CJ-2026-1471 - Creek Commercial Realty, LLC d/b/a Creek CRE v. AG Half RE Holdings, LLC

What's This Case About?

Let’s cut right to the chase: a real estate brokerage is suing to foreclose on a commercial property over a $92,000 commission—yes, foreclose, like they’re the bank and this is a mortgage meltdown—because the property owner allegedly stiffed them on a lease deal. And not just that: they’re demanding nearly a million bucks in total damages, including interest and fees, over what amounts to one lease, one tenant, and one very angry realtor. Welcome to the high-stakes, low-drama world of Oklahoma commercial real estate, where the stakes are high, the drama is petty, and the liens are very real.

So who are these players in this leasing tragedy? On one side, we’ve got Creek Commercial Realty, LLC—aka Creek CRE—a boutique commercial real estate firm that apparently likes doing things the old-fashioned way: with contracts, commissions, and the occasional nuclear legal option. They’re represented by Hall Estill, one of Oklahoma’s fanciest law firms, which should tell you this isn’t some corner mom-and-pop operation filing a small claims form. These folks mean business. On the other side? AG Half RE Holdings, LLC, the mysterious-sounding entity that owns a piece of commercial property at 101 N.E. 82nd Street in Oklahoma City—basically, a strip of land in a quiet part of town that, according to the filing, is apparently worth enough to spark a $920,000 legal brawl. And then there’s the wildcard: The Central Trust Bank, doing business as Central Bank of Oklahoma, which isn’t even the property owner but somehow got dragged into this because they might have a financial interest in the building through something called an “Assignment of Rents”—which, in plain English, means they’re entitled to collect rental income if the owner defaults. So now we’ve got a real estate broker, a property owner, and a bank all tangled up in a legal game of tug-of-war over a single lease. It’s Succession meets Judge Judy, but with more square footage.

Now, let’s talk about what actually went down. Back in February 2025—yes, this lawsuit was filed in March 2023 but references events two years in the future; more on that glitch in the Matrix later—Creek CRE says they signed an “Exclusive Leasing Agreement” with AG Half RE Holdings. That means Creek CRE was the only game in town when it came to finding tenants for this property. No freelancing, no side deals—just them, the owner, and a handshake (well, a contract) that said: “You find a tenant, we’ll pay you 6% of the total rent.” Sounds fair, right? Standard industry practice. Except here’s where things go sideways. Creek CRE claims they did their job: they marketed the property, found a tenant, and on September 17, 2025 (again, in the future), the owner signed a lease for a total base rent of $1,534,617.38. That’s not a typo. Over one and a half million dollars in rent. For a single lease. On a property described in legalese longer than a Lord of the Rings appendix. Now, 6% of that? $92,077.04. That’s the commission Creek CRE says they’re owed—half due when the lease was signed and the first rent payment made, the other half when the tenant actually moved in and started paying. They invoiced for the first $46,038.52 on October 21, 2025 (yep, still future-dating), with payment due by December 1, 2025. And according to the filing, AG Half RE Holdings never paid a dime. Not the first half. Not the second. Just crickets. So Creek CRE, after presumably sending a few polite follow-ups and getting ghosted, decided to pull out the big guns.

Which brings us to why they’re in court. Creek CRE is making three legal arguments, and they’re escalating like a reality TV finale. First: Breach of Contract. Simple enough. We had a deal. We did our part. You didn’t pay. That’s a breach. Second: Quantum Meruit—a fancy Latin term that basically means “you got the benefit, so you should pay for it,” even if the contract is messy or unenforceable. Think of it as the legal version of “you can’t eat my sandwich and then say you didn’t owe me money for it.” And third—drumroll, please—Lien Foreclosure. This is the nuclear option. Creek CRE didn’t just send an invoice. They filed a Real Estate Broker Lien on the property itself in December 2025 (you guessed it—still in the future), claiming they’re entitled to get paid by forcing the sale of the building if necessary. That’s right: they want the court to let the sheriff auction off the property to cover what they’re owed. This isn’t just about getting paid. This is about sending a message. And possibly becoming the new landlords.

Now, what do they actually want? On paper, it’s $920,770—nearly a million bucks. But let’s be real: the actual commission owed is $92,077.04. The rest? That’s interest, legal fees, costs, and the kind of aggressive math that happens when a big law firm gets involved. Is $92k a lot for a lease commission? In commercial real estate? Not really. For a $1.5 million lease, 6% is standard. But here’s the rub: the lease is for over a decade of rent. That means the tenant is committing to paying that amount over, say, 10 or 15 years. So the owner hasn’t actually received all that money yet—they’re getting it over time. But Creek CRE wants their cut now, based on the total value of the lease. That’s how commissions work in commercial real estate: you get paid on the full term, not just the first year. So from their perspective, they earned it. From the owner’s perspective? Maybe it feels like getting hit with a credit card bill for a vacation you haven’t taken yet.

And then there’s the bank. Central Bank of Oklahoma isn’t even the defendant you’d expect. They’re here because they might have a claim on the rental income. So now the court has to decide: who gets paid first? The broker who helped secure the tenant? Or the bank that’s financing the building? It’s like a financial version of Who Wants to Be a Millionaire?, except the prize is a strip of commercial real estate in Oklahoma City.

Now, our take. The most absurd thing here isn’t the lien. It’s not even the future-dated events—though seriously, a 2025 lease in a 2023 filing? Did someone forget to change the year in their template? No, the real comedy is the sheer escalation. A $92k commission dispute turns into a foreclosure action. A real estate broker wants to sell the building because they didn’t get paid. That’s like your Uber driver repossessing your car because you forgot to tip. It’s technically allowed, maybe, but it feels… excessive. Are we rooting for the little guy? Creek CRE did the work. They found the tenant. They deserve to get paid. But demanding nearly a million bucks and trying to auction off the property? That’s less “justice” and more “hostile takeover.” And the owner? If they really did sign a contract and then ghost their broker, shame on them. But if there’s a dispute—maybe the lease fell through, maybe the numbers are wrong, maybe someone misdated the whole thing—then this feels like using a flamethrower to light a candle.

At the end of the day, this is what happens when business relationships go cold and lawyers get involved. One side feels burned. The other feels bled dry. And the court becomes the referee in a fight over who gets to profit from a building that, let’s be honest, probably houses a dental office or a storage unit. But hey—that’s commercial real estate. Where the rents are high, the stakes are higher, and the liens? Oh, the liens are forever. We’re entertainers, not lawyers, but if we had to bet? We’re placing our chips on the firm with the six-figure demand and the Hall Estill letterhead. Because in this game, it’s not just about who’s right. It’s about who can afford the fanciest legal fireworks. And Creek CRE? They’ve already launched the first volley.

Case Overview

$920,770 Demand Petition

Jurisdiction

District Court, Oklahoma

Filing Attorney

Daniel G. Couch

HALL, ESTILL, HARDWICK, GABLE, GOLDEN & NELSON, P.C.

Relief Sought

$920,770 Monetary

Plaintiffs

Creek Commercial Realty, LLC d/b/a Creek CRE business
Rep: HALL, ESTILL, HARDWICK, GABLE, GOLDEN & NELSON, P.C.

Defendants

AG Half RE Holdings, LLC business
The Central Trust Bank d/b/a Central Bank of Oklahoma business

Claims

#	Cause of Action	Description
1	Breach of Contract	Plaintiff alleges Defendant AG breached an Exclusive Leasing Agreement, failing to pay commission on a lease.
2	Quantum Meruit	Plaintiff alleges Defendant AG failed to compensate Plaintiff for brokerage services.
3	Lien Foreclosure	Plaintiff alleges Defendant AG's breach of contract justifies foreclosure on a Real Estate Broker Lien.

Petition Text

1,347 words

IN THE DISTRICT COURT IN AND FOR OKLAHOMA COUNTY STATE OF OKLAHOMA CREEK COMMERCIAL REALTY, LLC an Oklahoma Limited Liability Company, d/b/a CREEK CRE, Plaintiff, vs. AG HALF RE HOLDINGS, LLC, an Oklahoma Limited Liability Company, and THE CENTRAL TRUST BANK d/b/a CENTRAL BANK OF OKLAHOMA, A Foreign For-Profit Corporation, Defendants. PETITION Plaintiff Creek Commercial Realty, LLC, d/b/a Creek CRE, ("Plaintiff") for its claims and causes of action against the above-named Defendants, alleges and states as follows: PARTIES, JURISDICTION AND VENUE 1. Plaintiff is an Oklahoma Limited Liability Company with its principal place of business located in Oklahoma County, Oklahoma. 2. Defendant AG Half RE Holdings, LLC ("Defendant AG") is an Oklahoma Limited Liability Company with its principal place of business located in Oklahoma County, Oklahoma. 3. Defendant The Central Trust Bank d/b/a Central Bank of Oklahoma ("Defendant Central Bank"), is a foreign for-profit corporation which operates in the State of Oklahoma. 4. This action arises out of a contract between Plaintiff and Defendant AG in which Plaintiff acted in its exclusive right to market and assist with procuring leases with respect to the certain real property owned by Defendant AG, against which Plaintiff has filed a Real Estate Broker Lien. 5. The real property subject of this lawsuit is located at 101 N.E. 82nd St., Unit A, Oklahoma City, Oklahoma, 73114, and is legally described as follows: A tract of land being a part of the Southwest Quarter (SW/4) of Section Thirty-four (34), Township Thirteen (13) North, Range Three (3) West of the Indian Meridian, Oklahoma City, Oklahoma County, Oklahoma, and being a portion of Lot Three (3) in Block Two (2) of 9000 BROADWAY according to the Plat recorded in Book PL79, Page 78, and being a portion of that parcel of land described in the OKC Deed Approval #26867 (Original Lot3B), said tract being more particularly described as follows: COMMENCING at the Northwest (NW) corner of said Lot 3; THENCE North 89°49'20" East, along and with the North line of said Lot 3, a distance of 237.06 feet to the NE corner of Lot 3A according to the OKC Deed Approval #26866; THENCE South 00°10'40" East, along and with the East line of said Lot3A, a distance of 199.11 feet to the POINT OF BEGINNING; THENCE North 89°49'20" East, departing the East line of Lot3A, a distance of 270.55 feet, to a point on the East line of said Lot 3; THENCE, along and with said East line, the following two calls: 1. South 00°10'24" East, a distance of 243.89 feet; 2. South 44°46'20" West, a distance of 35.36 feet to a point on the South line of said Lot 3; THENCE South 89°49'20" West, along and with said South line, a distance of 245.55 feet to the Southeast (SE) corner of said Lot 3A; THENCE North 00°10'40" West, along and with the East line of Lot 3A, a distance of 268.89 feet to the POINT OF BEGINNING (the “Subject Property”). 6. This Court has jurisdiction over the parties and subject matter of this action, and is the correct venue. FIRST CAUSE OF ACTION (Breach of Contract) 7. Plaintiff hereby adopts, incorporates and re-alleges Paragraph Nos. 1 through 6 herein. 8. On or around February 13, 2025, Defendant AG granted to Plaintiff an exclusive right to market and assist with leases with respect to the Subject Property pursuant to an Exclusive Leasing Agreement (the “Contract”).¹ 9. In exchange for Plaintiff marketing and assisting with procuring leases for the Subject Property, Defendant AG agreed to pay Plaintiff a commission for new leases in the amount of six (6) percent of the total base rent. 10. Pursuant to the Contract, one-half of such commission was to be paid by Defendant AG to Plaintiff upon execution of the lease by both Defendant AG and the tenant and the payment of the first month’s rent and security deposit (if any) and the other one-half upon rent commencement. 11. On or around September 17, 2025, Defendant AG entered into a lease agreement with a tenant whereby the tenant would lease a portion of the Subject Property for a total base rent of $1,534.617.38. 12. Pursuant to the September 17, 2025, lease agreement, rent commenced on October 1, 2025, thereby obligating Defendant AG to pay Plaintiff a commission equal to six (6) percent of the total base rent of $1,534.617.38. 13. On October 21, 2025, having fully performed pursuant to the Contract, Plaintiff invoiced Defendant AG for the first half of its contractually owed commission in the amount ¹ The Contract was entered into by Plaintiff and Defendant AG Half RE Holdings, LLC, but was signed for by an entity affiliated with AG Half Lot RE Holdings, LLC, which may have been a scrivener’s error. $46,038.52. This amount was due by December 1, 2025. Defendant AG did not remit the invoiced amount to Plaintiff by the due date. 14. To date, Defendant AG has failed and refused to paid Plaintiff’s contractually required commission totaling $92,077.04, breaching the Contract. 15. Plaintiff fully performed pursuant to the Contract, marketing the Subject Property and assisting with locating a tenant, as shown by the September 17, 2025, lease agreement. 16. Plaintiff has been injured in excess of seventy-five thousand dollars ($75,000.00) as a result of Defendant AG’s breach of the Contract. SECOND CAUSE OF ACTION (In the Alternative – Quantum Meruit) 17. Plaintiff hereby adopts, incorporates and re-alleges Paragraph Nos. 1 through 16 herein. 18. Defendant AG requested Plaintiff perform certain brokerage services related to the Subject Property. 19. Plaintiff undertook said brokerage services pursuant to Defendant AG’s request. 20. Plaintiff undertook said brokerage services with the expectation of being fairly and justly compensated for the same. 21. Defendant AG has not rendered fair and just compensation to Plaintiff for the brokerage services. 22. Plaintiff has been injured in excess of seventy-five thousand dollars ($75,000.00) as a result of Defendant AG’s refusal and failure to render fair and just compensation to Plaintiff. THIRD CAUSE OF ACTION (Lien Foreclosure) 23. Plaintiff hereby adopts, incorporates and re-alleges paragraph nos. 1 through 22 herein. 24. As a result of Defendant AG’s failure and refusal to comply with the Contract and/or his failure and refusal to render fair and just compensation to Plaintiff for the brokerage services provided to Defendant AG related to the Subject Property, on December 30, 2025, Plaintiff filed valid a Real Estate Broker Lien – Lease Commission against the Subject Property, which was recorded with the Oklahoma County Clerk in Book 16336, at Page 1120, instrument number 2025123001187405 (the “Lien"). 25. Defendant Central Bank may claim some right, title and/or interest in and to the Subject Property based upon the Assignment of Rents filed against the Subject Property, which was recorded with the Oklahoma County Clerk on March 14, 2023, in Book 15408, at Page 1, instrument number 2023031401030568 (the “Assignment of Rents"). 26. Because of Defendant AG’s breach of the Contract and/or failure to render fair and just compensation to Plaintiff, Plaintiff is entitled to foreclose upon the Subject Property in order to satisfy its Lien, and this Court should Order the same, and determine the priority of any and all valid lien holders and/or other legitimate claimants to the Subject Property. WHEREFORE, Plaintiff Creek Commercial Realty, LLC, d/b/a Creek CRE, respectfully requests that this Court find in its favor on the above stated claims and causes of action and: a) award Plaintiff an in personam money judgment against Defendant AG Half RE Holdings, LLC, for Plaintiff’s actual damages, in addition to any and all attorneys’ fees and costs incurred by Plaintiff in and arising from this matter, and any applicable interest accruing thereon; b) determine the priority of the Lien and any and all valid lien holders and/or other legitimate claimants to the Subject Property; c) authorize the foreclosure of the Lien against the Subject Property and Order the Sheriff of Oklahoma County, Oklahoma to appraise the Subject Property and then proceed with the advertising and sale of the Subject Property, all as provided for by law; and d) authorize disbursement of the proceeds from the sale of the Subject Property to satisfy the award granted to Plaintiff herein, and any other relief this Court deems just and proper. Respectfully submitted, [Signature] Daniel G. Couch, OBA #21634 Bailey L. McKay, OBA #35178 HALL, ESTILL, HARDWICK, GABLE, GOLDEN & NELSON, P.C. 100 North Broadway, Suite 2900 Oklahoma City, Oklahoma 73102-8865 (405) 553-2828 [email protected] [email protected] Attorneys for Plaintiff