CJ-2026-1200 - Tri-State Trailer Rentals, LLC v. Fleenor Bros. Enterprises, Inc.

What's This Case About?

Let’s get one thing straight: this isn’t just a trailer rental dispute. This is a full-blown, slow-motion, paper-trail implosion of a business relationship that started with a handshake (or at least a signature) and ended with a $90,000 bill and a Missouri man possibly on the hook for someone else’s missing trailers. Because yes—Tri-State Trailer Rentals, an Oklahoma-based company that apparently really, really likes renting out trailers, is suing a Missouri corporation and one Kyle Cousins for $89,798.38. And no, that’s not a typo. They’re suing for eighty-nine thousand seven hundred ninety-eight dollars and thirty-eight cents. Someone kept receipts. Someone really wanted those trailers back. Or at least the money.

So who are we talking about here? On one side: Tri-State Trailer Rentals, LLC—TSTR, if you’re nasty or in a hurry. They’re an Oklahoma limited liability company, based in Tulsa County, and they do one thing: rent trailers. Not party trailers. Not food trailers. We’re talking heavy-duty, VIN-numbered, probably-dirty-from-construction-site-duty trailers. The kind that follow dump trucks and make noise when you drive past a job site. These are not cute little Airstreams. These are industrial beasts with names like “1UYVS2537R3196143” (yes, that’s a real VIN listed in the filing—bless the court clerk who had to type that in). TSTR is represented by a law firm with a name that sounds like a 19th-century detective agency: Barrow & Grimm, P.C. Their attorney? John C. Gotwals. Sounds like a guy who wears suspenders and says “per diem” unironically. (Spoiler: he does.)

On the other side: Fleenor Bros. Enterprises, Inc.—a Missouri corporation that, despite the name, appears to have done a lot of business in Tulsa County, Oklahoma. We don’t know what Fleenor Bros. actually does, but given that they rented 21 trailers over a four-year span, we’re guessing it involves moving heavy stuff. Maybe construction. Maybe demolition. Maybe they’re in the business of renting trailers to rent other trailers. Who knows. But what we do know is that Kyle Cousins—a guy from Carthage, Missouri (population: 15,000, and now possibly one fewer after this lawsuit)—signed on the dotted line to personally guarantee Fleenor’s payments. That’s the nuclear option in business deals. It means: “If my company flakes, I will pay. Even if I have to sell my car, my boat, or my emotional support lawn gnome.” And now? That promise might come due.

So what happened? Buckle up. Because this isn’t one missed payment. This is a symphony of missed payments. It starts in May 2020, when Fleenor Bros. fills out a Credit Application to rent trailers from TSTR. Standard stuff—name, address, promise to pay. But here’s the kicker: Kyle Cousins personally guarantees all of Fleenor’s obligations. That’s like cosigning a lease for your cousin’s apartment and then finding out he’s turned it into a raccoon sanctuary. You’re on the hook.

Then, over the next four years, Fleenor rents. And rents. And rents. We’re talking 13 separate rental agreements. Let’s do the math: - June 2020: 3 trailers - July 2020: 3 more - August 2020: 1 - August 2020 (again): 2 - January 2021: 4 - February 2021: 3 - February 2021 (again): 5 - February 2024: 5 - February 2024 (again): 2 - February 2024 (a third time that month): 3 - March 2024: 1 - August 2024: 5 - August 2024 (again): 2

That’s 39 trailers, rented in batches, over four years. At some point, Fleenor wasn’t just renting trailers—they were running a trailer timeshare. And TSTR, bless their ledger-loving hearts, kept signing the contracts. Maybe they thought, “Hey, steady customer!” Or maybe they just really, really believed in the honor system. Either way, by July 2025, the music stopped. Fleenor hadn’t paid a dime of the $89,798.38 they owed. Not a single invoice cleared. No “sorry, cash flow issues.” No “we lost the check in the mail.” Just… radio silence. And now TSTR is suing.

Why are they in court? Legally, TSTR is throwing the whole book at Fleenor and Cousins. First claim: Breach of Contract. Translation: “You signed 13 contracts. You agreed to pay. You didn’t. Pay up.” Second claim: Breach of Guaranty. This one’s for Kyle Cousins. “You promised to pay if Fleenor didn’t. Fleenor didn’t. So you pay.” Third claim: Unjust Enrichment. Fancy legal speak for: “You got something (trailers) for nothing. That’s not fair. Give us the money.” It’s the legal equivalent of your mom saying, “You can’t eat the cookies and say you didn’t eat the cookies.”

Now, what do they want? $89,798.38. Plus interest—$39.60 per day since July 28, 2025. That’s not chump change. For context, that’s enough to buy three brand-new 24-foot utility trailers. Or a very nice used pickup truck. Or, if you’re feeling fancy, a down payment on a house in Carthage, Missouri. Is it a lot for unpaid trailer rentals? Absolutely. But remember: this isn’t one trailer for one month. This is 39 trailers, rented over four years. Even at $500 a month per trailer (a conservative estimate), we’re talking north of $900,000 in potential rental value. So $89k might actually be less than what was owed. TSTR might be playing nice.

And now, our take. What’s the most absurd part of this? It’s not the VIN numbers. It’s not even the fact that someone thought it was a good idea to rent three batches of trailers in one month in February 2024. No, the absurdity lies in the escalation. This didn’t happen overnight. TSTR could’ve pulled the plug after the first missed payment. Or the fifth. Or the tenth. But they kept signing new contracts. They kept handing over trailers. It’s like lending your lawnmower to a neighbor, and when they don’t return it, you lend them your leaf blower, then your snowblower, then your pressure washer—just to see if this time they’ll pay attention. At some point, it stops being about business and starts being a psychological experiment: “How many trailers can I rent before they say no?”

And poor Kyle Cousins. Did he think he was just rubber-stamping a form? Did he imagine Fleenor Bros. would stay afloat? Or did he sign that guaranty thinking, “Eh, it’ll never come to that”? Now he might be on the hook for nearly $90,000—because his buddy’s company decided to treat trailer rentals like a Netflix subscription they never canceled.

We’re rooting for accountability. Not vengeance. TSTR deserves to be paid. But also? Someone needs to write a handbook: “How Not to Rent 39 Trailers and Disappear.” Until then, this case is a cautionary tale for anyone who thinks “I’ll pay later” is a viable business model. Spoiler: it’s not. And if you sign a guaranty? You will pay. Even if your name is Kyle Cousins and your town has a population smaller than a Walmart on Black Friday.

We’re entertainers, not lawyers. But even we know: you don’t mess with trailer people. They’ve got VINs, receipts, and patience. And when they come after you? They come with paperwork.

Case Overview

$89,898 Demand Petition

Jurisdiction

District Court of Tulsa County, Oklahoma

Filing Attorney

John C. Gotwals

BARROW & GRIMM, P.C.

Relief Sought

$89,898 Monetary

Plaintiffs

Tri-State Trailer Rentals, LLC business
Rep: BARROW & GRIMM, P.C.

Defendants

Fleenor Bros. Enterprises, Inc. business
Kyle Cousins individual

Claims

#	Cause of Action	Description
1	Breach of Contract
2	Breach of Guaranty
3	Unjust Enrichment

Petition Text

1,356 words

IN THE DISTRICT COURT IN AND FOR TULSA COUNTY STATE OF OKLAHOMA Tri-State Trailer Rentals, LLC Plaintiff, v. Fleenor Bros. Enterprises, Inc.; and Kyle Cousins, Defendants. Case No. CJ 2026-01200 Caroline E. Wall PETITION COMES NOW Plaintiff, Tri-State Trailer Rentals, LLC ("TSTR"), and for its causes of action against Defendants, Fleenor Bros. Enterprises, Inc. ("Fleenor") and Kyle Cousins ("Cousins") (Fleenor and Cousins, collectively, "Defendants") states as follows: Parties, Venue, and Jurisdiction 1. TSTR is an Oklahoma limited liability company doing business in Tulsa County, Oklahoma. 2. On information and belief, Fleenor is a Missouri for profit corporation doing business in Tulsa County, State of Oklahoma, and surrounding States. 3. On information and belief, Cousins is an individual residing in Carthage, Missouri, doing business in Tulsa County, Oklahoma. 4. The contract which forms the basis of this action was made and entered into in Tulsa County, Oklahoma. 5. Jurisdiction is properly vested in this Court pursuant to 12 O.S. § 2004(F). 6. Venue is proper in Tulsa County pursuant to 12 O.S. § 143. General Allegations 7. On May 27, 2020, Fleenor executed a Customer Account Credit Application for Trailer Rentals (the “Credit Application”), by which it agreed to make all rental payments due and owing for its rental of trailers. 8. Cousins, as part of the Credit Application, agreed to personally guarantee all payment obligations incurred by Fleenor thereunder. 9. On or about June 11, 2020, Fleenor executed that certain Trailer Rental Agreement (the “First Contract”), by which it agreed to lease Three (3) Trailers, VIN Numbers 1DW1A53286S913113, 1UYVS25385P566213, and 1DW1A53255S787612. 10. On or about July 21, 2020, Fleenor executed that certain Trailer Rental Agreement (the “Second Contract”), by which it agreed to lease Three (3) Trailers, VIN Numbers 1GRAA062X4K258732, 1GRAA06243G325505, and 1GRAA96261G318964. 11. On or about August 7, 2020, Fleenor executed that certain Trailer Rental Agreement (the “Third Contract”), by which it agreed to lease One (1) Trailer, VIN Number 1GRAA0628FW702119. 12. On or about August 19, 2020, Fleenor executed that certain Trailer Rental Agreement (the “Fourth Contract”), by which it agreed to lease Two (2) Trailers, VIN Numbers 1UYVS2530L6982405 and 1UYVS2534L6982410. 13. On or about January 14, 2021, Fleenor executed that certain Trailer Rental Agreement (the “Fifth Contract”), by which it agreed to lease Four (4) Trailers, VIN Numbers 1UYVS2539J6148923, 1UYVS2535J6220507, 1UYVS2537J6220508, and 1GRAA0625JW114008. 14. On or about February 19, 2021, Fleenor executed that certain Trailer Rental Agreement (the “Sixth Contract”), by which it agreed to lease Three (3) Trailers, VIN Numbers 1UYVS2535HM904513, 1UYVS2537J6220606, and 1UYVS2537HU904819. 15. On or about February 22, 2021, Fleenor executed that certain Trailer Rental Agreement (the “Seventh Contract”), by which it agreed to lease Five (5) Trailers, VIN Numbers 1UYVS2538DM757503, 1UYVS2539DM757509, 1UYVS535DM757538, 1UYVS2532EM814201, and 1UYVS2535EM814323. 16. On or about February 23, 2024, Fleenor executed that certain Trailer Rental Agreement (the “Eighth Contract”), by which it agreed to lease Five (5) Trailers, VIN Numbers 1UYVS2530J6148924, 1UYVS253XK6698455, 1UYVS2534J6148909, 1UYVS2535J6220507, and 1UYVS2533J6220604. 17. On or about February 23, 2024, Fleenor executed that certain Trailer Rental Agreement (the “Ninth Contract”), by which it agreed to lease Two (2) Trailers, VIN Numbers 1UYVS2537J6220606 and 1UYVS2539L6982404. 18. On or about February 23, 2024, Fleenor executed that certain Trailer Rental Agreement (the “Tenth Contract”), by which it agreed to lease Three (3) Trailers, VIN Numbers 1GRAA0629JW113976, 1GRAA0626JW113983, and 1GRAA0621JW114006. 19. On or about March 28, 2024, Fleenor executed that certain Trailer Rental Agreement (the “Eleventh Contract”), by which it agreed to lease One (1) Trailer, VIN Number 1UYVS2532J6260303. 20. On or about August 2, 2024, Fleenor executed that certain Trailer Rental Agreement (the “Twelfth Contract”), by which it agreed to lease Five (5) Trailers, VIN Numbers 1UYVS2530R3196131, 1UYVS2532R3196132, 1UYVS2534R3196133, 1UYVS2531R3196140, and 1UYVS2530R3186327. 21. On or about August 9, 2024, Fleenor executed that certain Trailer Rental Agreement (the "Thirteenth Contract") (the First Contract, Second Contract, Third Contract, Fourth Contract, Fifth Contract, Sixth Contract, Seventh Contract, Eighth Contract, Ninth Contract, Tenth Contract, Eleventh Contract, Twelfth Contract, and Thirteenth Contract, collectively, the “Contract”), by which it agreed to lease Two (2) Trailers, VIN Numbers 1UYVS2537R3196143 and 1UYVS2539R3196144. 22. Fleenor has failed or otherwise refused to make the payments due and payable under the Contract and the Credit Application. First Cause of Action Breach of Contract – Fleenor 23. TSTR re-alleges and incorporates paragraphs 1-22 above. 24. Fleenor breached the Contracts and the Credit Agreement by failing to pay TSTR all sums due thereunder. 25. As of July 28, 2025, there was due and payable under the Contract an outstanding balance of Eighty-Nine Thousand Seven Hundred Ninety-Eight Dollars and 38/100 ($89,798.38), comprised of Eighty Thousand Two Hundred Ninety-Four Dollars and 38/100 ($80,294.38) in principal and Nine Thousand Five Hundred Four Dollars and no/100 ($9,504.00) in interest, and which continues to accrue interest at the rate of Thirty-Nine Dollars and 60/100 ($39.60) per diem from and after July 28, 2025. 26. TSRT is entitled to judgment against Fleenor for breach of contract in the amount of Eighty-Nine Thousand Seven Hundred Ninety-Eight Dollars and 38/100 ($89,798.38), plus prejudgment interest accruing at the rate of Thirty Nine Dollars and 60/100 ($39.60) per diem from and after July 28, 2025, and its costs and attorneys’ fees. Second Cause of Action Breach of Guaranty – Cousins 27. TSTR re-alleges and incorporates paragraphs 1-26 above. 28. Cousins breached the Credit Agreement by failing to pay TSRT all sums due to TSTR by Fleenor thereunder. 29. As of July 28, 2025, there was due and payable under the Contract an outstanding balance of Eighty-Nine Thousand Seven Hundred Ninety-Eight Dollars and 38/100 ($89,798.38), comprised of Eighty Thousand Two Hundred Ninety-Four Dollars and 38/100 ($80,294.38) in principal and Nine Thousand Five Hundred Four Dollars and no/100 ($9,504.00) in interest, and which continues to accrue interest at the rate of Thirty-Nine Dollars and 60/100 ($39.60) per diem from and after July 28, 2025. 30. TSRT is entitled to judgment against Frederick for breach of his guaranty under the Credit Agreement in the amount of Eighty-Nine Thousand Seven Hundred Ninety-Eight Dollars and 38/100 ($89,798.38), plus prejudgment interest accruing at the rate of Thirty-Nine Dollars and 60/100 ($39.60) per diem from and after July 28, 2025, and its costs and attorneys’ fees. Third Cause of Action Unjust Enrichment – Fleenor 31. TSTR re-alleges and incorporates paragraphs 1-21 above. 32. TSTR furnished valuable services to Fleenor with the reasonable expectation of payment from Fleenor. 33. Fleenor benefitted from the services furnished to them by TSTR, and accepted the services knowing TSTR expected payment therefrom. 34. As a result, Fleenor has been unjustly enriched under inequitable circumstances, causing TSTR to suffer damages as a direct result of said unjust enrichment. Therefore, TSTR is entitled to judgment against Fleenor in the amount of Eighty-Nine Thousand Seven Hundred Ninety-Eight Dollars and 38/100 ($89,798.38), comprised of Eighty Thousand Two Hundred Ninety-Four Dollars and 38/100 ($80,294.38) in principal and Nine Thousand Five Hundred Four Dollars and no/100 ($9,504.00) in interest, and which continues to accrue interest at the rate of Thirty-Nine Dollars and 60/100 ($39.60) per diem from and after July 28, 2025. Prayer WHEREFORE, Plaintiff Tri-State Trailer Rentals, LLC prays that the Court enter judgment in its favor and against Defendant Fleenor Bros. Enterprises, Inc., on its causes of action of breach of contract, or, in the alternative, on its unjust enrichment action, in the amount of Eighty-Nine Thousand Seven Hundred Ninety-Eight Dollars and 38/100 ($89,798.38), plus prejudgment interest accruing at the rate of Thirty-Nine Dollars and 60/100 ($39.60) per diem from and after July 18, 2025, and its costs and attorneys’ fees, and against Defendant Kyle Cousins on its cause of action for breach of guaranty in the amount of Eighty-Nine Thousand Seven Hundred Ninety-Eight Dollars and 38/100 ($89,798.38), plus prejudgment interest accruing at the rate of Thirty-Nine Dollars and 60/100 ($39.60) per diem from and after July 18, 2025, and its costs and attorneys’ fees; and for any such additional relief as the Court deems just and equitable. Respectfully submitted, BARROW & GRIMM, P.C. By John C. Gotwals, OBA No. 33181 Rebecca Kamp, OBA No. 36168 110 W. Seventh Street, Suite 900 Tulsa, OK 74119-1044 (918) 584-1600 (918) 585-2444 (Fax) [email protected] [email protected] ATTORNEYS FOR PLAINTIFF VERIFICATION STATE OF OKLAHOMA ) COUNTY OF TULSA ) SS: Mary Beth Pasque, of lawful age, being first duly sworn, upon oath says: That she is an authorized representative of Tri-State Trailer Rentals, LLC, the Plaintiff above named; that she has read the foregoing Petition and knows the contents thereof and that the things stated therein are true to the best of her knowledge and belief. DATED this 13th day of March, 2026. [signature] Mary Beth Pasque, Authorized Representative for Plaintiff Subscribed and sworn to before me this 13th day of March, 2026. My Commission Expires: Comm. No. 17002216 Notary Public