 134. FACTUAL BACKGROUND 4. Plaintiff realleges and incorporates the allegations contained in the preceding paragraphs as if fully set forth herein. 5. Synergy is a motorsport supply business located in Tulsa, Oklahoma. 6. Synergy mostly markets itself as a motorbike supplier, but it also sells additional inventory including “side-by-sides” and utility task vehicles or “UTVs.” 7. In February of 2024, Synergy had access to a high-performance, all electric UTV called a Volcon Stag. 8. Prior to February 15, 2024, Plaintiff and Synergy communicated regarding Plaintiff’s potential purchase of a 2024 Volcon Stag (the “Vehicle”). 9. On or about February 16, 2024, Plaintiff entered into a contract with Synergy for the purchase of the Vehicle. 10. On or about February 19, 2024, in accordance with the terms of the contract between the parties, Plaintiff mailed a check for $10,700.00 to Synergy to serve as a deposit for the purchase of the Vehicle. 11. On or about February 26, 2024, Synergy was in possession of the $10,700.00 deposit for the Vehicle. 12. Synergy confirmed via writing that an order for the vehicle had been placed in Plaintiff’s name. 13. Presently, Synergy has not delivered the vehicle to Plaintiff, nor has Synergy refunded the $10,700.00 deposit Plaintiff paid toward the vehicle despite receiving multiple demands from Plaintiff to do so. COUNT I – BREACH OF CONTRACT 14. Plaintiff adopts and incorporates by reference all of the statements and allegations contained in Paragraphs 1 through 13 of his Petition as if fully set forth herein and, in addition, states: 15. Plaintiff and Synergy entered into a valid and enforceable contract for the purchase of the vehicle on or about February 16, 2024. 16. Despite Plaintiff providing $10,700.00 to Synergy pursuant to contract between the parties, Synergy failed to deliver the vehicle or refund the $10,700.00 deposit Plaintiff paid toward the Vehicle. 17. Therefore, Synergy breached its contract with Plaintiff. By virtue of Synergy’s breach, Plaintiff is entitled to recover the full $10,700.00 paid to Synergy for the vehicle. 18. Plaintiff is also entitled to recover his costs and reasonable attorneys’ fees pursuant to 12 O.S. § 936. COUNT II – CONVERSION/THING IN ACTION PURSUANT TO 60 O.S. § 312 19. Plaintiff adopts and incorporates by reference all of the statements and allegations contained in Paragraphs 1 through 18 of his Petition as if fully set forth herein and, in addition, states: 20. Plaintiff paid $10,700 to Defendant as a deposit toward the Vehicle. 21. Defendant never delivered the Vehicle and is still in possession of the $10,700 deposit. 22. By retaining the deposit, Defendant has engaged in acts of dominion or control over such funds in denial of or inconsistent with the rights that Plaintiff has in such funds. This entitles Plaintiff to assert an action for conversion or a Thing in Action pursuant to 60 O.S. § 312. COUNT III – UNJUST ENRICHMENT 23. Plaintiff adopts and incorporates by reference all of the statements and allegations contained in Paragraphs 1 through 18 of his Petition as if fully set forth herein and, in addition, states: 24. Plaintiff provided $10,700.00 to Synergy as a deposit for the vehicle. 25. Synergy unjustly benefitted by accepting the funds from Plaintiff and failing to provide the vehicle or a refund of the funds Synergy received. 26. Therefore, Plaintiff is entitled to judgment under the principles of quantum meruit or unjust enrichment for the funds it paid to Synergy in exchange for the vehicle. 27. Plaintiff is therefore entitled to a judgment against Synergy for $10,700.00, plus interest, reasonable attorneys’ fees, and costs. COUNT IV – VIOLATION OF THE OKLAHOMA CONSUMER PROTECTION ACT PURSUANT TO 15 O.S. § 751 28. Plaintiff adopts and incorporates by reference all of the statements and allegations contained in Paragraphs 1 through 27 of his Petition as if fully set forth herein and, in addition, states: 29. Plaintiff provided $10,700.00 to Synergy in the course of Synergy’s business. 30. Synergy engaged in an unlawful practice as defined in the Oklahoma Consumer Protection Act by failing to deliver the Vehicle and retaining possession of the $10,700.00. 31. Plaintiff suffered an injury as a result of Synergy’s commission of an unlawful practice. 32. Plaintiff is therefore entitled to a judgment against Synergy for $10,700.00, plus interest, reasonable attorneys’ fees, and costs. PRAYER FOR RELIEF WHEREFORE, Plaintiff demands the Court for judgment in his favor and against Defendant as follows: A. That all allegations in this Petition are found to be true and correct; B. Monetary damages not to exceed $75,000; C. Punitive damages; D. Pre and post-judgment interest; E. Reasonable attorney fees and all costs of this action; and F. Such other and further relief as the Court deems to be just and appropriate in law or in equity under the facts and circumstances presented by this lawsuit. Respectfully submitted, Deric J. McClellan, OBA #32827 Jayci Jones, OBA #35652 -Of the Firm- CROWE DUNLEVY A Professional Corporation 222 N. Detroit Ave., Suite 600 Tulsa, OK 74120 (918) 592-9800 (918) 592-9801 (Facsimile) ATTORNEYS FOR PLAINTIFF WARD MORGAN