Ally Bank v. Lucky Wheeler

IN THE DISTRICT COURT IN AND FOR ADAIR COUNTY, OKLAHOMA ALLEY BANK, Plaintiff, v. LUCKY WHEELER, Defendant. No. CJ-2025-81 (Civil relief more than $10,000: REPLEVIN) Filed: 10/03/2025 Closed: 02/06/2026 Judge: Brown, L. Elizabeth Parties ALLY BANK, Plaintiff WHEELER, LUCKY, Defendant Attorneys Attorney Rayment, Brian Jay(Bar # 7441) TRIAD CENTER I, SUITE #550 7666 EAST 61ST STREET TULSA, OK 74133 Represented Parties ALLY BANK, Events Event Wednesday, January 28, 2026 at 10:00 AM HEARING(HEA) Party WHEELER, LUCKY Docket L. Elizabeth Brown Reporter Issues For cases filed before 1/1/2000, ancillary issues may not appear except in the docket. Issue # 1. Issue: REPLEVIN (REPLE) Filed by: ALLY BANK Filed Date: 10/03/2025 Disposition Information: Party Name: Defendant: WHEELER, LUCKY Disposed: TRANSFERRED TO ANOTHER JURISDICTION, 02/06/2026. Judge. Docket <table> <tr> <th>Date</th> <th>Code</th> <th>Count</th> <th>Party</th> <th>Serial #</th> <th>Entry Date</th> <th>User Name</th> <th>User Type</th> <th>Fee</th> </tr> <tr> <td>10-03-2025</td> <td>TEXT</td> <td>1</td> <td>2236307</td> <td></td> <td>Oct 3 2025 8:38:57:050AM</td> <td>OSCN\\NicholeCooper</td> <td>-</td> <td>$0.00</td> </tr> <tr> <td colspan="8">CIVIL RELIEF MORE THAN $10,000 INITIAL FILING.</td> </tr> <tr> <td>10-03-2025</td> <td>REPLE</td> <td></td> <td>2236309</td> <td></td> <td>Oct 3 2025 8:38:57:177AM</td> <td>OSCN\\NicholeCooper</td> <td>Realized</td> <td>$0.00</td> </tr> <tr> <td colspan="8">REPLEVIN</td> </tr> <tr> <td>10-03-2025</td> <td>DMFE</td> <td></td> <td>2236310</td> <td></td> <td>Oct 3 2025 8:38:57:223AM</td> <td>SYSTEM\\Autodocket</td> <td>Realized</td> <td>$7.00</td> </tr> <tr> <td colspan="8">DISPUTE MEDIATION FEE($7.00)</td> </tr> </table> U.S. Postal Service CERTIFIED MAIL RECEIPT Domestic Mail Only For delivery information, visit our web site at www.usps.com. Certified Mail Fee $5.30 Extra Services & Fees (checkbox, add fee to appropriate) Return Receipt (hardcopy) $1.19 Return Receipt (electronic) $0.00 Certified Mail Restricted Delivery $0.00 Adult Signature Required $0.00 Adult Signature Restricted Delivery $0.00 Postage $0.78 Total Postage and Fees $10.48 Sent To: Street and Apt. No., or PO Box No. City, State, ZIP code PS Form 3800, January 2023 See Reverse for Instructions SENDER: COMPLETE THIS SECTION ■ Complete items 1, 2, and 3. ■ Print your name and address on the reverse so that we can return the card to you. ■ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: Rayment, Bryan Jay Triad Center I, Suite #550 7666 East 61st Street Tulsa, OK, 74133 2. Article Number (transfer from piece sent): 9590 9402 9265 4295 9943 47 3. Service Type ☐ Adult Signature ☐ Certified Mail® ☐ Collect on Delivery ☐ Adult Signature Restricted Delivery ☐ Certified Mail® Restricted Delivery ☐ Free Certification™ ☐ Registered Mail™ Restricted Delivery ☐ Registered Mail Restricted Delivery ☐ Signature Confirmation™ Restricted Delivery ☐ Priority Mail Express® ☐ Signature Confirmation COMPLETE THIS SECTION ON DELIVERY A. Signature NASA Agent Addressee B. Received by (Printed Name) Five C. Date of Delivery 11/10/2025 D. Is delivery address different from item 1? ☒ Yes If YES, enter delivery address below: ☐ No 10-03-2025 PFE1 - 2236311 Oct 3 2025 2:20:43:533PM OSCN\nicholeCooper Realized $163.00 PETITION($163.00) Document Available (#1063563700) 10-03-2025 PFE7 - 2236312 Oct 3 2025 8:38:57:223AM SYSTEM\Autodocket Realized $6.00 LAW LIBRARY FEE($6.00) 10-03-2025 OCISR - 2236313 Oct 3 2025 8:38:57:223AM SYSTEM\Autodocket Realized $25.00 OKLAHOMA COURT INFORMATION SYSTEM REVOLVING FUND($25.00) 10-03-2025 OCJC - 2236314 Oct 3 2025 8:38:57:223AM SYSTEM\Autodocket Realized $1.55 OKLAHOMA COUNCIL ON JUDICIAL COMPLAINTS REVOLVING FUND($1.55) 10-03-2025 OCASA - 2236315 Oct 3 2025 8:38:57:223AM SYSTEM\Autodocket Realized $5.00 OKLAHOMA COURT APPOINTED SPECIAL ADVOCATES($5.00) 10-03-2025 SSFCHSCPC - 2236316 Oct 3 2025 8:38:57:223AM SYSTEM\Autodocket Realized $10.00 SHERIFF'S SERVICE FEE FOR COURTHOUSE SECURITY PER BOARD OF COUNTY COMMISSIONER($10.00) 10-03-2025 CCADMINCSF - 2236317 Oct 3 2025 8:38:57:223AM SYSTEM\Autodocket Realized $1.00 COURT CLERK ADMINISTRATIVE FEE ON COURTHOUSE SECURITY PER BOARD OF COUNTY COMMISSIONER($1.00) 10-03-2025 CCADMIN0155 - 2236318 Oct 3 2025 8:38:57:223AM SYSTEM\Autodocket Realized $0.16 COURT CLERK ADMINISTRATIVE FEE ON $1.55 COLLECTION($0.16) 10-03-2025 SJFIS - 2236319 Oct 3 2025 8:38:57:223AM SYSTEM\Autodocket Realized $0.45 STATE JUDICIAL REVOLVING FUND - INTERPRETER AND TRANSLATOR SERVICES($0.45) 10-03-2025 DCADMIN155 - 2236320 Oct 3 2025 8:38:57:223AM SYSTEM\Autodocket Realized $0.23 DISTRICT COURT ADMINISTRATIVE FEE ON $1.55 COLLECTIONS($0.23) 10-03-2025 DCADMIN05 - 2236321 Oct 3 2025 8:38:57:223AM SYSTEM\Autodocket Realized $0.75 DISTRICT COURT ADMINISTRATIVE FEE ON $5 COLLECTIONS($0.75) 10-03-2025 DCADMINCSF - 2236322 Oct 3 2025 8:38:57:223AM SYSTEM\Autodocket Realized $1.50 DISTRICT COURT ADMINISTRATIVE FEE ON COURTHOUSE SECURITY PER BOARD OF COUNTY COMMISSIONER($1.50) 10-03-2025 CCRMPF - 2236323 Oct 3 2025 8:38:57:223AM SYSTEM\Autodocket Realized $10.00 COURT CLERK'S RECORDS MANAGEMENT AND PRESERVATION FEE($10.00) 12-02-2025 RESP - 2248192 7:57:16:970AM OSCN\cFiling - $ 0.00 RESPONSE TO MOTION TO DISMISS Document Available (#1064055568) 01-12-2026 MO - WHEELER, LUCKY 2260561 Jan 12 2026 3:33:56:307PM OSCN\NicholeCooper - $ 0.00 OCIS Case Summary for CJ-2025-81- ALLY BANK v. LUCKY WHEELER (Adair Cou... Page 3 of 4 10-03-2025 CCADMIN04 - 8:38:57:223AM Realized $ 0.50 COURT CLERK ADMINISTRATIVE FEE ON COLLECTIONS($ 0.50) 10-03-2025 LTF - 2236325 Oct 3 2025 8:38:57:603AM OSCN\NicholeCooper Realized $ 10.00 LENGTHY TRIAL FUND($ 10.00) 10-03-2025 SMF - 2236326 Oct 3 2025 2:21:38:287PM OSCN\NicholeCooper Realized $ 10.00 SUMMONS FEE($ 10.00) Document Available (#1063563704) 10-03-2025 TEXT - 2236308 Oct 3 2025 8:38:57:130AM OSCN\NicholeCooper - $ 0.00 OCIS HAS AUTOMATICALLY ASSIGNED JUDGE BROWN, L. ELIZABETH TO THIS CASE. 10-03-2025 ACCOUNT - 2236327 Oct 3 2025 8:42:10:357AM OSCN\NicholeCooper - $ 0.00 RECEIPT #2025-158788 ON 10/03/2025. PAYOR: KIVELL, RAYMENT, FRANCIS TOTAL AMOUNT PAID: $ 252.14. LINE ITEMS: CJ-2025-81: $173.00 ON AC01 CLERK FEES. CJ-2025-81: $6.00 ON AC23 LAW LIBRARY FEE CIVIL AND CRIMINAL. CJ-2025-81: $1.66 ON AC31 COURT CLERK REVOLVING FUND. CJ-2025-81: $5.00 ON AC58 OKLAHOMA COURT APPOINTED SPECIAL ADVOCATES. CJ-2025-81: $1.55 ON AC59 COUNCIL ON JUDICIAL COMPLAINTS REVOLVING FUND. CJ-2025-81: $7.00 ON AC64 DISPUTE MEDIATION FEES CIVIL ONLY. CJ-2025-81: $0.45 ON AC65 STATE JUDICIAL REVOLVING FUND, INTERPRETER SVCS. CJ-2025-81: $2.48 ON AC67 DISTRICT COURT REVOLVING FUND. CJ-2025-81: $25.00 ON AC79 OCIS REVOLVING FUND. CJ-2025-81: $10.00 ON AC81 LENGTHY TRIAL FUND. CJ-2025-81: $10.00 ON AC88 SHERIFF'S SERVICE FEE FOR COURT HOUSE SECURITY. CJ-2025-81: $10.00 ON AC89 COURT CLERK'S RECORDS MANAGEMENT AND PRESERVATION FEE. 10-20-2025 O - WHEELER, LUCKY 2239083 Oct 20 2025 2:58:53:587PM OSCN\TristaWolf - $ 0.00 ORDER Document Available (#1063565153) 10-30-2025 SMS - 2241402 Oct 31 2025 2:32:03:973PM OSCN\cFiling - $ 0.00 SUMMONS RETURN, SERVED Document Available (#10637771052) 11-10-2025 EAA - WHEELER, LUCKY 2243897 Nov 10 2025 3:16:43:413PM OSCN\AliceRankin - $ 0.00 SPECIAL ENTRY OF APPEARANCE AND MOTION TO DISMISS FOR LACK OF JURISDICTION AND IMPROPER VENUE Document Available (#1063564238) 11-26-2025 SMS - WHEELER, LUCKY 2247068 Nov 26 2025 8:24:52:703AM OSCN\AliceRankin - $ 0.00 SUMMONS RETURNED, SERVED: 11/17/25 RAYMENT BRYAN JAY Document Available (#1063828248) IN THE DISTRICT COURT IN AND FOR ADAIR COUNTY STATE OF OKLAHOMA ALLY BANK, Plaintiff, vs. LUCKY WHEELER, Defendant. PETITION Plaintiff, Ally Financial, Inc., ("ALLY"), for its first cause of action against the Defendant, Lucky Wheeler, alleges and states: Jurisdiction 1. Plaintiff is a corporation duly authorized to transact business within the State of Oklahoma. 2. Defendant, Lucky Wheeler, is a resident of Adair County, Oklahoma The vehicle which is the subject of this action is located in Adair County, Oklahoma. The Court has jurisdiction of the subject matter hereof and the parties hereto. 3. On or about August 9, 2023, Leonard W. Willis executed a Retail Instalment Sale Contract a copy of which is attached hereto as Exhibit "A," whereby Leonard W. Willis contracted, covenanted, and agreed to purchase a 2020 Dodge Ram 2500, VIN # 3C6UR5DL5LG141226, from Superior Dodge Chrysler Jeep, for the amount of $56,392.00. 4. The Retail Instalment Sale Contract attached has been assigned to Plaintiff. Plaintiff’s lien is perfected as against the subject motor vehicle as reflected on Exhibit “B”. Plaintiff’s claims herein and Plaintiff’s lien have remained in existence and perfected against the subject vehicle because Defendant Lucky Wheeler has asserted an interest in the subject motor vehicle, but any interest of Lucky Wheeler is junior and inferior to the interest of Plaintiff. 5. Leonard W. Willis is now deceased. Leonard W. Willis has defaulted in the obligations owed to Ally under the contract and Plaintiff is entitled to possession of the following described vehicle: 2020 Dodge Ram 2500, VIN # 3C6UR5DL5LG141226 The actual wholesale book value of the collateral described above is approximately $34,700.00. 6. The provisions of the Retail Instalment Sale Contract executed by Defendant, Leonard W. Willis, provided that in the event Debtor defaults in the payment of the indebtedness secured thereby, ail obligations secured under the terms of the contract become immediately due and payable and, therefore, Plaintiff may proceed to enforce payment of the same and exercise any and all rights and remedies contained in the security agreement or as provided by law. Default has occurred under the terms of the Retail Instalment Sale Contract and pursuant to its terms, Plaintiff hereby demands payment and immediate delivery of the goods listed above as collateral according to the terms of the contract. Plaintiff’s security interest has been perfected against Raphael Palacios, and the collateral described above by the filing of a Lien Entry form with the office of the Oklahoma Tax Commission. See Exhibit "B". By reason of Exhibits "A" and “B” attached hereto, Plaintiff claims an interest in a lien on, and the right to possession of the above-described personal property. 7. There remains due and owing to Plaintiff the sum of $52,728.29, plus interest at 17.00% percent per annum from February 23, 2025. 8. Defendant, Lucky Wheeler, was a friend of the deceased, Leonard W. Willis, is in possession of the subject motor vehicle, and has asserted a claim in the subject vehicle for storage. Defendant Lucky Wheeler, has failed to timely provide the statutory notice to Plaintiff of his claim and, therefore, his claim is subject to the security interest of Plaintiff. 9. Plaintiff has requested that the Defendant, Lucky Wheeler, permit Plaintiff to recover the subject motor vehicle, however, Defendant has refused to turn over the vehicle. 10. The property listed above as collateral was not taken in execution on any order or judgment against Plaintiff or for the payment of any tax, fine, or amercement assessed against it or by virtue of an order of delivery issued under the Replevin law of the State of Oklahoma or any other mesne or final process issued against said Plaintiff. 12. By virtue of the nature of the personal property described herein, it may easily be concealed, removed, damaged, destroyed, encumbered, mortgaged, or alienated, and Plaintiff is fearful that Defendants may attempt to conceal, remove, damage, destroy, encumber, mortgage or alienate the property described herein. WHEREFORE, Plaintiff prays for judgment against the Defendant, Lucky Wheeler, and the subject vehicle, in rem, in the principal sum of $56,392.00, plus interest at 17.00% percent per annum from February 23, 2025, and the costs of this action, accrued and accruing, including a reasonable attorney's fee. Plaintiff further prays that it be awarded judgment against Defendant for immediate possession and delivery of the above-described personal property and that the property be sold to satisfy the indebtedness due and owing to Plaintiff. Plaintiff further prays that an order be issued restraining Defendant, Lucky Wheeler, from concealing, removing, damaging, destroying, encumbering, mortgaging, or alienating the vehicle until such time as the Court may direct. Plaintiff further prays for a reasonable attorney's fee and the costs of this action, accrued and accruing, and for such other and further relief as this Court deems just and equitable. KIVELL, RAYMENT, & FRANCIS, PC A Professional Corporation By ____________________________ Brian J. Rayment, OBA #7441 Triad Center, Suite 550 7666 East 61st Street Tulsa, Oklahoma 74133 Telephone: (918) 254-0626 Facsimile: (918) 254-7048 ATTORNEYS FOR PLAINTIFF VERIFICATION STATE OF OKLAHOMA ) COUNTY OF TULSA ) SS. I, Brian J. Rayment, OBA #7441, being duly sworn according to law, upon his oath deposes and states: That I am the attorney for the Plaintiff named in the foregoing action; that I have read the above Petition and know the contents thereof and that the same are true and correct based upon the records of the Plaintiff. ____________________________________ Brian J. Rayment Notary Public My Commission Expires: Notary Public State of Oklahoma CYNTHIA HADLEY WAGONER COUNTY COMMISSION #03006386 Comm. Exp. 04-18-2027 RETAIL INSTALLMENT SALE CONTRACT SIMPLE FINANCE CHARGE Buyer Name and Address (Including County and Zip Code) LEONARD W WILLIS 56143 CR 693 COLCORD, OK DELAWARE, 74338 Co-Buyer Name and Address (Including County and Zip Code) N/A Seller - Creditor (Name and Address) SUPERIOR DODGE CHRYSLER JEEP R 504 HIGHWAY 412 E SILOAM SPRINGS, AR 72761-4729 You, the Buyer (and Co-Buyer, if any), may buy the vehicle below for cash or on credit. By signing this contract, you choose to buy the vehicle on credit under the agreements in this contract. You agree to pay the Seller - Creditor (sometimes "we" or "us" in this contract) the Amount Financed and Finance Charge in U.S. funds according to the payment schedule below. We will figure your finance charge on a daily basis. The Truth-In-Lending Disclosures below are part of this contract. <table> <tr> <th>New/Used</th> <th>Year</th> <th>Make and Model</th> <th>Vehicle Identification Number</th> <th>Primary Use For Which Purchased<br>Personal, family, or household unless otherwise indicated below<br>☐ business<br>☐ agricultural ☐ N/A</th> </tr> <tr> <td>USED</td> <td>2020</td> <td>RAM 2500</td> <td>3C6UR5DL5LG141226</td> <td></td> </tr> </table> FEDERAL TRUTH-IN-LENDING DISCLOSURES <table> <tr> <th>ANNUAL PERCENTAGE RATE<br>The cost of your credit as a yearly rate.</th> <th>FINANCE CHARGE<br>The dollar amount the credit will cost you.</th> <th>Amount Financed<br>The amount of credit provided to you or on your behalf.</th> <th>Total of Payments<br>The amount you will have paid after you have made all payments as scheduled.</th> <th>Total Sale Price<br>The total cost of your purchase on credit, including your down payment of $2,000.00 is $92,954.72</th> </tr> <tr> <td>17.00 %</td> <td>$34,562.72</td> <td>$56,392.00</td> <td>$90,954.72</td> <td></td> </tr> </table> Your Payment Schedule Will Be: (e) means an estimate <table> <tr> <th>Number of Payments</th> <th>Amount of Payments</th> <th>When Payments Are Due</th> </tr> <tr> <td>72</td> <td>$1,263.26</td> <td>Monthly beginning 09/23/2023</td> </tr> <tr> <td>One Final Payment Of</td> <td>$N/A</td> <td>On N/A</td> </tr> <tr> <td>N/A</td> <td></td> <td></td> </tr> </table> Late Charge. If payment is not received in full within 10 days after it is due, you will pay a late charge of $1.00 or 5% of the part of the payment that is late, whichever is greater. Prepayment. If you pay early, you will not have to pay a penalty. Security Interest. You are giving a security interest in the vehicle being purchased. Additional Information: See this contract for more information including information about nonpayment, default, any required repayment in full before the scheduled date and security interest. OPTIONAL GAP CONTRACT. A gap contract (debt cancellation contract) is not required to obtain credit and will not be provided unless you sign below and agree to pay the extra charge. If you choose to buy a gap contract, the charge is shown in Item 4D of the Itemization of Amount Financed. See your gap contract for details on the terms and conditions it provides. It is a part of this contract. Term 72 Mos. I want to buy a gap contract. Buyer Signs X ROADVANTAGE Name of Gap Contract ☐ VENDOR'S SINGLE INTEREST INSURANCE (VSI insurance): If the preceding box is checked, the Creditor requires VSI insurance for the initial term of the contract to protect the Creditor for loss or damage to the vehicle (collision, fire, theft, concealment, skip). VSI insurance is for the Creditor's sole protection. This insurance does not protect your interest in the vehicle. You may choose the insurance company through which the VSI insurance is obtained. If you elect to purchase VSI insurance through the Creditor, the cost of this insurance is $N/A and is also shown in Item 4B of the Itemization of Amount Financed. The coverage is for the initial term of the contract. Buyer Signature X N/A Co-Buyer Signature X N/A Returned Check Charge: You agree to pay a charge of $30.00 plus the amount of any fees charged to us by any financial institution if any check you give us is dishonored or any electronic payment is returned unpaid. NOTICE: ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST THE SELLER OF GOODS OR SERVICES OBTAINED PURSUANT HERETO OR WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER. The preceding NOTICE applies only to goods or services obtained primarily for personal, family or household use. In all other cases, Buyer will not assert against any subsequent holder or assignee of this contract any claims or defenses the Buyer (debtor) may have against the Seller, or against the manufacturer of the vehicle or equipment obtained under this contract. ITEMIZATION OF AMOUNT FINANCED 1 Cash Price (including $ N/A sales tax) $52,254.00 (1) 2 Total Downpayment = Trade-In 2012 FORD F-150 Gross Trade-In Allowance $2,000.00 Less Pay Off Made By Seller to N/A $N/A Equals Net Trade In $2,000.00 + Cash $N/A + Other N/A $N/A + Other N/A $N/A + Other N/A $N/A (If total downpayment is negative, enter "0" and see 4J below) $2,000.00 (2) Unpaid Balance of Cash Price (1 minus 2) $50,254.00 (3) 4 Other Charges Including Amounts Paid to Others on Your Behalf (Seller may keep part of these amounts): A Cost of Optional Credit Insurance Paid to Insurance Company or Companies. Life $N/A Disability $N/A $N/A B Vendor's Single Interest Insurance Paid to Insurance Company $N/A C Other Optional Insurance Paid to Insurance Company or Companies $N/A D Optional Gap Contract $1,500.00 E Official Fees Paid to Government Agencies to N/A for N/A $N/A to N/A for N/A $N/A to N/A for N/A $N/A F Government Taxes Not Included in Cash Price $N/A G Government License and/or Registration Fees $N/A H SERVICE AND HANDLING FEE. A SERVICE AND HANDLING FEE IS NOT AN OFFICIAL FEE. A SERVICE AND HANDLING FEE IS NOT REQUIRED BY LAW BUT MAY BE CHARGED TO THE CUSTOMER FOR PERFORMING SERVICES AND HANDLING DOCUMENTS RELATING TO THE CLOSING OF A SALE OR LEASE. THE SERVICE AND HANDLING FEE MAY RESULT IN PROFIT TO THE DEALER. THE SERVICE AND HANDLING FEE DOES NOT INCLUDE PAYMENT FOR THE PREPARATION OF LEGAL DOCUMENTS. THIS NOTICE IS REQUIRED BY LAW. I Government Certificate of Title Fees $129.00 J Other Charges (Seller must identify who is paid and describe purpose) to N/A for Prior Credit or Lease Balance $N/A to STATE for ELECTRONIC FILING FEE $5.00 to CNA WARRANTY for SERVICE CONTRACT $4,504.00 to N/A for N/A $N/A to N/A for N/A $N/A to N/A for N/A $N/A to N/A for N/A $N/A to N/A for N/A $N/A to N/A for N/A $N/A to N/A for N/A $N/A Total Other Charges and Amounts Paid to Others on Your Behalf $6,138.00 (4) 5 Amount Financed (3 + 4) $56,392.00 (5) OPTION: ☐ You pay no finance charge if the Amount Financed, item 5, is paid in full on or before _________N/A______, Year __N/A__. SELLER'S INITIALS __N/A__ Insurance. You may buy the physical damage insurance this contract requires from anyone you choose subject to our approval of your choice as the law allows. You may also provide the physical damage insurance through an existing policy owned or controlled by you that is acceptable to us. Your choice of insurance providers will not affect the credit terms or our decision to sell or extend credit to you. You are not required to buy any other insurance to obtain credit unless the box indicating Vendor's Single Interest Insurance is required is checked on page 1 of this contract. If any insurance is checked below, policies or certificates from the named insurance companies will describe the terms and conditions. Check the insurance you want and sign below: Optional Credit Insurance ☐ Credit Life: ☐ Buyer ☐ Co-Buyer ☐ Both ☐ Credit Disability: ☐ Buyer ☐ Co-Buyer ☐ Both Premium: Credit Life $N/A Credit Disability $N/A Insurance Company Name N/A N/A Home Office Address N/A N/A Credit life insurance and credit disability insurance are not required to obtain credit. Your decision to buy or not to buy credit life insurance and credit disability insurance will not be a factor in the credit approval process. They will not be provided unless you sign and agree to pay the extra cost. If you choose this insurance, the cost is shown in Item 4A of the Itemization of Amount Financed. Credit life insurance is based on your original payment schedule. This insurance may not pay all you owe on this contract if you make late payments. Credit disability insurance does not cover any increase in your payment or in the number of payments. Coverage for credit life insurance and credit disability insurance ends on the original due date for the last payment unless a different term for the insurance is shown below. Other Optional Insurance ☐ N/A N/A Type of Insurance Term Premium $N/A Insurance Company Name N/A N/A Home Office Address N/A N/A ☐ N/A N/A Type of Insurance Term Premium $N/A Insurance Company Name N/A N/A Home Office Address N/A N/A Other optional insurance is not required to obtain credit. Your decision to buy or not buy other optional insurance will not be a factor in the credit approval process. It will not be provided unless you sign and agree to pay the extra cost. I want the insurance checked above. X N/A N/A Buyer Signature Date X N/A N/A Co-Buyer Signature Date THIS INSURANCE DOES NOT INCLUDE INSURANCE ON YOUR LIABILITY FOR BODILY INJURY OR PROPERTY DAMAGE CAUSED TO OTHERS. WITHOUT SUCH INSURANCE YOU MAY NOT OPERATE THIS VEHICLE ON PUBLIC HIGHWAYS. OTHER IMPORTANT AGREEMENTS 1. FINANCE CHARGE AND PAYMENTS a. How we will figure Finance Charge. We will figure the Finance Charge on a daily basis at the Annual Percentage Rate on the unpaid part of the Amount Financed. b. How we will apply payments. We may apply each payment to the earned and unpaid part of the Finance Charge, to the unpaid part of the Amount Financed and to other amounts you owe under this contract in any order we choose as the law allows. c. How late payments or early payments change what you must pay. We based the Finance Charge, Total of Payments, and Total Sale Price shown on page 1 of this contract on the assumption that you will make every payment on the day it is due. Your Finance Charge, Total of Payments, and Total Sale Price will be more if you pay late and less if you pay early. Changes may take the form of a larger or smaller final payment or, at our option, more or fewer payments of the same amount as your scheduled payment with a smaller final payment. We will send you a notice telling you about these changes before the final scheduled payment is due. d. You may prepay. You may prepay all or part of the unpaid part of the Amount Financed at any time without penalty. If you do so, you must pay the earned and unpaid part of the Finance Charge and all other amounts due up to the date of your payment. 2. YOUR OTHER PROMISES TO US a. If the vehicle is damaged, destroyed, or missing. You agree to pay us all you owe under this contract even if the vehicle is damaged, destroyed, or missing. b. Using the vehicle. You agree not to remove the vehicle from the U.S. or Canada, or to sell, rent, lease, or transfer any interest in the vehicle or this contract without our written permission. You agree not to expose the vehicle to misuse, seizure, confiscation, or involuntary transfer. If we pay any repair bills, storage bills, taxes, fines, or charges on the vehicle, you agree to repay the amount when we ask for it. c. Security Interest. You give us a security interest in: • The vehicle and all parts or goods put on it; • All money or goods received (proceeds) for the vehicle; • All insurance, maintenance, service, or other contracts we finance for you; and • All proceeds from insurance, maintenance, service, or other contracts we finance for you. This includes any refunds of premiums or charges from the contracts. This secures payment of all you owe on this contract. It also secures your other agreements in this contract. You will make sure the title shows our security interest (lien) in the vehicle. You will not allow any other security interest to be placed on the title without our written permission. d. Insurance you must have on the vehicle. You agree to have physical damage insurance covering loss of or damage to the vehicle for the term of this contract. The insurance must cover our interest in the vehicle. You agree to name us on your insurance policy as an additional insured and as loss payee. If you do not have this insurance, we may, if we choose, buy physical damage insurance. If we decide to buy physical damage insurance, we may either buy insurance that covers your interest and our interest in the vehicle, or buy insurance that covers only our interest. If we buy either type of insurance, we will tell you which type and charge you must pay. The charge will be the premium for the insurance and a finance charge computed at the Annual Percentage Rate shown on page 1 of this contract. If the vehicle is lost or damaged, you agree that we may use any insurance settlement to reduce what you owe or repair the vehicle. e. What happens to returned insurance, maintenance, service, or other contract charges. If we obtain a refund of insurance, maintenance, service, or other contract charges, you agree that we may subtract the refund from what you owe. 3. IF YOU PAY LATE OR BREAK YOUR OTHER PROMISES a. You may owe late charges. You will pay a late charge on each late payment as shown on page 1 of this contract. Acceptance of a late payment or late charge does not excuse your late payment or mean that you may keep making late payments. If you pay late, we may also take the steps described below. b. You may have to pay all you owe at once. If you break your promises (default), we may demand that you pay all you owe on this contract at once. Default means: • You do not pay any payment on time; • You give false, incomplete, or misleading information during credit application; • You start a proceeding in bankruptcy or one is started against you or your property; or • You break any agreements in this contract. The amount you will owe will be the unpaid part of the Amount Financed plus the earned and unpaid part of the Finance Charge, any late charges, and any amounts due because you defaulted. c. You may have to pay collection costs. If we hire an attorney to collect what you owe, you will pay the attorney's fee and court costs as the law allows. d. We may take the vehicle from you. If you default, we may take (repossess) the vehicle from you if we do so peacefully and the law allows it. If your vehicle has an electronic tracking device (such as GPS), you agree that we may use the device to find the vehicle. If we take the vehicle, any accessories, equipment, and replacement parts will stay with the vehicle. If any personal items are in the vehicle, we may store them for you. If you do not ask for these items back, we may dispose of them as the law allows. e. How you can get the vehicle back if we take it. If we repossess the vehicle, you may pay to get it back (redeem). We will tell you how much to pay to redeem. Your right to redeem ends when we sell the vehicle. f. We will sell the vehicle if you do not get it back. If you do not redeem, we will sell the vehicle. We will send you a written notice of sale before selling the vehicle. We will apply the money from the sale, less allowed expenses, to the amount you owe. Allowed expenses are expenses we pay as a direct result of taking the vehicle, holding it, preparing it for sale, and selling it. Attorney fees and court costs the law permits are also allowed expenses. If any money is left (surplus), we will pay it to you unless the law requires us to pay it to someone else. If money from the sale is not enough to pay the amount you owe, you must pay the rest to us. If you do not pay this amount when we ask, we may charge you interest at a rate not exceeding the highest lawful rate until you pay. g. What we may do about optional insurance, maintenance, service, or other contracts. This contract may contain charges for optional insurance, maintenance, service, or other contracts. If we demand that you pay all you owe at once or we repossess the vehicle, you agree that we may claim benefits under these contracts and cancel them to obtain refunds of unearned charges to reduce what you owe. 4. WARRANTIES SELLER DISCLAIMS Unless the Seller makes a written warranty, or enters into a service contract within 90 days from the date of this contract, the Seller makes no warranties, express or implied, on the vehicle, and there will be no implied warranties of merchantability or of fitness for a particular purpose. This provision does not affect any warranties covering the vehicle that the vehicle manufacturer may provide. 5. Used Car Buyers Guide. The information you see on the window form for this vehicle is part of this contract. Information on the window form overrides any contrary provisions in the contract of sale. Spanish Translation: Guía para compradores de vehículos usados. La información que ve en el formulario de la ventanilla para este vehículo forma parte del presente contrato. La información del formulario de la ventanilla deja sin efecto toda disposición en contrario contenida en el contrato de venta. 6. SERVICING AND COLLECTION CONTACTS You agree that we may try to contact you in writing, by e-mail, or using prerecorded/artificial voice messages, text messages, and automatic telephone dialing systems, as the law allows. You also agree that we may try to contact you in these and other ways at any address or telephone number you provide us, even if the telephone number is a cell phone number or the contact results in a charge to you. 7. APPLICABLE LAW Federal law and the law of the state of Arkansas apply to this contract. Electronic Contracting and Signature Acknowledgment. You agree that (i) this contract is an electronic contract executed by you using your electronic signature, (ii) your electronic signature signifies your intent to enter into this contract and that this contract be legally valid and enforceable in accordance with its terms to the same extent as if you had executed this contract using your written signature and (iii) the authoritative copy of this contract ("Authoritative Copy") shall be that electronic copy that resides in a document management system designated by us for the storage of authoritative copies of electronic records, which shall be deemed held by us in the ordinary course of business. Notwithstanding the foregoing, if the Authoritative Copy is converted by printing a paper copy which is marked by us as the original (the "Paper Contract"), then you acknowledge and agree that (1) your signing of this contract with your electronic signature also constitutes issuance and delivery of such Paper Contract, (2) your electronic signature associated with this contract, when affixed to the Paper Contract, constitutes your legally valid and binding signature on the Paper Contract and (3) subsequent to such conversion, your obligations will be evidenced by the Paper Contract alone. NO COOLING OFF PERIOD State law does not provide for a "cooling off" or cancellation period for this sale. After you sign this contract, you may only cancel it if the seller agrees or for legal cause. You cannot cancel this contract simply because you change your mind. This notice does not apply to home solicitation sales. The Annual Percentage Rate may be negotiable with the Seller. The Seller may assign this contract, and retain its right to receive a part of the Finance Charge. HOW THIS CONTRACT CAN BE CHANGED. This contract contains the entire agreement between you and us relating to this contract. Any change to this contract must be in writing and we must sign it. No oral changes are binding. Buyer Signs X __________________________ Co-Buyer Signs X N/A If any part of this contract is not valid, all other parts stay valid. We may delay or refrain from enforcing any of our rights under this contract without losing them. For example, we may extend the time for making some payments without extending the time for making others. You authorize us to obtain information about you, or the vehicle you are buying, from the state motor vehicle department or other motor vehicle registration authorities. See the rest of this contract for other important agreements. NOTICE TO RETAIL BUYER: Do not sign this contract in blank. You are entitled to a copy of the contract at the time you sign. Keep it to protect your legal rights. You agree to the terms of this contract. You confirm that before you signed this contract, we gave it to you, and you were free to take it and review it. You confirm that you received a completely filled-in copy when you signed it. Buyer Signs X __________________________ Date 08/09/2023 Co-Buyer Signs X N/A Date N/A Buyer Printed Name LEONARD W WILLIS Co-Buyer Printed Name N/A If the "business" use box is checked in "Primary Use for Which Purchased": Print Name N/A Title N/A Co-Buyers and Other Owners — A co-buyer is a person who is responsible for paying the entire debt. An other owner is a person whose name is on the title to the vehicle but does not have to pay the debt. The other owner agrees to the security interest in the vehicle given to us in this contract. Other owner signs here X N/A Address N/A Seller signs SUPERIOR DODGE CHRYSLER JEEP R Date 08/09/2023 By X __________________________ Title Finance Manag Seller assigns its interest in this contract to ALLY BANK (Assignee) under the terms of Seller's agreement(s) with Assignee. ☐ Assigned with recourse ☒ Assigned without recourse ☐ Assigned with limited recourse By X __________________________ Title Finance Manager CERTIFICATE OF TITLE STATE OF OKLAHOMA VEHICLE IDENTIFICATION NUMBER 3C6UR5DL5LG141226 YEAR 2020 MAKE RAM TITLE NO. 810013606351 BODY TYPE PK MODEL 2500 AGENT NO. M0104 COLOR White APPLICATION DATE 05-Sep-2023 ODOMETER 55705 Actual DATE 1st SOLD DATE ISSUED 06-Sep-2023 TYPE OF TITLE Original MAILING ADDRESS ALLY BANK PO BOX 8101 COCKEYSVILLE MD 21030-8101 THIS VEHICLE IS SUBJECT TO THE FOLLOWING LIEN(S) 8/14/2023 ALLY BANK NAME AND ADDRESS OF THE VEHICLE OWNER LEONARD W WILLIS 56143 COUNTY ROAD 693 COLCORD OK 74338-3857 It is hereby certified that according to the records of the Oklahoma Tax Commission, the person named hereon is the owner of the vehicle described above which is subject to a lien(s) as shown; however, the vehicle may be subject to other liens or security interests. CONTROL NO. 53274184 (This is not a title number) ASSIGNMENT OF TITLE BY REGISTERED OWNER (If Dealer, List License # Here: ____________________________) I/we hereby assign and warrant ownership of the vehicle described on this certificate to the following, subject only to the liens or encumbrances, if any, properly noted on this certificate. Purchaser(s) Name (Type or Print) ________________________________________________ Purchaser(s) Complete Address: _________________________________________________ Actual Purchase Price of Vehicle: ________________________________________________ I certify to the best of my knowledge that the ODOMETER READING reflected on the vehicle's odometer and listed below is the ACTUAL MILEAGE of the vehicle UNLESS one of the accompanying statements is checked. [ ] [ ] [ ] [ ] [ ] [ ] [ ] [ ] [ ] [ ] (NO TENTHS) [ ] 1. The odometer has exceeded its mechanical limits [ ] 2. The odometer reading is NOT the actual mileage Warning——Odometer Discrepancy Signature of Seller(s): _______________________________ Printed Name of Seller(s): Subscribed and Sworn to Before me this ______________ Day of ____________________, 20 ______ Notary Public ______________________________ Commission Expiration: _______________________ Notarization required only of seller's signature(s). Affix notary seal/stamp to the right. Signature of Buyer(s): _______________________________ Printed Name of Buyer(s): OKLAHOMA TAX COMMISSION / MOTOR VEHICLE DIVISION NOTICE OF TRANSFER (SUBMISSION OF THIS FORM IS OPTIONAL - REFER TO INSTRUCTIONS ON REVERSE!) VEHICLE IDENTIFICATION NUMBER 3C6UR5DL5LG141226 TITLE NUMBER 810013606351 BUYER'S NAME (Printed) _______________________________ _______________________________ BUYER'S ADDRESS/CITY/STATE/ZIP __________________________ __________________________ __________________________ SELLER'S NAME (Printed) _______________________________ _______________________________ SELLERS ADDRESS/CITY/STATE/ZIP __________________________ __________________________ __________________________ SIGNATURE OF SELLER: _______________________________ DATE OF SALE: _______________________ CONTROL No. (Not a Title Number) 53274184 NOTICE OF TRANSFER FILING FFT IN THE DISTRICT COURT IN AND FOR ADAIR COUNTY STATE OF OKLAHOMA ALLY BANK, Plaintiff, vs. LUCKY WHEELER, Defendant. SUMMONS TO THE NAMED DEFENDANT: ____________________________, PSL # ________is authorized to serve this writ. Lucky Wheeler 25325 East Collins Rd. Stillwell, OK 74960 Brian J. Rayment, OBA #7441 You have been sued by the above-named Plaintiff and you are directed to file a written answer to the attached Petition in the Court at the above address within twenty (20) days after service of this Summons upon you exclusive of the date of service. Within the same time, a copy of your answer must be delivered or mailed to the attorney for the Plaintiff. Unless you answer the Petition within the time stated, judgment will be rendered against you with costs of the action. Issued this 3 day of October, 2025. Adair County District Court Clerk By: This summons was served on _______________________________, 2025. Signature of Person Serving Summons YOU MAY SEEK THE ADVICE OF AN ATTORNEY ON ANY MATTER CONNECTED WITH THIS SUIT OR YOUR ANSWER. SUCH ATTORNEY SHOULD BE CONSULTED IMMEDIATELY SO THAT AN ANSWER MAY BE FILED WITHIN THE TIME LIMIT STATED IN THIS SUMMONS. IN THE DISTRICT COURT IN AND FOR ADAIR COUNTY STATE OF OKLAHOMA ALLY BANK, ) ) ) Plaintiff, ) ) ) Case No. CJ-2025-81 vs. ) ) LUCKY WHEELER, ) ) ) Defendant. ) ORDER THE STATE OF OKLAHOMA: TO: Lucky Wheeler 25325 East Collins Rd. Stillwell, OK 74960 GREETINGS: On this 20 day of October, 2025, Plaintiff's verified Petition comes on for hearing before me, the undersigned Judge of the above Court, praying for possession and immediate delivery of the personal property and for in rem against Defendant, Lucky Wheeler, and the below described motor vehicle for the total sum of $56,392.00, plus interest at 17.00% percent per annum from February 23, 2025, until paid, a reasonable attorney's fee and the costs of this action, accrued and accruing, and further, for a temporary order restraining Defendant from concealing, removing, damaging, destroying, encumbering, mortgaging, or alienating the personal property described in Plaintiff's Petition, to-wit: 2020 Dodge Ram 2500, VIN # 3C6UR5DL5LG141226 until such time as the Court shall enter an order finding Plaintiff has no lien upon or right to possession of the property and to any other relief to which Plaintiff may be entitled, and the Court, having examined the verified Petition and being fully advised in the premises, finds that the temporary relief prayed for by Plaintiff should be entered instanter and without notice, providing such temporary relief as follows: IT IS ORDERED, ADJUDGED AND DECREED by this Court that the Defendant is restrained and enjoined from, in any manner, concealing, removing, damaging, destroying, encumbering, mortgaging, or alienating the personal property above-described, or from removing the vehicle from Adair County, Oklahoma, until further order of this Court. You are further notified that this order shall remain in effect pending the hearing, if any, on Plaintiff's request for an order of prejudgment delivery of the property. YOU WILL GOVERN YOURSELF ACCORDINGLY. [Signature] DISTRICT COURT JUDGE Brian J. Rayment, OBA #7441 Triad Center, Suite 550 7666 East 61st Street Tulsa, Oklahoma 74133 Telephone: (918) 254-0626 Facsimile: (918) 254-7048 ATTORNEYS FOR PLAINTIFF AFFIDAVIT OF SERVICE Case: CJ-2025-81 Court: IN THE DISTRICT COURT IN AND FOR ADAIR COUNTY STATE OF OKLAHOMA County: ADAIR, OK Job: 14433280 (604.1291) Plaintiff / Petitioner: ALLY BANK Defendant / Respondent: LUCKY WHEELER Received by: REX GUINN DBA RLG PROCESS SERVICES PSS-21-2 For: KIVELL RAYMENT & FRANCIS, P.C. To be served upon: LUCKY WHEELER I, REX GUINN, being duly sworn, depose and say: I am over the age of 18 years and not a party to this action, and that within the boundaries of the state where service was effected, I was authorized by law to make service of the documents and informed said person of the contents herein Recipient Name / Address: KIMBERLY WHEELER, 25325 E COLLINS ROAD , STILLWELL, OK 74960 Manner of Service: Substitute Service - Abode, Oct 25, 2025, 2:25 pm CDT Documents: SUMMONS; ORDER; PETITION (Received Oct 22, 2025 at 6:20pm CDT) Additional Comments: 1) Unsuccessful Attempt: Oct 24, 2025, 10:40 am CDT at 25325 E COLLINS ROAD , STILLWELL, OK 74960 No answer at door. 2) Successful Attempt: Oct 25, 2025, 2:25 pm CDT at 25325 E COLLINS ROAD , STILLWELL, OK 74960 received by KIMBERLY WHEELER. Relationship: Wife; REX GUINN Date 10/28/25 REX GUINN DBA RLG PROCESS SERVICES PSS-21-2 PO BOX 911 STILLWELL, Oklahoma 74960 (918) 680-0001 Filed District Court ADAIR COUNTY, OKLAHOMA October 30, 2025 11:01 AM NICHOLE COOPER, COURT CLERK Case Number CJ-2025-81 Subscribed and sworn to before me by the affiant who is personally known to me. Notary Public Date Commission Expires IN THE DISTRICT COURT IN AND FOR ADAIR COUNTY STATE OF OKLAHOMA ALLY BANK, ) ) ) Plaintiff, ) vs. ) ) LUCKY WHEELER, ) Defendant. SUMMONS TO THE NAMED DEFENDANT: Rex Guinn, PSL #21·2 is authorized to serve this writ. Lucky Wheeler 25325 East Collins Rd. Stillwell, OK 74960 You have been sued by the above-named Plaintiff and you are directed to file a written answer to the attached Petition in the Court at the above address within twenty (20) days after service of this Summons upon you exclusive of the date of service. Within the same time, a copy of your answer must be delivered or mailed to the attorney for the Plaintiff. Unless you answer the Petition within the time stated, judgment will be rendered against you with costs of the action. Issued this 3 day of October, 2025. Adair County District Court Clerk By: This summons was served on 10-25-2025. Signature of Person Serving Summons YOU MAY SEEK THE ADVICE OF AN ATTORNEY ON ANY MATTER CONNECTED WITH THIS SUIT OR YOUR ANSWER, SUCH ATTORNEY SHOULD BE CONSULTED IMMEDIATELY SO THAT AN ANSWER MAY BE FILED WITHIN THE TIME LIMIT STATED IN THIS SUMMONS. IN THE DISTRICT COURT IN AND FOR ADAIR COUNTY STATE OF OKLAHOMA ALLY BANK, Plaintiff, Vs. LUCKY WHEELER, Defendant Case No. CJ-2025-81 SPECIAL ENTRY OF APPEARANCE AND MOTION TO DISMISS FOR LACK OF JURISDICTION AND IMPROPER VENUE I. SPECIAL ENTRY OF APPEARANCE 1. Defendant’s appearance is special and limited to this Motion to Dismiss. 2. By filing this Motion, Defendant does not submit to the jurisdiction of this Court and does not waive any other defenses available under Oklahoma law. II. FACTUAL BACKGROUND 3. Plaintiff filed this action in the District Court of Adair County, Oklahoma, alleging that Defendant is a resident of Adair County and that the subject motor vehicle is located in Adair County. 4. In truth, Defendant is not now, and was not at the time of filing, a resident of Adair County, Oklahoma. Defendant resides in Cherokee County, Oklahoma. 5. The motor vehicle which is the subject of this action is likewise located in Cherokee County, Oklahoma, not in Adair County. 6. Defendant has no substantial or continuous contacts with Adair County and has conducted no relevant transactions there giving rise to the claims asserted in Plaintiff’s Petition. III. LACK OF PERSONAL JURISDICTION AND IMPROPER VENUE 7. Under Oklahoma law, civil actions must generally be brought in the county where the defendant resides or where the transaction or occurrence giving rise to the action took place. See, e.g., 12 O.S. §§ 134, 137. 8. Because Defendant does not reside in Adair County and the subject vehicle and alleged transaction are not located or occurring in Adair County, venue is improper in this Court as to Defendant. 9. Plaintiff’s allegation that Defendant is a resident of Adair County is incorrect and cannot serve as a proper basis for personal jurisdiction or venue. 10. Continuing to exercise jurisdiction over Defendant in a county where Defendant does not reside and has insufficient contacts would violate Defendant’s due process rights under the Oklahoma and United States Constitutions. 11. Accordingly, this case should be dismissed as to Defendant for lack of personal jurisdiction and improper venue. IV. PRAYER FOR RELIEF WHEREFORE, premises considered, Defendant Lucky Wheeler respectfully prays that this Court: A. Find that it lacks personal jurisdiction over Defendant and that venue is improper in Adair County as to Defendant; B. Dismiss Plaintiff's Petition as to Defendant for lack of jurisdiction and improper venue C. Grant such other and further relief as the Court deems just and proper. Respectfully submitted this 10 day of November, 2025. Lucky Wheeler, Defendant Pro Se VERIFICATION STATE OF OKLAHOMA ) COUNTY OF CHEROKEE ) ss. I, Lucky Wheeler, of lawful age, being first duly sworn upon oath, state that I am the Defendant in the above-styled case; that I have read the foregoing Special Entry of Appearance and Motion to Dismiss for Lack of Jurisdiction and Improper Venue and know the contents thereof; and that the facts stated therein are true and correct to the best of my knowledge and belief. Lucky Wheeler, Defendant Pro se Subscribed and sworn to before me this 10 day of November, 2025. Notary Public My Commission No.: ____________________ My Commission Expires: 4/27/28 CERTIFICATE OF SERVICE I hereby certify that on this 12 day of November, 2025, a true and correct copy of the foregoing Special Entry of Appearance and Motion to Dismiss for Lack of Jurisdiction and Improper Venue was deposited in the United States Mail, postage prepaid, addressed to: Rayment, Brian Jay Bar # 7441 Triad Center I, Suite #550 7666 East 61st Street Tulsa, Ok. 74133 Lucky Wheeler, Defendant Pro Se U.S. Postal Service™ CERTIFIED MAIL® RECEIPT Domestic Mail Only For delivery information, visit our website at www.usps.com Certified Mail Fee $5.30 Extra Services & Fees (checkbox, add fee if appropriate) Return Receipt (hardcopy) $0.71 Return Receipt (electronic) $0.18 Certified Mail Restricted Delivery $0.00 Adult Signature Required $0.00 Adult Signature Restricted Delivery $0.00 Postage $0.72 Total Postage and Fees $10.48 Sent To Street and Apt. No., or PO Box No. City, State, ZIP+ PS Form 3800, January 2023 See Reverse for Instructions REFERRED MAIL CERTIFIED MAIL SENDER: COMPLETE THIS SECTION ■ Complete items 1,2, and 3. ■ Print your name and address on the reverse so that we can return the card to you. ■ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: Raymont, Bryan Jay Triad Center I, Suite #550 7666 East 61st Street Tulsa, Ok. 74133 2. Article Number (Transfer from) 9590 9402 9265 4295 9943 47 2. Article Number (Transfer from) 9589 0710 5270 2383 3628 02 COMPLETE THIS SECTION ON DELIVERY A. Signature X NASA Agent Addressee B: Received by (Printed Name) Live C. Date of Delivery 1/1/2025 D. Is delivery address different from item 1? Yes If YES, enter delivery address below: No 3. Service Type Adult Signature Adult Signature Restricted Delivery Certified Mail® Certified Mail Restricted Delivery Collect on Delivery Delivery Restricted Delivery Insured Mail Restricted Delivery (over $500) Priority Mail Express® Registered Mail™ Registered Mail Restricted Delivery Signature Confirmation™ Signature Confirmation Restricted Delivery IN THE DISTRICT COURT IN AND FOR ADAIR COUNTY STATE OF OKLAHOMA ALLY BANK; vs. LUCKY WHEELER; Plaintiff, Defendants. FILED DISTRICT COURT ADAIR COUNTY, OKLAHOMA December 2, 2025 7:04 PM NICHOLE COOPER, COURT CLERK Case Number CJ-2025-81 Case No. CJ-2025-81 RESPONSE TO MOTION TO DISMISS Plaintiff, Ally Bank, for its Response to Defendant Lucky Wheeler’s Motion to Dismiss for Lack of Jurisdiction and Improper Venue, states: 1. Defendant asserts that jurisdiction and venue do not exist in Adair County, Oklahoma 2. Defendant’s Motion should be denied because Defendant’s own statement establishes that he and the subject vehicle are located in Stillwell, in Adair County, Oklahoma. 3. The notice of possessory lien served by Defendant upon Plaintiff is attached as Exhibit “A”. That notice provides an address for Defendant at 25325 East Collins Road. Stillwell, OK 74960. A copy of that notice is attached as Exhibit “A”. 4. The notice also asserts that the subject vehicle is located at the same address as Defendant, 25325 East Collins Road. Stillwell, OK 74960. Stillwell is in Adair County. 5. Defendant was served at the same address in Stillwell, Oklahoma. WHEREFORE, Plaintiff prays for deny Defendant, Lucky Wheeler’s Motion to Dismiss for Lack of Jurisdiction and Improper Venue, and for such other, further and additional relief as this Court deems just and proper. In the alternative, should the Court find that Defendant does indeed reside in Cherokee County, this action should be transferred to Cherokee County and the Plaintiff requests such a transfer. KIVELL, RAYMENT AND FRANCIS A Professional Corporation By: __________________________ Brian Rayment, OBA #7441 Triad Center I, Suite 550 7666 East 61st Street Tulsa, Oklahoma 74133 Telephone (918) 254-0626 Facsimile (918) 254-7915 E-mail: [email protected] ATTORNEYS FOR PLAINTIFF CERTIFICATE OF MAILING I, Brian Rayment, hereby certify that a true and correct copy of the above and foregoing instrument was mailed on the 25th day of November, 2025, with proper postage fully prepaid thereon, to the following: Lucky Wheeler 25325 East Collins Road Stillwell, OK 74960 By: ______________________________________ Brian J. Rayment Notice of Possessory Lien Service Oklahoma - Motor Vehicle Services Pursuant to the Provisions of 42 O.S. Chapter 2 This document is to serve as notice to all parties with an interest in the described property of a special lien claim, described hereon. The claimant affirms that the described labor, materials or skill furnished were authorized by the owner of the property and was in fact provided or performed, or the property was abandoned as described. Complete Legal Name of Lien Claimant: LUCKY WHEELER Business Name (if applicable): ____________________________ Telephone Number: (918) 507-0793 Complete Physical Address: 25325 E COLLINS RD, STILWELL, OK 74960 Complete Mailing Address: 25325 E COLLINS RD, STILWELL, OK 74960 Property Description: <table> <tr> <th>Year</th> <th>Make</th> <th>Model</th> <th>Identification Number</th> </tr> <tr> <td>2020</td> <td>RAM</td> <td>2500</td> <td>3C6UR5DL5LG141226</td> </tr> </table> Location of Property: 25325 E COLLINS RD, STILWELL, OK 74960 Details of Service(s) Provided Repairs Requested By (Legal Name): ABANDON' Requestor's Complete Physical Address: ____________________________ Requestor's Complete Mailing Address: ____________________________ Itemized Description and Date(s) of Labor or Service(s) Performed, including Material: (Continue on reverse, if necessary.) List charges claimed for each item, the total of which must equal the total compensation claimed. TITLE FEE $400 Date of Abandonment (If no other service rendered): 06/27/2025 (MM/DD/YY) Date of First Services Rendered: 06/27/2025 (MM/DD/YY) (Pursuant to 42 O.S. § 91, Notice of Possessory Lien must be mailed by certified mail within 60 days of Date of First Services Rendered) Total Amount of Repairs and/or Service Claimed: $400.00 Notice is hereby given to the following interested parties (Utilize separate notices, as required, for additional interested parties): If you no longer have a legal or financial interest in the described property, please disregard this notice. (1) Name: LEONARD W WILLIS Complete Mailing Address: 56143 COUNTY ROAD 693, COLCORD, OK 74338 (2) Name: ALLY BANK Complete Mailing Address: PO BOX 8101, COCKEYSVILLE, MD 21030 Signature of Lien Claimant: ____________________________ Contact Person (If business): LUCKY WHEELER State of Oklahoma, County-of: MUSKOGEE Subscribed and sworn to before me this 25 day of July 2023 My commission expires: ____________________________ Notice: The described property may be subject to delinquent taxes, fees and penalties due the state of Oklahoma. 1) When applicable (refer to instructions), attach either a photograph of the property (Process 1 or Process 2 motor vehicle) or inspection confirmation (Process 2 other than motor vehicle) of its condition. 2) Attach written proof of authority to perform the work, labor or service. THE DISTRICT COURT OF ADAIR COUNTY THE STATE OF OKLAHOMA Plaintiff, Ally Bank v. Defendant Lucky Wheeler. Case No.: CJ2025-81 MOTION FOR REQUEST FOR HEARING COMES NOW, Lucky Wheeler Defendant, pro se, and respectfully moves this Honorable Court to set this matter for a hearing. In support of this Motion, the movant states as follows: 1. This case is currently pending before the Court. 2. A hearing is necessary to address the following issue(s): That Adair County lacks jurisdiction as my residence is not within its territorial authority 3. The requested hearing will allow the Court to receive testimony, review evidence, and make a determination on the matter. 4. Granting this request is in the interest of justice and judicial efficiency. WHEREFORE, Lucky Wheeler respectfully requests that this Honorable Court schedule a hearing at the Court’s earliest convenience and grant any other relief the Court deems just and proper. Respectfully submitted, Lucky Wheeler 25325 Collins Rd. Stilwell Ok, 74960 Defendant/Respondent, Pro Se] CERTIFICATE OF SERVICE I certify that a true and correct copy of the foregoing Motion for Request for Hearing was served on ] on this ___ day of ________, 2026, by electronic service, etc. IN THE DISTRICT COUNTY OF ADAIR THE STATE OF OKLAHOMA ALLY BANK PLAINTIFF, v. LUCKY WHEELER DEFENDANT, Case No.: CJ-2025-81 ORDER ON MOTION TO REQUEST HEARING THIS MATTER comes before the Court on the Motion to Request Hearing filed by LUCKY WHEELER Defendant, pro se. The Court, having reviewed the Motion and being otherwise fully advised in the premises, hereby FINDS that the Motion is well taken. IT IS THEREFORE ORDERED AND ADJUDGED THAT: 1. The Motion to Request Hearing is GRANTED 2. This matter shall be set for hearing before the Court. 3. The Clerk of Court is directed to schedule the hearing and provide notice to all parties of the date, time, and location of the hearing. 4. All parties shall appear and be prepared to present testimony and evidence relevant to the issues before the Court. ______________________________ January 20th, 2026 @ 10:00 am DONE AND ORDERED this 13 day of January, 2026. ______________________________ [signature] JUDGE ADAIR COUNTY DISTRICT COURT Prepared by: ______________________________ LUCKY WHEELER Defendant, Pro Se 25325 Collins Rd Stillwell Ok,74960