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BECKHAM COUNTY • CJ-2026-00040

Citizens State Bank v. Billy S. Brown

Filed: Apr 9, 2026
Type: CJ

What's This Case About?

A bank is suing a network of exotic car dealers over $346,262 — and the drama centers around a 1984 GMC pickup truck and a 2014 Corvette that may or may not be hiding in Oklahoma City. This isn’t Fast & Furious. This is Fast & Furious Debt Collection.

Meet Billy S. Brown — also known as B. Scott Brown, also known as Billy Scott Brown (because why have one name when you can have three?). He runs SB Exotic Auto Sales LLC with his wife, Retzel L. Brown, out of a residential property in Elk City, Oklahoma — a town so small it makes your GPS question its life choices. Their business model? Apparently, buying, fixing, and selling classic and exotic vehicles. Or at least, that’s the theory. Because right now, they’re at the center of a financial tornado involving a Texas-based bank, a mechanic with a vendetta, and two cars that have become more valuable as legal pawns than as actual vehicles.

The storm began when Citizens State Bank — headquartered in San Angelo, Texas — handed Billy and Retzel a loan originally totaling $372,294.66 back in December 2024. The loan was secured by a mortgage on six residential lots in Elk City, plus a whole fleet of vehicles: a 1983 Chevy C-10, a 1966 Cadillac DeVille, a 1984 GMC C1500 pickup, a 2006 Ferrari F430, and a 2014 Chevrolet Corvette Stingray. This wasn’t just a loan — it was a garage full of collateral. But by September 2025, things went sideways. The Browns missed their October 2025 payment. Then they missed the next one. And the next. And now, the bank says they owe $346,262.66, accruing 8% interest like a very angry savings account.

So the bank did what banks do when money disappears: they sued. But they didn’t just go for the cash. Oh no. They pulled out the full legal artillery — foreclosure, replevin (twice), and a side of existential dread for good measure.

Let’s unpack that. First, foreclosure — the bank wants to sell the six lots in Elk City to pay off the debt. Standard procedure, right? But here’s where it gets juicy: the bank also wants to repossess two specific vehicles — the 1984 GMC C1500 pickup and the 2014 Corvette — under a legal maneuver called replevin, which is basically the court saying, “Hey, give the bank the car now because it technically belongs to them until the loan’s paid.” And here’s the kicker: someone else already has the truck.

Enter James Voyles, owner of Classic Corner Iconic Cars, operating out of a shop on NW 39th Street in Oklahoma City. According to the filing, Scott Brown (same guy, different name) brought the 1984 GMC pickup to Voyles for repairs. Voyles did $21,691.99 worth of work — labor, parts, taxes, storage — and then, allegedly, Brown never came back. So Voyles did what mechanics in Oklahoma are legally allowed to do: he slapped a possessory lien on the truck and announced a public auction to sell it — scheduled for April 10, 2026, just one day after the bank filed its lawsuit.

But here’s the problem: the bank claims they have the first lien on that truck, thanks to the security agreement signed back in December 2024. So when Voyles tried to sell it, he wasn’t just selling a truck — he was trying to auction off the bank’s property. And the bank is pissed. They argue Voyles’ notice of sale didn’t follow Oklahoma law — it was allegedly sent too late and didn’t meet formal requirements. So now, the bank wants the court to step in and say, “Nope, we get the truck, not you.”

Meanwhile, the 2014 Corvette? That one’s gone full Where’s Waldo? The bank says it’s either at Classic Corner Iconic Cars or at Scott Brown’s house — but no one’s seen it. And no one’s handing it over. The bank believes Brown and his company are “unlawfully detaining” it, possibly hiding it to keep it out of the bank’s hands. The Corvette is worth an estimated $50,000, and the bank wants it back — stat — before it vanishes into the Oklahoma twilight.

So what does the bank want? Three things: 1. Money: $346,262.66 plus interest, legal fees, and costs. 2. Property: Foreclose on the six lots in Elk City and sell them. 3. Cars: Immediate possession of the GMC pickup and the Corvette — even if that means sending court officers to haul them out of a mechanic’s shop.

Now, $346,000 sounds like a lot — and it is — but in the world of commercial loans and real estate mortgages, it’s not outrageous. What’s wild is how small the drama feels for such a big sum. We’re talking about a loan secured by a few city lots and a handful of cars — one of which is a 1984 pickup being fought over like it’s the Holy Grail. The Corvette, sure — that’s a nice car. But the GMC? It’s not even a rare model. It’s a workhorse, a beater, the kind of truck that should be hauling hay, not hauling legal briefs.

And yet, here we are. A bank from Texas is suing a married couple in Oklahoma, a mechanic in Oklahoma City, and “occupants of the premises, if any” (which sounds like a Law & Order cold open) — all over a truck that might not even sell for enough to cover the lien.

The most absurd part? The layers of betrayal. Billy Brown allegedly pledged the same truck to two different parties — the bank as collateral, and Voyles as a repair job. And Voyles, thinking he’s within his rights, tries to sell it — only to get slapped with a lawsuit. Meanwhile, the bank, which probably doesn’t even care about the truck, just wants to protect its position. It’s not about the cars — it’s about the principle. And possibly the attorney fees.

We’re rooting for the Corvette. Not because it’s flashy (though it is), but because it’s the only one in this whole mess that hasn’t been touched by human greed, bad paperwork, or a questionable mechanic’s lien. It’s just a car — a beautiful, midlife-crisis-on-wheels, 2014 Chevrolet Corvette Stingray — caught in the crossfire of a financial feud that should’ve been settled with a spreadsheet and a notary stamp.

But this is America. When money’s on the line, even a pickup truck from 1984 gets a day in court. And honestly? We’ll be watching — with popcorn — to see who ends up with the keys.

Case Overview

$346,263 Demand Petition|complaint
Jurisdiction
District Court, Oklahoma
Relief Sought
$346,263 Monetary
Injunctive Relief
Declaratory Relief
Plaintiffs
Claims
# Cause of Action Description
1 FORECLOSURE -
2 REPLEVIN -
3 REPLEVIN -

Petition Text

9,211 words
IN THE DISTRICT COURT WITHIN AND FOR BECKHAM COUNTY, STATE OF OKLAHOMA CITIZENS STATE BANK, Plaintiff, vs. BILLY S. BROWN; RETZEL L. BROWN; JAMES VOYLES; CLASSIC CORNER ICONIC CARS; SB EXOTIC AUTO SALES LLC; OCCUPANTS OF THE PREMISES, IF ANY Defendants. PETITION Comes now the Plaintiff and for its cause of action against the Defendant above named, alleges and states: 1. That the Plaintiff was at all times hereinafter mentioned, and now is, a Corporation, duly organized, existing and authorized to bring this action. That the defendants, Billy S. Brown and Retzel L. Brown, were at all times hereinafter mentioned, and now are, married. That the defendant, James Voyles, is claiming some right, title or interest in and to the subject property, but that any right, title, lien, estate, encumbrance, claim, assessment or interest, either in law or in equity which said defendant, may have or claim to have is subsequent, junior and inferior to the first mortgage lien of the Plaintiff. That the defendant, Classic Corner Iconic Cars, is claiming some right, title or interest in and to the subject property, but that any right, title, lien, estate, encumbrance, claim, assessment or interest, either in law or in equity which said defendant, may have or claim to have is subsequent, junior and inferior to the first mortgage lien of the Plaintiff. That the defendant, SB Exotic Auto Sales LLC, is claiming some right, title or interest in and to the subject property, but that any right, title, lien, estate, encumbrance, claim, assessment or interest, either in law or in equity which said defendant, may have or claim to have is subsequent, junior and inferior to the first mortgage lien of the Plaintiff. That the Plaintiff does not know, and with due diligence is unable to ascertain, the true and correct name(s) of the individual(s) occupying the real property, and therefore sues said individual(s) by the name(s) of Occupant(s) of the premises, whose true and correct name(s) are unknown to Plaintiff. That said individual(s) are made party defendant(s) herein to foreclose any right, title, or interest which they may have or claim to have in and to the real estate and premises herein sued upon by reason of their occupancy. FIRST CAUSE OF ACTION—FORECLOSURE 2. That the original maker(s), for a good and valuable consideration, made, executed and delivered to the Payee, a certain written promissory note; a true authoritative copy of said note is hereto attached, marked Exhibit "A" and made a part hereof by reference. 3. That as part of the same transaction, subsequent to the execution of the promissory note, and to secure the payment of the note above described and the indebtedness represented thereby, the owners of the real estate hereinafter described, made, executed and delivered to the payee of said note, an Extension and Modification of Loan, marked Exhibit "B" and made a part hereof, and a certain real estate mortgage in writing, and therein and thereby mortgaged and conveyed to said mortgagee the following described real estate situated in Beckham County, State of Oklahoma, to-wit: LOTS SEVEN (7), EIGHT (8), NINE (9), TEN (10), ELEVEN (11), AND TWELVE (12) IN BLOCK EIGHTY-ONE (81) OF THE ORIGINAL TOWN OF ELK CITY, BECKHAM COUNTY, OKLAHOMA; with the buildings and improvements and the appurtenances, (including any modular, manufactured or mobile home located thereon) hereditaments and all other rights thereunto appertaining or belonging, and all fixtures then or thereafter attached or used in connection with said premises. That said mortgage was duly executed and acknowledged according to law, the mortgage tax duly paid thereon, and was filed in the office of the County Clerk of Beckham County, Oklahoma, and therein recorded at December 10, 2025, in Book No. 2473, at Page 401, which mortgage and the record thereof is incorporated herein by reference as provided by law. Together with all Modification Agreements entered into subsequent to the execution and recording of the mortgage herein sued upon. 4. That thereafter, for a good and valuable consideration, said note and mortgage were assigned and endorsed to the Plaintiff. That Plaintiff has complied with all of the terms, conditions precedent and provisions of said note and mortgage, and is duly empowered to bring this suit. 5. Said mortgage provides that in addition to and together with the monthly payments of principal and interest as provided in said note, the mortgagor(s) will pay on the first day of each month, installments of taxes, assessments and insurance premiums, if any, relating to said property and said mortgage, agreed to be paid on said note and mortgage by said makers thereof. 6. That said note and mortgage provide that if default be made in the payment of any of the monthly installments, or on failure or neglect to keep or perform any of the other conditions and covenants of the mortgage, that the entire principal sum and accrued interest, together with all other sums secured by said mortgage, shall at once become due and payable, at the option of the holder thereof, and the holder shall be entitled to foreclose said mortgage and recover the unpaid principal thereon and all expenditures of the mortgagee made thereunder, with interest thereon, and to have said premises sold and the proceeds applied to the payment of the indebtedness secured thereby, together with all legal and necessary expense and all costs. 7. That default has been made upon said note and mortgage in that the installments due October 18, 2025, and thereafter have not been paid. 8. That preliminary to the bringing of this action, and as a necessary expense thereof, this Plaintiff caused the abstract of title to be extended and certified to date at a cost of a reasonable amount for title search and examination expenses of a reasonable amount with interest per annum thereon, until paid. 9. That said note and mortgage provide that in case of a foreclosure of said mortgage and as often as any proceedings shall be taken to foreclose the same, the makers will pay an attorney's fee as therein provided, and that the same shall be a further charge and lien on said premises. 10. That after allowing all just credits there is due to Plaintiff on said note and mortgage the sum of $346,262.66, with 8% interest per annum thereon from September 18, 2025, until paid; said abstract expense of a reasonable amount with interest thereon, until paid; title search and examination expenses of a reasonable amount with interest per annum thereon, until paid; and a reasonable attorney's fee, and for all costs of this action; and for all charges due under the terms of the note and mortgage, and for such sums as may have been advanced since default on the indebtedness herein sued upon or may be hereafter advanced or incurred by Plaintiff through completion of this action, including taxes, recording fees, assessments, hazard insurance premiums, expenses reasonably necessary for the preservation of the subject property, or of the priority of Plaintiff's first mortgage lien, and further including costs, expenses and attorneys fees incurred in any bankruptcy instituted by any party defendant and all expenses, costs and attorneys fees of execution and sale, including poundage upon sale and that said amounts are secured by said mortgage and constitute a first, prior and superior lien upon the real estate and premises above described. 11. That said mortgage specifically provides that appraisement of said property is expressly waived or not waived at the option of the mortgagee. 12. Plaintiff further alleges as follows: (a) That SB Exotic Auto Sales, LLC, executed a Security Agreement dated December 12, 2024, covering 1983 Chevrolet C-10 Pickup VIN number 1GCDC14H5DF363248; 1966 Cadillac De Vile Coupe NIM number F6215403; 1984 GMC 1500 Pickup VIN number 1GTDC14H5EJ516001; 2014 Chevrolet Corvette Stingray VIN number 1G1YM2D70E51006011; 2006 Ferrari F430 VIN number 2FFEW59A580160675, attached hereto as Exhibit “C”. (b) That B Scott Brown, executed a Security Agreement dated December 12, 2024, covering any and all Livestock and all farm products, including but not limited to all poultry and livestock now owned or hereafter acquired and their natural increase along with their produce, products and replacements: all crops, now growing or to be grown in this year and succeeding years and all products of the crops wherever stored and any document of title or other document representing a storage obligation, including but not limited to warehouse receipts, negotiable or non-negotiable, which may be received for crops owned by the Debtor but stored off the farm, and all feed, seed, fertilizer, medicines and other supplies used or produced in Debtor’s farming operations, attached hereto as Exhibit “D”. (c) That there appears a Notice of Possessory Lien and Notice of Sale by James Voyles and Classic Corner Iconic Cars, claiming a lien and right to sell the 1984 GMC 1500 Pickup VIN number 1GTDC14H5EJ516001; that said Notice of Possessory Lien and Notice of Sale do not meet the notice requirements of Service Oklahoma, attached hereto as Exhibit “E”. (d) That Plaintiff believes and alleges that the 2014 CHEVROLET CORVETTE STINGRAY, Vin #1G1YM2D70E5106011, is held at Classic Corner Iconic Cars and/or the residence of B. Scott Brown, and that defendant has failed and refused to turn the subject property over to the plaintiff as required by the terms of not, mortgage, security agreements, and loan modification. That Billy Scott Brown, B. Scott Brown and Scott Brown are one and the same person as Billy S. Brown, defendant herein. That the defendants, Billy S. Brown; Retzel L. Brown; James Voyles; Classic Corner Iconic Cars; SB Exotic Auto Sales LLC; Occupants of the Premises, if any, may be claiming some right, title, lien, estate, encumbrance, claim, assessment or interest in or to the real estate and premises involved herein adverse to the Plaintiff, which constitutes a cloud upon the title of Plaintiff, but that any right, title, lien, estate, encumbrance, claim, assessment or interest, either in law or in equity which said defendants, or any or either of them may have or claim to have, is subsequent, junior and inferior to the first mortgage lien of the Plaintiff. That said interest or claims arising by reason of the foregoing facts and circumstances, as well as any other right, title or interest which the defendants named herein, or any or either of them have or claim to have, in or to said real estate and premises is subsequent, junior and inferior to the mortgage and lien of the Plaintiff. 13. In accordance with the Fair Debt Collection Practices Act, Title 15 U.S.C.A. Sec.1692(g), if applicable, unless the person or entity responsible for the payment of the above debt, within thirty days after receipt of this notice, disputes the validity of the debt, or any portion thereof, the debt will be assumed to be valid; and if said person or entity notifies the undersigned attorney for Plaintiff in writing within said thirty day period that the debt, or any portion thereof, is disputed, said attorney will obtain verification of the debt and a copy of such verification will be mailed to said person or entity by the undersigned attorney for Plaintiff; and upon written request by you within the thirty day period, the undersigned attorney for Plaintiff will provide the name and address of the original creditor, if different from the current creditor. WHEREFORE, Plaintiff prays judgment against SB Exotic Auto Sales, LLC, Billy S. Brown and Retzel L. Brown, in the sum of $346,262.66, with 8% interest per annum thereon from September 18, 2025, until paid; abstract expense of a reasonable amount, with interest thereon, until paid; title search and examination expenses of a reasonable amount with interest per annum thereon, until paid; and a reasonable attorney's fee, and for all costs of this action; and for all charges due under the terms of the note and mortgage, and for such sums as may have been advanced since default on the indebtedness herein sued upon or may be hereafter advanced or incurred by Plaintiff through completion of this action, including taxes, recording fees, assessments, hazard insurance premiums, expenses reasonably necessary for the preservation of the subject property, or of the priority of Plaintiff's first mortgage lien, and further including costs, expenses and attorneys fees incurred in any bankruptcy instituted by any party defendant and all expenses, costs and attorneys fees of execution and sale, including poundage upon sale, on any judgment hereafter entered in this cause, including poundage upon sale, and for all costs of this action. And for a further judgment against all of the Defendants in and to this cause adjudging: That all of the Defendants herein be required to appear and set forth any right, title, claim or interest which they have, or may have, in and to said real estate and premises; and That said mortgage be foreclosed and that the same be declared a valid first, prior and superior lien upon the real estate hereinbefore described, for and in the amounts above set forth, and ordering said real estate and premises sold, for cash, with or without appraisement, as the Plaintiff may elect at the time judgment is entered as provided in said mortgage and by law, subject to unpaid taxes, advancements by Plaintiff for taxes, insurance premiums, or expenses necessary for the preservation of the subject property, if any, to satisfy said judgment, and that the proceeds arising therefrom be applied to the payment of the costs herein, and the payments and satisfaction of the judgment, mortgage and lien of this Plaintiff, and that the surplus, if any, be paid into Court to abide the further order of the Court. That should the proceeds of sale be insufficient to pay the Plaintiff's judgment and upon application of Plaintiff and hearing, a deficiency judgment be awarded to Plaintiff against such Defendants as may be personally liable therefor, all as provided by law. That all right, title and interest of said Defendants, and each of them, if any, in and to said real estate, be adjudged subject, junior and inferior to the mortgage lien and judgment of this Plaintiff, and that upon confirmation of such sale, the Defendants herein, and each of them, and all persons claiming by, through or under them since the commencement of this action, be forever barred, foreclosed and enjoined from asserting or claiming any right, title, interest, estate or equity of redemption in or to said premises, or any part thereof; That this Plaintiff have such other and further relief as may be just and equitable. SECOND CAUSE OF ACTION- REPLEVIN Pursuant to 12 O.S. 1571, Plaintiff seeks a remedy of Replevin, specifically: 14. The prior allegations are incorporated herein by reference. 15. Defendant, Scott Brown and/or SB Exotic Auto Sales LLC, owns, and Plaintiff, Citizens State Bank, holds a priority lien, on a 1984 GMC 1500 Pickup VIN number 1GTDC14H5EJ516001, which Defendant, James Voyles, dba Classic Corner Iconic Cars, was entrusted to sell. 16. Scott Brown and/or SB Exotic Auto Sales LLC, is the lawful owner of the 1984 GMC 1500 Pickup VIN number 1GTDC14H5EJ516001, subject to the priority lien of Plaintiff. 17. Defendant, James Voyles, dba Classic Corner Iconic Cars, took possession of the 1984 GMC 1500 Pickup VIN number 1GTDC14H5EJ516001. It is believed the vehicle is presently stored as 3920 NW 39th St., Oklahoma City, OK. 18. Plaintiff, Citizens State Bank has communicated with Defendants and requested a return of the vehicle due to the default on the loans set forth herein. 19. Although requested, the Plaintiff has not been provided access to the vehicle or a return of the vehicle by Defendants. Accordingly, Plaintiff has been denied his right to possession, because Defendant continues to unlawfully possess this vehicle without proper notice, or right. 20. Upon knowledge and belief, Defendant has unlawfully taken and kept possession of the 1984 GMC 1500 Pickup VIN number 1GTDC14H5EJ516001 to the exclusion of Plaintiff, and the same should be turned over to Plaintiff. 21. Defendant has violated the priority rights of Citizens State Bank, and he should be liable for damages, costs and attorney's fees, and should be required to turn over the 1984 GMC 1500 Pickup VIN number 1GTDC14H5EJ516001, without further delay. 22. Plaintiff is entitled to a reasonable attorney's fee and its other reasonable costs of this action under 12 O.S. Supp. 1981§ 936. 23. Due to the Defendant's actions, Plaintiff has a special ownership of interest in the 1984 GMC 1500 Pickup VIN number 1GTDC14H5EJ516001, seeks and its entitled to immediate possession of the 1984 GMC 1500 Pickup VIN number 1GTDC14H5EJ516001. 24. The actual value of the Collateral is estimated at $22s,000.00. 25. It is believed the 1984 GMC 1500 Pickup VIN number 1GTDC14H5EJ516001 has not been taken in execution on any Order of Judgment against Defendant, Scott Brown and/or SB Exotic Auto Sales, LLC, or for the payment of any tax, fine or amercement assessed against Defendant, Scott Brown and/or SB Exotic Auto Sales, LLC, or by virtue of an Order of Delivery issued under Chapter 31 of Title 12 of the Oklahoma Statutes, or any other means or final process issued against Defendant, Scott Brown and/or SB Exotic Auto Sales, LLC. 26. Plaintiff believes the Defendant is in actual or constructive possession of the 1984 GMC 1500 Pickup VIN number 1GTDC14H5EJ516001 and Defendant's possession is subject to the rights of the Plaintiff. Defendant has failed to deliver or relinquish possession of the 1984 GMC 1500 Pickup VIN number 1GTDC14H5EJ516001 to Plaintiff. Defendant is therefore wrongfully detaining the 1984 GMC 1500 Pickup VIN number 1GTDC14H5EJ516001. 27. Plaintiff believes Defendant may attempt to conceal, damage or destroy the 1984 GMC 1500 Pickup VIN number 1GTDC14H5EJ516001 or a part thereof or to remove the 1984 GMC 1500 Pickup VIN number 1GTDC14H5EJ516001 from the State or County, and Plaintiff will thereby suffer irreparable harm. Plaintiff is without adequate remedy at law to prevent such harm and injury. 28. Plaintiff hereby requests the issuance of an Order for Delivery for the recovery of the 1984 GMC 1500 Pickup VIN number 1GTDC14H5EJ516001. Plaintiff further requests the Clerk of this Court issue a Notice to be served upon the Defendant(s) which Notice shall notify Defendant: (a.) An Order of Delivery of the 1984 GMC 1500 Pickup VIN number 1GTDC14H5EJ516001 is sought; (b.) Defendant has the right to object by written response filed with the Court Clerk and delivered or mailed to Plaintiff's attorney within five (5) days after service of the Petition; and (c.) The Order for Delivery shall be issued by the Clerk in the event no written response is filed within the five (5) day period. 29. This is an attempt to collect a debt and any information obtained will be used for that purpose. THIRD CAUSE OF ACTION—REPLEVIN Pursuant to 12 O.S. 1571, Plaintiff seeks a remedy of Replevin, specifically: 30. The prior allegations are incorporated herein by reference. 31. Defendant, Scott Brown and/or SB Exotic Auto Sales LLC, owns, and Plaintiff, Citizens State Bank, holds a priority lien, on a 2014 CHEVROLET CORVETTE STINGRAY, Vin #1G1YM2D70E5106011. 32. Scott Brown and/or SB Exotic Auto Sales LLC, is the lawful owner of the 2014 CHEVROLET CORVETTE STINGRAY, Vin #1G1YM2D70E5106011, subject to the priority lien of Plaintiff. 33. Defendant, Scott Brown and/or SB Exotic Auto Sales LLC, hold possession of the 2014 CHEVROLET CORVETTE STINGRAY, Vin #1G1YM2D70E5106011. Plaintiff believes and alleges that the vehicle’s whereabouts are presently being concealed by Defendants, Scott Brown and/or SB Exotic Auto Sales LLC. 34. Plaintiff, Citizens State Bank has communicated with Defendants and requested a return of the vehicle due to the default on the loans set forth herein. 35. Although requested, the Plaintiff has not been provided access to the vehicle or a return of the vehicle by Defendants. Accordingly, Plaintiff has been denied his right to possession, because Defendant continues to unlawfully possess this vehicle without proper notice, or right. 36. Upon knowledge and belief, Defendant has unlawfully retained and concealed possession of the 2014 CHEVROLET CORVETTE STINGRAY, Vin #1G1YM2D70E5106011 to the exclusion of Plaintiff, and the same should be turned over to Plaintiff. 37. Defendants, Scott Brown and/or SB Exotic Auto Sales LLC, have violated the priority rights of Citizens State Bank, and he should be liable for damages, costs and attorney’s fees, and should be required to turn over the 12014 CHEVROLET CORVETTE STINGRAY, Vin #1G1YM2D70E5106011, without further delay. 38. Plaintiff is entitled to a reasonable attorney’s fee and its other reasonable costs of this action under 12 O.S. Supp. 1981 § 936. 39. Due to the Defendant’s actions, Plaintiff has a special ownership of interest in the 2014 CHEVROLET CORVETTE STINGRAY, Vin #1G1YM2D70E5106011, seeks and its entitled to immediate possession of the 2014 CHEVROLET CORVETTE STINGRAY, Vin #1G1YM2D70E5106011. 24. The actual value of the Collateral is estimated at $50,000.00. 25. It is believed the 2014 CHEVROLET CORVETTE STINGRAY, Vin #1G1YM2D70E5106011 has not been taken in execution on any Order of Judgment against Defendant, Scott Brown and/or SB Exotic Auto Sales, LLC, or for the payment of any tax, fine or amercement assessed against Defendant, Scott Brown and/or SB Exotic Auto Sales, LLC, or by virtue of an Order of Delivery issued under Chapter 31 of Title 12 of the Oklahoma Statutes, or any other means or final process issued against Defendant, Scott Brown and/or SB Exotic Auto Sales, LLC. 26. Plaintiff believes the Defendant is in actual or constructive possession of the 2014 CHEVROLET CORVETTE STINGRAY, Vin #1G1YM2D70E5106011 and Defendant’s possession is subject to the rights of the Plaintiff. Defendant has failed to deliver or relinquish possession of the 2014 CHEVROLET CORVETTE STINGRAY, Vin #1G1YM2D70E5106011 to Plaintiff. Defendant is therefore wrongfully detaining the 2014 CHEVROLET CORVETTE STINGRAY, Vin #1G1YM2D70E5106011. 27. Plaintiff believes Defendants may attempt to conceal, damage or destroy the 2014 CHEVROLET CORVETTE STINGRAY, Vin #1G1YM2D70E5106011 or a part thereof or to remove the 2014 CHEVROLET CORVETTE STINGRAY, Vin #1G1YM2D70E5106011 from the State or County, and Plaintiff will thereby suffer irreparable harm. Plaintiff is without adequate remedy at law to prevent such harm and injury. 28. Plaintiff hereby requests the issuance of an Order for Delivery for the recovery of the 2014 CHEVROLET CORVETTE STINGRAY, Vin #1G1YM2D70E5106011. Plaintiff further requests the Clerk of this Court issue a Notice to be served upon the Defendant(s) which Notice shall notify Defendant: (a.) An Order of Delivery of the 2014 CHEVROLET CORVETTE STINGRAY, Vin #1G1YM2D70E5106011 is sought; (b.) Defendant has the right to object by written response filed with the Court Clerk and delivered or mailed to Plaintiff's attorney within five (5) days after service of the Petition; and (c.) The Order for Delivery shall be issued by the Clerk in the event no written response is filed within the five (5) day period. 29. This is an attempt to collect a debt and any information obtained will be used for that purpose. Signed and dated this 9th, day of April, 2026. ATTORNEYS' LIEN CLAIMED. LAMUN MOCK CUNNYNGHAM & DAVIS, P.C. Kelly M. Parker, OBA#22673 LAMUN MOCK CUNNYNGHAM & DAVIS, P.C. 5621 N. Classen Blvd. Oklahoma City, OK 73118 (405) 840-5900 Fax (405) 842-3132 [email protected] Attorney for Plaintiff (Original Borrower: Billy S. Brown; Property Address: 10509 North 1970 Road Elk City, OK 73644) EXHIBIT "A" PAGE 1 OF 2 PAGES DCN PRE-AUTHORIZED PAYMENTS: This payment is preauthorized for periodic payments, in whole or in part, at any time, without notice or minimum charge of $25.00. However, my remaining payments will continue to be due until this note is paid in full. LATE PAYMENT: If a payment is more than 10 days late, Debtor will be charged late fees of $5% of the payment amount or $1500, whichever is less. DEFAULT: I will be in default if: 1. I fail to make a payment when due; or 2. All good faith believe that the prospect of repayment of this note is impaired or insecure; or 3. I default under any other document executed in connection with or as security for this note (the "Loan Documents"); or 4. For any reason, this note, or the Loan Documents, becomes nonenforceable; has a proceeding supplementary to or in enforcement of a judgment commenced with respect to any collateral property described under or in connection with this note become unsupportable; the Debtor has furnished or furnishes any information or representation which is materially incorrect; if the note is payable on demand, then I understand and agree that you may demand payment at any time, at your option, with or without notice, without causing a breach of contract; balance due on this note at any time for whatever exchanged purposes, except from not in default. Upon the occurrence of any such event described above, Lender may, at its option and with or without acceleration of the balance, increase the interest rate on this note to the Maximum Rate. NOTICE: Any notice to me will be considered given when deposited in the U.S. Mail postage prepaid, addressed to me at the address shown above or at any other address that I shall notify you in writing. Such notice shall be served by first class mail with return receipt requested within one year unless notice of mailing delivered herewith is signed by me or my attorney in person at the time and place of delivery thereof. Such mailing shall be sufficient proof of notice to me. ADDITIONAL INFORMATION: Notices or provides for notices will be provided to you all information reasonably required by you pertaining to matters affecting the financial status of the borrower. REMEDIES: If I am in default, then you may, after giving any notice required by law: 1. Require me to immediately pay to you the entire balance due on this Note, including under the Loan Documents and all interest thereon; 2. Take any other remedy that you have under this Note, the Loan Documents or applicable law; 3. Offset, give you a first lien security interest in all of my deposits and other property subject to me in your control or possession as collateral security for the note, without any notice or demand to me and without liability for any subsequent sale or realization upon all or any portion of such deposits and other property until all amounts owed or secured hereunder have been satisfied in full, and/or apply offset of any and all such deposits and other property against any amounts due on any notes, order or other obligation connected with this note and any order of preference attaching to your claims under the note. OBTAINING YOUR RIGHTS: You may waive for any day, entirely any of your rights represented on the Loan Documents without losing them. Nothing herein releases or partially payments. Even though the note matures in full, all of your rights under this note survive the maturity and you may collect the entire balance due unless this note is paid in full at that time. This note does not relieve you of any of your obligations under this note. Any modification of any of my promises under this note is not binding unless made in writing and signed by both parties to the note. PAYMENTS: If I am unable to otherwise, my payments are authorized to be disbursed by you directly between principal and interest as determined by you in accordance with the terms of this note. Any notice or demand required by law or by the Loan Documents is sufficient if delivered to me at the address shown above. COLLECTION COSTS: If you are forced to take collection action, I will pay your reasonable collection costs, including reasonable attorneys' fees. I will not be liable for attorney's fees or expenses for amounts allowed by applicable law. MAXIMUM RATE: The Maximum Rate means: the maximum non-usurious rate of interest permitted by applicable law. If a state law limits the maximum rate, the Maximum Rate means that rate. However, the maximum rate permitted by federal law will also be the maximum rate permitted by applicable state law. The Maximum Rate applies by taking into account all amounts characterized by applicable law as interest to the extent such rates authorize such maximum amount permitted by applicable law. INTEREST AND OTHER CHARGES: In no way nor in any event may the interest or other charges contracted for charged, or received under or in connection with this note or the Loan Documents exceed the Maximum Rate or any amount allowed by applicable law. Any amount in excess of the maximum is a mistake and is canceled automatically, or if already paid, will be credited on the principal amount of this note or refunded to me, at your option. APPLICABLE LAW: This note is governed by Texas law, and applicable laws including, to the extent permitted by applicable laws, any future amendments of such laws or any new laws coming into effect in the future to the extent a higher rate of interest is permitted by any such amendment or new law. NOTICE OF CLAIMS: I will not make any claim, bring any suit, or otherwise assert a cause of action, claim, counterclaim or defense in or related to this note, the Loan Documents, or any applicable laws unless a court of competent jurisdiction determines at any time it believes in discovery that any term of this note is unconstitutional, invalid, or any action taken by you in connection with this note may be a violation of any duty occasioned by law then it will: 1. Immediately notify you specifying with particularity the nature and extent of such violation; and 2. Afford you a reasonable time (of not less than 60 days) in which to cure the violation. ENTIRE AGREEMENT: This note and the Loan Documents are the entire agreement between me and you with respect to my debts. There are no oral conditions, representations or commitments affecting balance or any of the other Loan Documents. An extension modification in the terms of payment, release of any liability, or satisfaction of notes held in whole or in part or exchange for collateral or otherwise is not effective unless it is in writing and signed by your authorized officer. SUFFICIENCY/TERM OF PROVISIONS: NOTICE OF CONFIDENTIALITY RIGHTS: IF YOU ARE A NATURAL PERSON, YOU MAY REMOVE OR STRIKE ANY OR ALL OF THE FOLLOWING INFORMATION FROM ANY INSTRUMENT THAT TRANSFERS AN INTEREST IN REAL PROPERTY BEFORE IT IS FILED FOR RECORD IN THE PUBLIC RECORDS: YOUR SOCIAL SECURITY NUMBER OR YOUR DRIVER'S LICENSE NUMBER. EXTENSION AND MODIFICATION OF LOAN Date: Effective September 18, 2025 Note: Date: December 12, 2024 Original Amount: $372,294.66 Maker: B. SCOTT BROWN Payee: Citizens State Bank Modified Principal Amount: $346,262.66 Holder of Note and Lien: CITIZENS STATE BANK Holder's Mailing Address: P.O. Box 1510, San Angelo, Texas 76902 Obligor: BILLY SCOTT BROWN, aka BILLY S. BROWN, aka B. SCOTT BROWN and RETZEL L. BROWN, husband and wife Obligor's Mailing Address: 10509 N. 1970 Road, Elk City, Beckham County, Oklahoma 73644 Note and Liens are Described in the Following Documents, Recorded in: Promissory Note and Security Agreement covering the personal property described below and dated, December 12, 2024 executed by B. Scott Brown, for the benefit of CITIZENS STATE BANK; further secured by Real Estate Mortgage with Power of Sale to be recorded in the real property records of Beckham County, Oklahoma covering the real property described below. Property (including any improvements) Subject to Lien: Real Property: Lots Seven (7), Eight (8), Nine (9), Ten (10), Eleven (11), and Twelve (12) in Block Eighty-One (81) of the Original Town of Elk City, Beckham County, Oklahoma. Vehicles: 1983 Chevrolet C-10 pickup, VIN 1GCDC14H5DF363248; 2008 F430 Ferrari, VIN 2FFEW59A580160675; 1984 GMC C1500 Pickup VIN 1GTDC14H5EJ516001; and 2014 Chevrolet Corvette Stingray VIN 1G1XM2D70E5106011. Modified Terms: (1) Payments of Principal and Interest: Principal and interest are payable in monthly installments of $1,000.00 each, with the first of such installment being due and payable on October 18, 2025, and continuing regularly each month on the 18th day of every month thereafter until March 18, 2026, when all remaining unpaid principal and accrued interest is due and payable in full. Interest will be calculated on the unpaid principal to the date of each installment paid. Payments will be credited first to the accrued interest and then to reduction of principal. (2) Annual interest rate on unpaid principal balance: 8% per annum. Interest on this note is computed on a 365/360 simple interest basis; that is, in applying the ratio of the annual interest rate over a year consisting of 360 days, times the outstanding principal balance, times the actual number of days the principal balance is outstanding shall be the interest accrued, unless such calculation would result in a usurious rate, in which case interest shall be calculated on a per diem basis of a year of 365 or 366 days, as the case may be. (3) Annual interest rate on matured, unpaid amount: All past due principal and interest shall bear interest from maturity thereof until paid at the rate of 18% per annum. (4) Extended Maturity Date: March 18, 2026. (5) The undersigned for and in consideration of the above-referenced lender extending credit or agreeing to the terms stated herein, if requested by lender or Closing agent for lender, to fully cooperate and adjust for clerical errors in any or all loan closing documentation if deemed necessary or desirable in the reasonable discretion of lender, and promptly execute and deliver such additional documents as requested by lender. Agreement to Extend: The Loan Agreement, Note and the Lien Documents continue as written, except as provided in this agreement. The Note is secured by a lien against the Property. Whether Obligor is primarily liable on the Note or not, Obligor nevertheless agrees to pay the Note and comply with the obligations expressed in the Lien Documents and Loan Agreement. Obligor warrants and represents that the facts recited above are true and correct. Obligor reaffirms each of the representations, warranties, covenants, and agreements of Obligor set forth in the Loan Agreement, Note and the Lien Documents, with the same force and effect as if each were separately stated herein. Obligor warrants and represents that no event has occurred and no condition exists which would constitute a default under the Loan Agreement, Note and the Lien Documents, either with or without notice or lapse of time, or both. For value received, Obligor renews the Note and promises to pay to the order of Holder of Note and Lien, according to the Modified Terms, the Unpaid Principal and Interest on Note. All unpaid amounts are due by the Extended Maturity Date of Note. Obligor also extends the liens described in the Lien Documents. Obligor warrants to Holder of Note and Lien that the Note and the Lien Documents, as modified, are valid and enforceable and represents that they are not subject to rights of offset, rescission, or other claims. Obligor waives all demands for payment, presentations for payment, notices of intention to accelerate maturity, notices of acceleration of maturity, protests, notices of protest, rights under Sections 51.003, 51.004, and 51.005 of the Texas Property Code, and rights under Section 17.001 and Chapter 43 of the Texas Civil Practice and Remedies, to the extent permitted by law. A default exists under this note if (1) Obligor defaults in the payment of this note or in the performance of any obligation in any instrument securing or collateral to this note; (2) (a) Obligor or (b) any other party liable on any part of this note or any instrument securing or collateral to this note (an “Other Obligated Party”) fails to timely pay or perform any obligation or covenant in any written agreement between Holder and Obligor or any Other Obligated Party; (3) any representation in this Agreement, the Note or in any other written agreement between Holder and Obligor or any Other Obligated Party is materially false when made; (4) a receiver is appointed for Obligor or an Other Obligated Party or any property on which a lien or security interest is created as security (the “Collateral Security”) for any part of this Note; (5) any property mortgaged or pledged as security is assigned for the benefit of creditors; (6) a bankruptcy or insolvency proceeding is commenced by Obligor or an Other Obligated Party; (7) (a) a bankruptcy or insolvency proceeding is commenced against Obligor or an Other Obligated Party and (b) the proceeding continues without dismissal for 60 days, the party against whom the proceeding is commenced admits the material allegations of the petition against it, or an order for relief is entered; (8) Obligor or an Other Obligated Party is terminated, begins to wind up its affairs, or is authorized to terminate or wind up its affairs by its governing body or persons, or any event occurs or condition exists that permits the termination or winding up of the affairs of Obligor or an Other Obligated Party; or (9) any property mortgaged or pledged as security for this note is impaired by loss, theft, damage, levy and execution, issuance of an official writ or order of seizure, or destruction, unless it is promptly replaced with collateral security of like kind and quality or restored to its former condition. When the context requires, singular nouns and pronouns include the plural. THE TERMS OF THE NOTE AND THIS MODIFICATION SHALL BE CONSTRUED IN ACCORDANCE WITH THE LAWS OF THE STATE OF TEXAS AND IS PERFORMABLE IN TOM GREEN COUNTY TEXAS WHERE ANY ACTION TO ENFORCE THE TERMS AND CONDITIONS OF THE NOTE SHALL BE HELD. HOWEVER, ANY FORECLOSURE OF THE HOLDER'S LIEN OR LIENS SHALL BE HAD IN ACCORDANCE WITH THE MORTGAGE, DEED OF TRUST, SECURITY AGREEMENT OR OTHER LIEN DOCUMENT OR DOCUMENTS GIVEN TO SECURE THE NOTE. JURY WAIVER. OBLIGOR HEREBY WAIVES THE RIGHT TO ANY TRIAL BY JURY IN ANY ACTION, PROCEEDING, OR COUNTERCLAIM BROUGHT BY EITHER OBLIGOR OR HOLDER AGAINST THE OTHER. IN CONSIDERATION OF (I) THE RENEWAL, EXTENSION AND/OR MODIFICATION OF CERTAIN PROVISIONS OF THE NOTE AND THE LIEN DOCUMENTS AS HEREIN PROVIDED AND (II) THE OTHER BENEFITS RECEIVED BY OBLIGOR AND ANY GUARANTORS, OBLIGOR AND GUARANTORS, IF ANY, HEREBY RELEASE, RELINQUISH AND FOREVER DISCHARGE HOLDER, AS WELL AS ITS PREDECESSORS, SUCCESSORS, ASSIGNS, AGENTS, ATTORNEYS, OFFICERS, DIRECTORS, EMPLOYEES, AND REPRESENTATIVES (TOGETHER, THE "RELEASED PARTIES"), OF AND FROM ANY AND ALL CLAIMS, DAMAGES (DIRECT OR CONSEQUENTIAL), CAUSES OF ACTION, COSTS, AND EXPENSES OF ANY KIND WHATSOEVER, IN LAW OR IN EQUITY, AT COMMON LAW, STATUTORY, OR OTHERWISE, WHICH OBLIGOR AND/OR GUARANTORS, IF ANY, HAVE OR MAY HAVE AGAINST THE RELEASED PARTIES (OR ANY OF THEM), WHETHER KNOWN OR UNKNOWN, OCCURRING PRIOR TO THE DATE OF THIS AGREEMENT AND WHICH ARE DIRECTLY OR INDIRECTLY, ATTRIBUTABLE TO OR ARISING OUT OF THE COLLATERAL, THE NOTE, OR THE LIEN DOCUMENTS, INCLUDING WITHOUT LIMITATION, CLAIMS BASED UPON: BREACH OF FIDUCIARY DUTY, BREACH OF ANY DUTY OF FAIR DEALING, BREACH OF CONFIDENCE, UNDUE INFLUENCE, FRAUD, UNCONSCIONABILITY, DURESS, ECONOMIC DURESS OR COERCION, CONTROL, CONFLICT OF INTEREST, MISUSE OF INSIDER INFORMATION, NEGLIGENCE, GROSS NEGLIGENCE, BAD FAITH, MALPRACTICE, VIOLATIONS OF THE RACKETEER INFLUENCED AND CORRUPT ORGANIZATION ACT, INTENTIONAL OR NEGLIGENT INFlictION OF EMOTIONAL DISTRESS, TORTIOUS INTERFERENCE WITH CONTRACTUAL OR BUSINESS RELATIONS, TORTIOUS INTERFERENCE WITH CORPORATE GOVERNANCE OR PROSPECTIVE BUSINESS ADVANTAGE, USURY, WRONGFUL SETOFF, ENVIRONMENTAL DUE DILIGENCE, VIOLATIONS OF THE TEXAS DECEPTIVE TRADE PRACTICES/CONSUMER PROTECTION ACT, LIBEL, SLANDER, CONSPIRACY, THE ILLEGALITY, UNENFORCEABILITY, OR ALLEGED BREACH OF THE LOAN DOCUMENTS, THE ENFORCEMENT OF THE LOAN DOCUMENTS, THE CONDITION OF THE COLLATERAL, MISUSE OF COLLATERAL, WRONGFUL RELEASE OF COLLATERAL, FAILURE TO INSPECT, AND ANY ACTS OF OMISSION OR COMMISSION, REPRESENTATIONS OR WARRANTIES, ALLEGED TO HAVE OCCURRED OR BEEN MADE BY HOLDER, ITS TRUSTEES, AGENTS, SERVANTS, EMPLOYEES, OFFICERS, SHAREHOLDERS, OR ATTORNEYS IN CONNECTION WITH THE LOAN DOCUMENTS, THE COLLATERAL, OR THE LOAN AND/OR ITS SOLICITATION, PROCESSING, APPROVAL, CLOSING, ADMINISTRATION, COLLECTION, OR ENFORCEMENT. OBLIGOR AND GUARANTORS, IF ANY, FURTHER AGREE TO LIMIT ANY DAMAGES THAT THEY MAY SEEK IN CONNECTION WITH ANY CLAIM OR CAUSE OF ACTION, IF ANY, TO EXCLUDE ALL PUNITIVE AND EXEMPLARY DAMAGES, DAMAGES ATTRIBUTABLE TO LOST PROFITS OR OPPORTUNITY, DAMAGE ATTRIBUTABLE TO MENTAL ANGUISH, AND DAMAGES ATTRIBUTABLE TO PAIN AND SUFFERING, AND DAMAGES WHICH MAY ARISE AT ANY TIME AGAINST ANY OF THE RELEASED PARTIES. OBLIGOR AND GUARANTORS, IF ANY, FURTHER COVENANT NOT TO SUETHE RELEASED PARTIES ON ACCOUNT OF ANY OF THE MATTERS DESCRIBED IN THIS PARAGRAPH AND EXPRESSLY WAIVE ANY AND ALL DEFENSES OBLIGOR AND GUARANTORS, IF ANY, MAY HAVE IN CONNECTION WITH OBLIGOR'S AND GUARANTOR'S, IF ANY, DEBTS AND OBLIGATIONS UNDER THE LOAN DOCUMENTS AND THIS AGREEMENT. THIS LOAN IS PAYABLE IN FULL ON OR BEFORE THE MATURITY DATE. AT MATURITY, OBLIGOR MUST REPAY THE LOAN AND UNPAID INTEREST THEN DUE. THE HOLDER IS UNDER NO OBLIGATION TO REFINANCE THE LOAN AT THAT TIME. OBLIGOR WILL, THEREFORE, BE REQUIRED TO MAKE PAYMENT OUT OF OTHER ASSETS OWNED, OR OBLIGOR WILL HAVE TO FIND A LENDER, WHICH MAY BE HOLDER, WHICH IS WILLING TO LEND THE MONEY. IF OBLIGOR REFINANCES THIS LOAN AT MATURITY, OBLIGOR MAY HAVE TO PAY ONE OR ALL OF THE CLOSING COSTS NORMALLY ASSOCIATED WITH A NEW LOAN EVEN IF OBLIGOR OBTAINS REFINANCING FROM THE SAME BANK. THIS WRITTEN LOAN AGREEMENT REPRESENTS THE FINAL AGREEMENT BETWEEN THE PARTIES AND MAY NOT BE CONTRADICTED BY EVIDENCE OF PRIOR, CONTEMPORANEOUS, OR SUBSEQUENT ORAL AGREEMENTS OF THE PARTIES. THERE ARE NO UNWRITTEN ORAL AGREEMENTS BETWEEN THE PARTIES. BILLY S. BROWN aka BILLY SCOTT BROWN RETZEL L. BROWN HOLDER OF NOTE AND LIEN: CITIZENS STATE BANK BY: ____________________________ Its: PRES : CEO W. Dean Feathers Citizens State Bank - NMLS# 552037 STATE OF Oklahoma § COUNTY OF Collin § This instrument was acknowledged before me on the 22 day of December, 2025 by BILLY S. BROWN aka BILLY SCOTT BROWN and REETZEL L. BROWN. T. JAMESON Notary Public In and for State of Oklahoma 21008801 My Commission Expires Jun. 30, 2029 THE STATE OF TEXAS § COUNTY OF TOM GREEN § This instrument was acknowledged before me on the 22 day of December, 2025 by W. DEAN FEATHERS, as President of CITIZENS STATE BANK, on behalf of said bank and in the capacity therein stated. BROOKLYNN ROSE SMETANA Notary ID #132685441 My Commission Expires September 18, 2028 Brooklynn Rose Smetana Notary Public, State of Texas AFTER RECORDING RETURN TO: CITIZENS STATE BANK P.O. Box 1510 San Angelo, Texas 76902 PREPARED IN THE LAW OFFICE OF: GOSSETT, HARRISON, MILLCAN, STIPANOVIC, P.C. 2 South Koenighein San Angelo, Texas 76903 EXHIBIT C 1 OF 3 PAGES EXHIBIT C. 2 OF 3 PAGES [Redacted] SECURITY AGREEMENT This Agreement made as of [DATE] by and between [COMPANY NAME], a Delaware corporation (the "Borrower"), and [SECURITY AGENT NAME], as trustee for the benefit of Secured Parties (the "Security Agent"). RECITALS: A. The Borrower has requested and the Secured Parties have agreed to provide revolving credit facilities to the Borrower. B. As security for the payment and performance of the Obligations, and subject to the terms and conditions set forth herein, the Borrower wishes to grant unto the Secured Parties a Lien on certain of its assets described in Schedule A attached hereto as Exhibit "A" (the "Collateral"). NOW, THEREFORE, in consideration of the premises and of the mutual covenants contained herein, and intending to be legally bound hereby, the parties agree as follows: I. GRANT OF SECURITY INTEREST. The Borrower hereby grants unto the Secured Parties, for the benefit of itself and its Affiliates, a continuing security interest in the Collateral, including without limitation all right, title and interest of the Borrower therein, whether now owned or hereafter acquired, whether now existing or hereafter arising, whether acquired by purchase, gift, inheritance, transfer, operation of law or otherwise, whether credited on account of principal, premium, interest, fees, charges or otherwise, and whether or not at the time of acquisition owned by the Borrower free and clear of any claim or encumbrance, to secure the payment and performance of all Obligations (hereinafter collectively referred to as the "Obligations"). II. SECURITY AGENT'S RIGHTS AND POWERS. The Secured Parties shall have all rights and powers as provided herein and as may be necessary for the enforcement of the obligations of the Borrower under this Agreement. Without limiting the generality of the foregoing, the Secured Parties shall have all of the rights and remedies set forth in Sections 364, 510 and 541 through 547 of the Bankruptcy Code. III. REPRESENTATIONS AND WARRANTIES. The Borrower represents and warrants to the Secured Parties that: (a) This Agreement has been duly authorized, executed and delivered by the Borrower, and constitutes a valid and binding agreement of the Borrower enforceable against it in accordance with its terms; (b) The Borrower owns the Collateral free and clear of any lien, encumbrance or other security interest except those granted pursuant to this Agreement; (c) Since the date of the latest financial statement delivered to the Secured Parties, there has been no event or condition that has had or would reasonably be expected to have a material adverse effect on the business, operations or financial condition of the Borrower; (d) All documents and instruments delivered by the Borrower in connection with this Agreement are true and correct copies of the documents and instruments delivered by the Borrower; (e) The Borrower has delivered to the Secured Parties all documents and information required to be delivered pursuant to the provisions of this Agreement; and (f) All representations and warranties of the Borrower contained herein are true and correct in all respects as of the date hereof. IV. CONSENT TO ACQUISITION OF COLLATERAL. The Borrower hereby consents to the resale, sale, transfer, assignment or other disposition of any portion of the Collateral. V. DEFAULT AND REMEDIES. If the Borrower shall default in the performance of any of its obligations under this Agreement, the Secured Parties, at their option, may declare all Obligations immediately due and payable, whereupon the Secured Parties shall be entitled to exercise any remedy available to them under applicable law, including, but not limited to, the enforcement of the security interest granted hereunder. VI. MISCELLANEOUS. This Agreement shall be governed by and construed in accordance with the laws of the State of Delaware. This Agreement may be amended, modified or supplemented only by a written instrument signed by all parties hereto. This Agreement may be executed in one or more counterparts, each of which shall be deemed an original but all of which together shall constitute one and the same instrument. This Agreement contains the entire agreement between the parties hereto regarding the subject matter hereof and supersedes all prior agreements and understandings, oral or written, with respect thereto. IN WITNESS WHEREOF, the parties hereto have caused this Agreement to be executed as of the day and year first above written. [COMPANY NAME] By: ________________________________ Name: ______________________________ Title: _______________________________ [SECURITY AGENT NAME] By: ________________________________ Name: ______________________________ Title: _______________________________ ADDITIONAL PROVISIONS OF THE OIL AND GAS RENEWABLE ENERGY RESEARCH ACT (OGERA) OF 1978 (a) Research and Development. The Secretary may authorize contracts, grants, or cooperative agreements with any person for research and development relating to the commercialization of renewable energy sources, including research and development relating to new minerals and new mineral products which are renewable energy sources. Such contracts, grants, or cooperative agreements may be awarded to groups of persons, institutions, or corporations. (b) Circumstances under which contracts, grants, or cooperative agreements may be awarded. As a general rule, contracts, grants, or cooperative agreements may not be awarded to any person, group of persons, institution, or corporation whose principal business is engaged in the production of oil or gas unless such contracts, grants, or cooperative agreements are made pursuant to a competitive bidding procedure conducted in accordance with the procedures established by the Commission on Competition and Regulatory Policy and subject to further review and approval by the Commission. In the case of contracts, grants, or cooperative agreements awarded pursuant to a competitive bidding procedure, the Commission shall evaluate and take into account the cost-effectiveness of the contract when making its decision. The Commission shall also ensure that the contracts, grants, or cooperative agreements awarded will result in the maximum possible benefit to the economy of the United States. The Commission shall also ensure that the contracts, grants, or cooperative agreements awarded will result in the maximum possible benefit to the economy of the United States. (c) Contingent Contracts, Grants, or Cooperative Agreements. The Commission may, if it determines that it would be impracticable to award a contract, grant, or cooperative agreement without such conditions, conditions precedent, or contingent conditions, award contracts, grants, or cooperative agreements containing such conditions, conditions precedent, or contingent conditions. The Commission shall notify the Congress of the Commission's determination that it would be impracticable to award contracts, grants, or cooperative agreements without such conditions, conditions precedent, or contingent conditions, and shall include in such notification a description of the condition, conditions precedent, or contingent conditions imposed on such contracts, grants, or cooperative agreements. If the Commission determines that it would be impracticable to award contracts, grants, or cooperative agreements without such conditions, conditions precedent, or contingent conditions, the Commission shall notify the Congress of such determination and shall include in such notification a description of the condition, conditions precedent, or contingent conditions imposed on such contracts, grants, or cooperative agreements. Such notification shall be submitted to both houses of the Congress within thirty days after such determination has been made. (d) Contracts, Grants, or Cooperative Agreements Not Awarded. If the Commission determines that it would be impracticable to award contracts, grants, or cooperative agreements without such conditions, conditions precedent, or contingent conditions, the Commission shall notify the Congress of such determination and shall include in such notification a description of the condition, conditions precedent, or contingent conditions imposed on such contracts, grants, or cooperative agreements. Such notification shall be submitted to both houses of the Congress within thirty days after such determination has been made. (e) Public Notice. Before any contract, grant, or cooperative agreement is awarded, the Commission shall publish notice in the Federal Register of its intent to award such contract, grant, or cooperative agreement. Such notice shall contain a description of the purpose of the contract, grant, or cooperative agreement and a summary of the proposed terms and conditions of the contract, grant, or cooperative agreement. Such notice shall be published at least thirty days before the contract, grant, or cooperative agreement is awarded. (f) Public Participation. Before any contract, grant, or cooperative agreement is awarded, the Commission shall provide opportunities for public participation in the consideration of the proposed contract, grant, or cooperative agreement. Such opportunities shall include, but not be limited to, public hearings and meetings and written comments. Such opportunities shall be provided at least thirty days before the contract, grant, or cooperative agreement is awarded. (g) Selection Criteria. In evaluating proposals for contracts, grants, or cooperative agreements, the Commission shall consider the following criteria: (1) Technical merit; (2) Economic feasibility; [Redacted] Form 752-D Revised 01/2023. For Claimants Use Only #TF000043 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: JAMES VOYLES Business Name (if applicable): Classic Corner Iconic Cars Telephone Number: (405) 604-0870 Complete Physical Address: 3920 NW 39th ST. STE #A OKLAHOMA CITY, OK 73112 Complete Mailing Address: 2329 SW 47th ST OKLAHOMA CITY, OK 73119 Property Description: Year: 1984 Make: GMC Model: CK1500 Identification Number: 1GTDC14H5EJ516001 Location of Property: 3920 NW 39th ST. STE #A OKC, LLC Complete Physical Address 3920 NW 39th ST. STE #A OKC, LLC Complete Mailing Address Details of Service(s) Provided Repairs Requested By: (Legal Name): SCOTT BROWN Requestor's Complete Physical Address: 1019 HISTORIC ROUTE 66 ELK CITY, OK 73644 Requestor's Complete Mailing Address: 1019 HISTORIC ROUTE 66 ELK CITY, OK 73644 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. Labor 16,561.00 Parts 4,384.95 Tax 371.04 Title 42 Service 375.00 Date of Abandonment (if no other service rendered): 02/25/2026 (MM/DD/YY) Date of First Services Rendered: 02/25/2026 (MM/DD/YY) (Pursuant to 42 O.S. § 591, 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: $ 21,691.99 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: SCOTT BROWN Complete Mailing Address: 1019 HISTORIC ROUTE 66 ELK CITY, OK 73644 (2) Name: Complete Mailing Address: Signature of Lien Claimant: [Signature] Commissioner (if business): JAMES VOYLES State of Oklahoma, County of: OKLAHOMA Subscribed and sworn to before me this _______ 2 day of March, 2026. My commission expires: 04/23/27 [Signature] Notary Public 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 for Process 2 motor vehicle), or an inspection confirmation (Process 2 other than motor vehicle) of its condition. 2) Attach written proof of authority to perform the work, labor or service. EXHIBIT "E" PAGE 1 OF 4 PAGES PAGE 2 OF 4 PAGES Notice of Sale Service Oklahoma - Motor Vehicle Services Pursuant to the Provisions of Title 42 Chapter 2 of the Oklahoma Statutes Notice of sale is hereby given to all parties with an interest in the described property (Attach additional sheets, if necessary.): If you no longer have a legal or financial interest in the described property, please disregard this notice. (1) SB EXOTIC AUTO SALES LLC Name (2) CITIZENS STATE BANK Name (3) SCOTT BROWN Name (4) ____________________________ Name (5) ____________________________ Name (6) ____________________________ Name Property: 1984 GMC C1500 Year Make Model Identification Number: 1GTDC14H5EJ516001 License Plate or Registration Decal Number and State: OKLAHOMA This sale shall be conducted to satisfy the lien on said property claimed by (Lien Claimant or Legal Agent of Claimant): Lien Claimant: JAMES VOYLES DBA (If applicable): Classic Corner Iconic Cars If claimant is a business, list name of contact person representing the business: JAMES VOYLES Claimant’s Physical Address: 3920 NW 39th ST. STE #A OKC, OK 73112 Telephone Number: (405) 604-0870 Claimant’s Mailing Address: 2329 SW 47th ST. OKLAHOMA CITY, OK 73119 Detail of Service(s) Provided Repairs Authorized By (if applicable): SCOTT BROWN Description and Date(s) of Work, Labor and/or Service Performed including Material (Continue on reverse, if necessary.): List charges claimed for each item, the total of which must equal the total compensation claimed. Labor 16,561.00 Parts 4,384.95 Tax 371.04 Title 42 Service 375.00 Storage 885.00 Date of Abandonment (if no other service rendered): 02/25/2026 (MM/DD/YY) Storage or Possession from (MM/DD/YY): 02/25/2026 to (MM/DD/YY): 03/30/2026 at $29.50 per day. Total Amount of Repairs, Service and/or Storage: $22,576.99 A public sale of the above described property is to be held on (MM/DD/YY): 04/10/2026 at (Time): 3:00pm (AM/PM) Sale Location: 3920 NW 39th ST. STE #A OKLAHOMA CITY, OK 73112 (List exact location of sale site, including street address and city. If rural route, include directions to site.) I hereby confirm and attest to the accuracy of the above described services provided on and for the described property. Signature of Claimant: Jane Magaryns POA State of Oklahoma, County of OKLAHOMA Subscribed and sworn to before me this 30 day of March, 2026. My commission expires: 01/23/27 Notary Public Notice: The described property may be subject to delinquent taxes, fees and penalties of 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 an inspection confirmation (Process 2 other than motor vehicle) of its condition. 2) Attach written proof of authority to perform the work, labor or service. EXHIBIT E PAGE 3 OF 4 PAGES Thalit Supra
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