Arvest Bank v. Bradley Parson, Personal Representative of the Estate of Jason M. Parson, deceased

IN THE DISTRICT COURT OF OKLAHOMA COUNTY, STATE OF OKLAHOMA ARVEST BANK, Plaintiff, vs. BRADLEY PARSON, Personal Representative of the Estate of JASON M. PARSON, deceased; and CARLOS PENA, Defendants. Case No. CJ-2026- CJ- 2026 - 1 2 5 9 PETITION FOR REPLEVIN COUNT ONE COMES NOW the Plaintiff, Arvest Bank, and for its first cause of action against the Defendant, Bradley Parson, Personal Representative of the Estate of Jason M. Parson, deceased, alleges and states as follows: 1. That the Plaintiff, Arvest Bank, is an Arkansas Corporation (hereinafter "Plaintiff"), organized and operating under the laws of the State of Arkansas with its principal place of business in Benton County, Arkansas. 2. That Jason M. Parson is one and the same person as Jason Michael Parson (hereinafter "Parson"). That Parson departed this life on or about the 31st day of May, 2024. That probate proceedings were commenced in Oklahoma County, Oklahoma, on the 26th day of June, 2024, in the case styled, In the Matter of the Estate of Jason M. Parson, deceased, Case No. PB-2024-869. That Bradley Parson was appointed the Personal Representative of the Estate of Jason M. Parson, deceased, on the 19th day of July, 2024, and has at all times since that date, and is currently, the duly appointed Personal Representative of the estate of Jason M. Parson, deceased. 3. After inquiry, there is no evidence that Parson was a member of the U.S. Military at the time of his death, or that he was otherwise entitled to any relief under the Servicemembers’ Civil Relief Act I (Title 50 Section 533, U.S. Code). 4. That this Court has jurisdiction of the parties and the subject matter herein. 5. That on or about the 5th day of June, 2021, Parson made, executed, and delivered to Ajax Motorsports of OKC, a Retail Installment Sales Contract (hereinafter the "Contract") in the principal amount of $20,270.96, bearing interest at the rate of 8.64% per annum. The Contract was assigned to Arvest Bank. A true and correct copy of this Contract is attached as Exhibit “A” and incorporated herein by reference. 6. That the Contract provided that said indebtedness was payable as follows: The sum of $361.78 per month for 72 months, with the first payment being due and payable on July 5, 2021, with a like amount payable monthly thereafter until all principal and interest are paid in full, with the final payment being due and payable on or before June 5, 2027, the maturity date 7. Plaintiff further alleges that said Contract provides that in the event any default is made in the payment of said Contract, or if said Contract is placed in the hands of an attorney for collection, the maker of said Contract will pay the attorney's fees, together with all costs of this action. 8. Plaintiff further alleges that the said Parson has failed, neglected and refused to pay said Contract according to the terms thereof, and that the said Parson is in default in that he has failed to pay all installments due as set forth in the Contract according to the terms and conditions of said Contract, and after allowing all just credits, there is now due and owing on said Contract to the Plaintiff herein, the principal amount of $9,096.59, plus accrued interest in the amount of $626.60, plus late fees in the amount of $157.50, all as of 29th day of January, 2026, with interest and late fees accruing thereon thereafter, plus attorney's fees, collection expenses, and all costs of this action accrued and accruing. 9. Parson is not entitled to any setoffs, counter claims, or defenses and if any be made they would be totally without merit. 10. This is an attempt to collect a debt and any information obtained will be used for that purpose. This communication is from a debt collector. Unless you notify this office within 35 days after receiving this notice that you dispute the validity of this debt or any portion thereof, this office will assume this debt is valid. If you notify this office in writing within 35 days from receiving this notice, this office will: Obtain verification of the debt or obtain a copy of a Judgment and mail you a copy of such Judgment or verification. If you request to this office in writing within 35 days after receiving this notice, this office will provide you with the name and address of the original creditor, if different from the current creditor. WHEREFORE, Plaintiff prays that it have and receive a judgment IN PERSONAM on its First Count against the Estate of Jason M. Parson, deceased, in the principal amount of $9,096.59, plus accrued interest in the amount of $626.60, plus late fees in the amount of $157.50, all as of 29th day of January, 2026, with interest and late fees accruing thereon thereafter, plus attorney's fees, collection expenses, and all costs of this action accrued and accruing. COUNT TWO COMES NOW the Plaintiff above named and for its second cause of action against the Defendants, Bradley Parson, Personal Representative of the Estate of Jason M. Parson, deceased and Carlos Pena, alleges and states: 11. Plaintiff adopts each, every, all and singular the allegations contained in its Count One above as if set forth herein in full. 12. That the Defendant, Carlos Pena (hereinafter "Defendant Pena"), is a resident of Edmond, Oklahoma County, Oklahoma. 13. That the Contract referred to hereinabove contained a Security Agreement clause, wherein to secure the payment of the indebtedness set forth herein, Parson acknowledged and delivered to the Plaintiff a first lien on the following collateral, to-wit: A) 2021 Kawasaki Teryx KRX 1000 VIN #JKARFCA16MB512493 14. That Plaintiff, as Assignee of Ajax Motorsports of OKC, duly filed its Lien Entry Form with Service Oklahoma, which lien is evidenced in the document attached hereto as Exhibit "B" and incorporated herein by reference. 15. That Parson at the time of the execution of said Contract was the owner of said collateral above described and that the Security Agreement contained within the Contract was given in connection with the borrowing of certain funds and was further given to insure the performance of the covenants and conditions of the Contract described in Plaintiff's First Count with interest thereon as aforesaid. 16. By reason of the above-mentioned Contract, Security Agreement, and Lien Entry Form, Plaintiff has an interest in the aforesaid collateral which entitles Plaintiff to immediate possession of said collateral and entry of an Order of Delivery granting the same. 17. Parson has failed to pay the indebtedness pursuant to the terms of the Contract and is now in default. The Plaintiff has given written notice to said Bradley Parson, Personal Representative of the Estate of Jason M. Parson, deceased (hereinafter "Defendant Personal Representative"), of said default and the right to cure, and said Defendant Personal Representative has failed and refused to cure the default. 18. Defendant Pena and/or Defendant Personal Representative's agents are currently in wrongful possession of the above-mentioned collateral, and the Plaintiff asks this Court to grant an Order of Delivery to allow the Plaintiff immediate possession of the property to sell in a commercial and reasonable manner pursuant to the laws of the State of Oklahoma. 19. Upon the event of the sale, Plaintiff will apply the sale proceeds to the indebtedness herein, and in the event that the sale proceeds do not satisfy the debt in question, Plaintiff shall be entitled to obtain a Deficiency Judgment against the Estate of Parson. 20. That the Plaintiff has an interest in the property described herein and is entitled to the immediate possession thereof. The estimated value of said collateral is $11,455.00. 21. That the property was not taken in execution on any order or judgment against said Plaintiff, or for the payment of any tax, fine, amercement assessed against said Plaintiff, or by virtue of any order of delivery issued in replevin or any other mesne or final process issued against said Plaintiff. 22. That the Plaintiff further alleges that the Defendant Pena and/or the Defendant Personal Representative, may attempt to transfer, conceal, damage or destroy the above described property or remove it from the jurisdiction of the Court or take other action that would prejudice the rights of the Plaintiff in and to said property and therefore the Plaintiff alleges that in accordance with 12 O.S. §1571(C) that Defendant Pena, Defendant Personal Representative, or any other party who wrongfully maintains possession of the vehicle, should be restrained and enjoined from taking such actions pending the hearing on the Plaintiff's Application for a Writ of Replevin or the issuance of an Order of Delivery if no hearing is held. 23. Pursuant to 12 O.S. §1574, an Order for Delivery should be entered against Defendant Pena, Defendant Personal Representative, or any other party who wrongfully maintains possession of the vehicle, requiring the Sheriff of Oklahoma County, or any other county or law enforcement agency within the state of Oklahoma where the vehicle may be located, to immediately take the vehicle and deliver possession to Arvest Bank or its designated agent, 24. That an Affidavit of Indebtedness is attached hereto as Exhibit "C" and incorporated herein by reference. WHEREFORE, Plaintiff prays that it have and receive judgment in its Second Count against the Defendants, Carlos Pena, and Bradley Parson, Personal Representative of the Estate of Jason M. Parson, deceased, and that this Court issue its Order for the immediate delivery of the aforementioned personal property to the Plaintiff prior to the judgment all as provided by law; that the lien of the Plaintiff be decreed to be a first and prior lien upon said personal property; that this Court enter a Temporary Restraining Order restraining and enjoining the Defendants, Carlos Pena, and Bradley Parson, Personal Representative of the Estate of Jason M. Parson, deceased, from transferring, concealing, damaging or removing the above described personal property from the jurisdiction of the Court, or taking any other action that would prejudice the rights of the Plaintiff in and to said property upon the issuance of an order of delivery; and that Plaintiff have and receive such other and further relief as may be equitable and just in the premises. ARVEST BANK, Plaintiff By: CARL J. BUCKHOLTS (OBA #30505) ELLIS & BUCKHOLTS 975 W. Willow - Patterson Bldg. Duncan, OK 73533 (580) 252-3240 - Telephone (580) 252-9596 - Facsimile ATTORNEYS FOR PLAINTIFF VERIFICATION STATE OF ARKANSAS ) COUNTY OF Benton ) ss. DEE HARDWICK, of lawful age, being first duly sworn upon oath, deposes and says: That she is a DAS - Legal Default Manager with ARVEST BANK, the above named Plaintiff, and has the authority to execute this verified Petition; that she has read the above and foregoing Petition; knows the contents thereof and that the matters set forth therein are true and correct to the best of her knowledge. DEE HARDWICK DAS - Legal Default Manager Subscribed and sworn to before me this 29 day of January, 2026. Nancy Bane Notary Public My Commission No. 12379692 My Commission Expires: 12/31/30 (SEAL) NANCY BANE Notary Public-Arkansas Benton County My Commission Expires 12-03-2030 Commission # 12379692 RETAIL INSTALLMENT SALES CONTRACT - SIMPLE INTEREST BUYER(S) NAME & ADDRESS (Last Name, First) Jason Michael Parson 804 Willow Ridge Pl Edmond, OK 73003 4054015981 4054015981 SELLER/SECURED PARTY Ajax Motorsports of OKC 8417 S. I-35 Service Road Oklahoma City, OK 73149 NUMBER 4348 DATE OF SALE 06/05/2021 DISCLOSURES 1. ANNUAL PERCENTAGE RATE The cost of the credit as a yearly rate. 8.64% 2. FINANCE CHARGE The dollar amount the credit will cost. $5,777.20 3. AMOUNT FINANCED The amount of credit provided to Buyer or on his behalf as itemized below. $20,270.96 4. TOTAL OF PAYMENTS The amount Buyer will have paid after Buyer has made all payments as scheduled. $26,048.16 5. TOTAL SALES PRICE The total cost of the purchase or credit, including Buyer's down payment $5,000.00 PAYMENT SCHEDULE WILL BE: <table> <tr> <th>NO. OF REGULAR PAYMENTS</th> <th>AMOUNT OF PAYMENTS</th> <th></th> </tr> <tr> <td>72</td> <td>Regular $361.78</td> <td>Plus a Final Payment</td> </tr> </table> DUE DATE OF PAYMENTS <table> <tr> <th>PAYMENT FREQUENCY</th> <th>DUE DATE OF PAYMENTS</th> </tr> <tr> <td>Monthly</td> <td colspan="2">07/05/2021</td> </tr> </table> Prepayment: If Buyer pays off early, Buyer will not have to pay a penalty. Late Charge: If a payment is late, Buyer will be charged a fee of $22.50 or 5% of the unpaid amount of the payment, whichever is greater. See Retail Installment Sales Contract, Security Agreement and related contract documents for additional information about non-payment, default, and required repayment in full before the scheduled date, and prepayment refunds and penalties. SECURITY/COLLATERAL Boxes checked apply to this transaction: [ ] The signers of the Security Agreement are giving a security interest in the following property: 2021 Kawasaki Teryx KRX 1000 JKAIRFC1A16WB512493 Collateral securing other sales by Seller to Buyer also secures this Contract. Assumption Policy: Someone buying Buyer's house: may, subject to certain conditions, be allowed to assume the remainder of the mortgage on the original terms, cannot assume the remainder of the mortgage. Fees paid in Cash by Buyer: Filing Fees $0.00, Non-Filing Insurance $0.00 ITEMIZATION OF AMOUNT FINANCED <table> <tr> <th>$25,135.96</th> <td>CASH PRICE (Including Accessories, Sales Tax, Service and Service Protection provided by Seller)</td> </tr> <tr> <th>$5,000.00</th> <td>Cash Down Payment</td> </tr> <tr> <th>$0.00</th> <td>Manufacturer's Rebates</td> </tr> <tr> <th>$0.00</th> <td>Trade In (describe)</td> </tr> <tr> <th>$0.00</th> <td>Payoff Balance on Trade-in (if any), Paid to</td> </tr> <tr> <th>$0.00</th> <td>Net Allowance on Trade In (Subtract line 5 from line 4)</td> </tr> <tr> <th>$5,000.00</th> <td>Total Cash Down and Not Trade (Add lines 2, 3 and 6. If amount is negative enter same positive amount on line 17)</td> </tr> <tr> <th>$5,000.00</th> <td>Total Down Payment (Enter amount from line 7 if positive amount), or enter '0' if line 7 is negative</td> </tr> <tr> <th>$20,135.96</th> <td>Unpaid Balance of Cash Price (Subtract line 8 from line 1)</td> </tr> </table> *-Amounts Paid to Others on Buyer's Behalf (Seller may retain a portion of amounts designated with an asterisk **) <table> <tr> <th>$0.00</th> <td>10 Credit Life Insurance Premium to</td> </tr> <tr> <th>$0.00</th> <td>11 Disability Insurance Premium to</td> </tr> <tr> <th>$0.00</th> <td>12 Other Insurance Premium to</td> </tr> <tr> <th>$0.00</th> <td>13 Filing and Releasing Fees to Public Officials</td> </tr> <tr> <th>$0.00</th> <td>14 License, Title and Registration to</td> </tr> <tr> <th>$0.00</th> <td>15 Service Contract to</td> </tr> <tr> <th>$135.00</th> <td>16 Processing Fee</td> </tr> <tr> <th>$0.00</th> <td>317 To</td> </tr> <tr> <th>$0.00</th> <td>18 To</td> </tr> <tr> <th>$135.00</th> <td>Total Amount Paid to Others on Behalf of Buyer (Add lines 10 through 18)</td> </tr> <tr> <th>$0.00</th> <td>20 Less Prepaid Finance Charge</td> </tr> <tr> <th>$20,270.96</th> <td>AMOUNT FINANCED (Add lines 9 and 19, less Prepaid Finance Charge entered on line 20)</td> </tr> </table> If this Contract arises from a consumer credit sale of a used vehicle (as defined in Part 435 of Title 16 of the Code of Federal Regulations) then 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. DISCLAIMER OF WARRANTIES Seller's oral statements about the property described herein do not constitute warranties and shall not be relied upon by Buyer. To the extent permitted by law, Seller disclaims all express and implied warranties, including without limitation, the Warranties of MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE or ANY OTHER REPRESENTATION (STANDARD OR LIMITED, EXPRESSED OR IMPLIED). Buyer acknowledges that the warranties contained herein are limited to the express representations made herein and are applicable only to the property sold hereunder. Buyer assumes all risk of loss or damage, whether in transit or at delivery, and Buyer accepts the property as received. CREDITOR/ASSIGNEE Arvest Bank PO Box 940 Rogers, AR 72757 (MN) (405) 698-7620 SECURITY AGREEMENT The Undersigned grants to Seller a security interest in Collateral described herein as secured by this Retail Installment Sales Contract executed herewith, and except for such collateral, which is the described Collateral, as defined in 16 CFR Sec. 429 (a), to secure (1) all future advances by Seller to Buyer, (2) all other liabilities to Seller including principal, interest, fees, charges, or obligations, presently due, joint-or several due or to become due or which may be declared due prior to their respective maturities, arising out of the performance of all agreements, covenants, and warranties of Buyer to Seller, (3) Collateral consists of (1) all property now owned or hereafter acquired by Buyer beneficially owned in, or attached to, such described property; including additions, accessories, improvements, improvements, replacements, proceeds payable therefrom, and the proceeds of insurance and/or proceeds payable by reason of damage to or loss of Collateral, and (4) proceeds from credit life and disability insurance policies issued to Buyer and proceeds paid to Buyer from such insurance coverage and from any extended service contract purchased by this undersigned pursuant to this contract. [Signature] INSURANCE STATEMENT CREDIT, LIFE, ACCIDENT, AND HEALTH INSURANCE are not required for this contract. Seller states that neither such insurance nor "auto" insurance is a factor in approval by Seller of the loan, and if Buyer is a Co-Buyer, Buyer must provide Seller with an application for such insurance by indicating the type of insurance desired and signing below. Life Insurance: [ ] Buyer [ ] Co-Buyer Cost: $0.00 Accident and Health Insurance: [ ] Buyer [ ] Co-Buyer Cost: $0.00 Buyer desires insurance checked above Co-Buyer desires insurance checked above Date: 06/05/2021 VENDOR'S SINGLE INTEREST AND/OR OTHER PROPERTY INSURANCE may be obtained by Buyer and/or Co-Buyer as desired. If Buyer or Co-Buyer desires such insurance is obtained through Seller, the cost for the term of the debt is: Property Insurance: $0.00 Vendor's Single Interest Insurance: $0.00 "The issuer issuing this policy waives its rights to subrogation against Buyer." RETAIL INSTALLMENT SALES The undersigned Buyer(s) are all other parties liable hereunder, hereby covenants and agrees to collaterally assign to Seller any purchase from Seller the property described herein and agree to pay Seller (a) the Amount Financed as shown herein, (b) interest at specified Annual Percentage Rate per year, (c) any other accrued and unpaid part of the finance charges: All payments received by Seller are to be applied first toward payment of any delinquent Finance Charge, and then toward payment of the unpaid amount of Amount Financed. ALL PARTIES DEEMED PRINCIPALS: All parties liable for payment under this contract, together with any co-signers, each party agrees that any party with approval of holder and without notice to any other party may from time to time renew this Contract or consent to or extend the time for payment of any sums due for any term or terms, and all parties shall be liable in same manner as on original contract. All parties liable for payment shall indemnify and hold Seller harmless against any action of collapse of collateral and addition or release of any party or guarantor. PREPAYMENT BUYER shall have the right to prepay the Amount Financed in whole or in part at any time without penalty; provided, however, that prior to or contemporaneously with any such prepayment Buyer shall have paid to Seller the finance charge from the day of sale until the date of prepayment in full. If Buyer shall be granted a rebate of any unearned portion of the Finance Charge. Partial prepayments shall be applied first to any interest due and remaining unpaid, and next in option of Seller, to principal payments in reverse order of maturity. DELINQUENCY CHARGE: Any payment required by this Contract not paid on or before the date stated hereon, the holder may assess a delinquency charge as in amount which is the greater of (i) 5% of the unpaid amount of the payment or (ii) up to the maximum amount allowable under the laws of the State of Oklahoma Department of Consumer Credit at the time the payment becomes delinquent. Buyer agrees the amount set by rule of the Oklahoma Department of Consumer Credit. COLLECTION COSTS: The Seller may charge and collect from the Buyer any fees, charges, or costs incurred by Seller in connection with collection, including the filing of an enforceable order of withdrawal or share draft issued to Seller in connection with this sale. This fee may be collected in addition to all other fees and charges. Buyer agrees to pay to Seller all fees, charges, and other amounts owed under this contract. Seller may charge and collect from the Buyer and shall not be subject to refund or rebate: Buyer agrees to pay the cost of enforcing the security agreement, including reasonable attorney fees if the unpaid debt after default, if allowed by law at the time this Contract is signed. BUYER(S) SIGNATURES 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. [Signature] [Signature] EXHIBIT A ADDITIONAL PROVISIONS: BUYER EXPRESSLY WARRANTS; COVENANTS AND AGREES: WARRANTIES AND COVENANTS 1. Financial Information. All applications, balance sheets, earnings statements, other financial information and other reports heretofore or which hereafter become available to Seller/Secured Party to induce it to enter into or continue a financing transaction with Buyer, fail to represent the true condition of Buyer as of the date set forth for such documents therein, and all other information furnished by Buyer or furnished to Seller/Secured Party at any time are or shall be, at the time furnished, accurate and correct in all material respects and complete knowledge of conditions necessary to give Seller/Secured Party true and accurate knowledge of the subject matter, unless otherwise specified herein. Buyer warrants that the information furnished Buyer since the effective date of the last furnished financial information which has not been replaced by Seller/Secured Party in writing. 2. Ownership Prohibition. Buyer will not permit any other security interest other than the Seller/Secured Party's security interest to attach to any of the Collateral, nor will it permit the Collateral to be levied upon, garnished or attached under any legal process, or permit any act to be done that may impair the value of the Collateral or the security interest afforded hereby. 2B. Financing Statement. Buyer agrees to join with Seller/Secured Party in executing one or more Financing Statements from time to time, in order-to-perfect, or to continue perfection of, its interest hereunder. Said opinions, opinions and/or confirmation or reproduction of this Agreement or of any Financing Statement is sufficient as a Financing Statement. 4. Residence, Use and Location. Statements made herein or otherwise as to Buyer's address, location, mode of possession and use of the Collateral are Buyer will not permit any of his Collateral to be removed from the specific premises hereinafter described without the written consent of Seller/Secured Party. Buyer's exact legal name is as set forth on the reverse side of this Agreement or Buyer's Individuals Buyer's principal residence is & Buyer's address is set forth herein. Under the Oklahoma Uniform Commercial Code, if Buyer's principal residence is not change principal residence or legal name without providing Seller/Secured Party 30 days prior written notice. 5. Sale, Transfer or Disposition of Collateral Prohibited. Buyer shall not sell, transfer, exchange, lease or otherwise dispose of the Collateral or any part thereof or Buyer's rights herein without first obtaining the prior written consent of Seller/Secured Party. The consent of Seller/Secured Party must be obtained before any such sale, transfer, exchange, lease or other disposition of the Collateral, except to satisfy Buyer's obligations hereunder (subject to the application of proceeds to obligations secured hereby) which requirement the Seller/Secured Party deems to be for the protection of its security interest, and it is understood and agreed that such action taken without the prior written consent of Seller/Secured Party would be a violation of the terms hereof and Buyer hereby authorizes Seller/Secured Party to take any and all actions necessary and/or advisable in Seller/Secured Party's sole discretion to protect and preserve the security interest of Seller/Secured Party herein. Buyer's exact legal name is as set forth on the reverse side of this Agreement or Buyer's address is set forth herein. 6. Maintenance and Inspection. Buyer owns own expense shall keep the Collateral in good condition and repair, shall not permit it to be misused or abused or wasted or allowed to deteriorate except for the ordinary wear and tear of its intended primary use, shall promptly notify Seller/Secured Party if the Collateral is sold, exchanged, destroyed, lost, missing, stolen, illegally used or its use in a manner not permitted by the written instructions provided by Seller/Secured Party, permit and facilitate Seller/Secured Party to examine and inspect the collateral at any time and whenever required. 7. Taxes. Buyer shall promptly pay any and all taxes, assessments and license fees with respect to the Collateral or the use of the collateral. EVENTS OF DEFAULT Buyer shall be in default under this Agreement upon the happening of any one or more of the following events or conditions, herein called "Events of Default": 1. Any warranty, covenant, representation, agreement, representation, financial information or statement made or furnished Seller/Secured Party by or on behalf of Buyer to induce Seller/Secured Party into this Agreement, or in connection herewith, is violated or proves to have been false in any material respect when made or furnished. 2. Any payment required hereunder or under any other note or obligation of Buyer to Seller/Secured Party or others is not made when due or in accordance with terms of applicable contract. 3. Buyer defaults in the performance of any covenants, obligation, warranty, or provision contained in any Loan Agreement or in any other note or obligation of Buyer to Seller/Secured Party or to others. 4. The occurrence of any event or condition which results in acceleration of the maturity of any Obligation of Buyer to Seller/Secured Party or to others under any note, indenture, charter, agreement, or undertaking. REMEDIES Upon the Occurrence of an Event of Default, and at any time thereafter, Seller/Secured Party may, at its option and without notice or demand to Buyer except as otherwise provided by law, exercise any and all rights and remedies provided by the UCC, as well as all other rights and remedies available to Seller/Secured Party by law or equity, including but not limited to: 1. Declare the unpaid balance of the Obligations and all other obliques and indebtedness of any other party hereto to holder, whether direct or indirect, absolute or contingent, now existing or hereafter arising, immediately due and payable (and/or proceed to enforce payment and performance), and require Buyer to pay all amounts due and payable on or after demand, including the unpaid balance of such liabilities. Buyer will be entitled to a rebate of any untaxed portion of any interest or other charge in accordance with applicable laws. Any amount not paid when due shall continue to accrue under the terms and at the percentage Rate provided in the Contract. 2. Require Buyer to assemble Collateral or evidence thereof and make it available to Seller/Secured Party at a place designated by Seller/Secured Party which is reasonably convenient to both parties. 3. Repossess the Collateral and all books and records evidencing or pertaining to the Collateral. Buyer authorizes Seller/Secured Party to take possession of and hold any property located at or containing Collateral. Collateral may be reclaimed such property within 10 days after notice of its taking and location is sent to Buyer such notice may be oral and the proceeds applied to expenses and other amounts due from Buyer to Seller/Secured Party. Any balance of said proceeds remaining after payment in full of all amounts secured by this Agreement may be paid Buyer. 4. Transfer, any of the Collateral or evidence thereof into its own name or that of Seller/Secured Party or against any such liability. Seller/Secured Party may also demand, negotiate, assign, sell, assign, alienate, pledge or hypothecate the Collateral, or any part thereon, in its own name or in the name of the Buyer as Seller/Secured Party may determine. 5. Sell or otherwise dispose of the Collateral. Unless, Collateral in whole or part is perishable or threatens to decline speedily in value or is of a type customarily sold, on a recognized market, Seller/Secured Party will give Buyer reasonable notice of the time and place of any public sale, or the time after which any private sale or other disposition is to be made. Any remittance of notice shall be met if notice is mailed postage prepaid, certified or registered mail, postage due herein at least ten days before sale of other disposition or action. Seller/Secured Party shall be entitled to, and Buyer shall be liable for all reasonable costs and expenditures of realizing on its security interest in the Collateral, including, but not limited to, fees for registration bonds, storage, repossession costs, repair and preparation costs for sale, selling costs, and advertising costs as set forth in the RETAIL INSTALLMENT SALES CONTRACT. All such costs are secured by the security interest in the Collateral covered herein. Buyer waives any right it may have to demand the return of any proceeds from the sale of the Collateral. In the event Seller/Secured Party may comply with any applicable state or federal law requirements concerning a disposition of the Collateral and compliance will not be considered adversely if the Collateral is repossessed, sold, delivered or otherwise disposed by Seller/Secured Party with the Collateral without giving any warranties, as to the Collateral and may specifically disclaim any warranty of title or the like. This procedure will not be considered adversely affect the security interest in the Collateral. If any of the Buyer fails to pay Seller/Secured Party, sale of the Collateral upon credit, Buyer will be credited only with payments actually made by the buyer received by Seller/Secured Party and applied to the indebtedness of the purchaser. In the event the proceeds are paid to Buyer, the Collateral will be returned to Buyer. Seller/Secured Party may resell the Collateral and Buyer will be credited with the proceeds of the sale. 6. Seller/Secured Party shall not be liable for the failure to collect any account, enforce any contract-right, or for any error or omission on the part of Seller/Secured Party, its officers, agents or employees, except as the same may be caused by the gross negligence or bad faith of Seller/Secured Party, or as otherwise provided in this Agreement, such as to commercially reasonable manner. Seller/Secured Party shall have acted in a commercially reasonable manner if its action or non-action is consistent with general banking usage in the area of Seller/Secured Party's business, the practice of commercial banks under similar circumstances, procedures which may be otherwise reasonable under the circumstances or as otherwise directed by Seller/Secured Party to take necessary steps to preserve rights against prior parties in an instrument or chattel paper. GENERAL 1. Waivers. No act, delay, or omission, including Seller/Secured Party's waiver of remedy because of any default hereunder shall constitute a waiver of any of Seller/Secured Party's rights and remedies under this Agreement or any other agreement between the parties. All rights and remedies granted hereunder are cumulative and not exclusive, and may be exercised concurrently, and the exercise of any one or more remedy will not be a waiver of any other. No "waiver" changes, modification, or discharge of any of Seller/Secured Party's rights or of Buyer's duties hereunder. Such allowance or indulgence will be in writing and signed by a duly authorized officer of Seller/Secured Party; and, any such waiver will not be a bar to the exercise of any right or remedy on any subsequent default. 2. Agreement Binding on Assignees. This Agreement shall inure to the benefit of the successors and assigns of Seller/Secured Party and shall be binding upon the heirs, executors, administrators, and successors and assigns of Buyer. 3. Rights of Seller/Secured Party Assignable. Seller/Secured Party at any time and at its option may pledge, transfer or assign rights under this Agreement in whole, or in part, any transfers or assignee shall have all the rights of Seller/Secured Party as to the rights or parts thereof so pledged, transferred, or assigned. Buyer's rights hereunder may not be assigned. 4. Joint and Several Responsibility of Buyer. If more than one Buyer executes this Agreement, their responsibility hereunder shall be joint and several and the reference to Buyer hereunder shall mean each or any of them. Such assignments shall be effectuated by a recourse assignment, and any assignment made in the course of collection of any such proceeds if not a transfer in bankruptcy, is not required by law. 5. Separability of Provisions. If any provisions of this Agreement shall for any reason be held to be invalid or unenforceable, such invalidity or unenforceability shall not affect any other provisions hereof which shall remain in full force and effect. If such invalid or unenforceable provisions had never been contained herein. 6. Governing Law. This Agreement shall be construed and enforced in accordance with the laws of the State of Oklahoma and to the extent such laws provide otherwise, in the event the law where the debtor or the collateral is located is (other than Oklahoma), as the case may be, contrary to the Agreement, any term used in the Uniform Commercial Code, as adopted and/or revised from time to time in the State of Oklahoma ("UCC"), and not defined in this Agreement has the meaning given to the term in the UCC. ASSIGNMENT BY SELLER AND TERMS FOR VALUE RECEIVED, Seller hereby sells, assigns, and transfers all of its right, title, and interest in and to the Whole Contract and the property described therein, to the Assignee shown on the reverse side hereof (herein called "Assignee"). Its successors or assigns with power to take legal proceedings in the name of the Seller or Assignees. Seller warrants that said assignment of creditor rights is in compliance with all laws governing such assignments; that Seller has taken all steps necessary to perfect the lien granted by this agreement as a First lien and to show Assignee as holder and encumbrances whatsoever, except the within Contract; that the Buyers had legal capacity to enter into this Contract at the time of its execution; and that there is now owing on the within Contract. Seller agrees to repurchase this Contract upon the Assignee's demand in the event the Buyers assert any claim or defense against Assignee or Seller relating to the performance or non-performance of Seller's obligations under this Contract or Seller's violation of any provision of applicable Federal or State law relating to consumer credit, or in the event Assignee becomes aware of any such occurrence. Seller agrees to indemnify and hold harmless Assignee from any and all losses, costs, expenses, damages, claims, causes of action, demands, notes, payments, and non-performance of this Contract. In addition, this Agreement is subject to the provisions set out below in the paragraph(s) initiated by Assignor, if any. [Check if applicable] This Assignment is made under the terms of a separate agreement. INITIALS: REPURCHASE: Seller guarantees the payment and performance of this Contract, except as otherwise provided in the Repurchase Agreement between the Seller and Assignee. INITIALS GUARANTY: Seller guarantees the payment and performance of this Contract. INITIALS WITHOUT RECOULSE: This Assignment is without recourse against the Assignor. INITIALS FULL RECOULSE: Seller guarantees payment of all amounts due on this contract as and when such payments, become due. Seller waives any extension of time made by Buyer. BY [NAME AND TITLE] [DATE] 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 THEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREBY. OKLAHOMA TAX COMMISSION LIEN HOLDERS RELEASE FORMS VIN: JKARFCA16MB512493 AGNT #: M5573 LIEN DEBTOR: PARSON, JASON MICHAEL PARSON, JASON MICHAEL 804 WILLOW RIDGE PL. EDMOND OK 73003-5172 VEHYR: 2021 MAKE: KAWA MODEL: LIEN DATE: 06/05/2021 BODY: LIEN HOLDER: ARVEST BANK ARVEST BANK PO BOX 940 ROGERS AR 72757-0940 TO: OKLAHOMA TAX COMMISSION MOTOR VEHICLE DIVISION P.O. BOX 269061 OKLAHOMA CITY OK 73126 REF#: L1814133768 TO WHOM IT MAY CONCERN: WE HAVE RELEASED OUR SECURITY INTEREST IN THE MOTOR VEHICLE DESCRIBED ABOVE, EFFECTIVE ON THE DATE WHICH APPEARS BY MY SIGNATURE. PLEASE REVISE YOUR RECORDS TO REFLECT THIS RELEASE. SIGNATURE OF REPRESENTATIVE OF SECURED PARTY X______________________________ DATE_____________________ LENDER: TO ENSURE PROPER PROCESSING OF YOUR COMPLETED LIEN RELEASE, PLEASE NOTE THE FOLLOWING. DO NOT ALTER THIS DOCUMENT NO STAPLES NO TAPE NO FOREIGN FIXTURES OR ATTACHMENTS NO WRITING OR MARKING (OTHER THAN SIGNATURE AND DATE FOR RELEASE) DO NOT ALTER THE SIZE OF THIS DOCUMENT IN THE DISTRICT COURT OF OKLAHOMA COUNTY, STATE OF OKLAHOMA ARVEST BANK, Plaintiff, vs. BRADLEY PARSON, Personal Representative of the Estate of JASON M. PARSON, deceased; and CARLOS PENA, Defendants. Case No. CJ-2026- AFFIDAVIT OF INDEBTEDNESS STATE OF ARKANSAS ) COUNTY OF Benton ) SS: I, Dee Hardwick, DAS - Legal Default Manager of Arvest Bank, being duly sworn, do hereby state under oath that the matters set forth herein are true and correct to the best of my knowledge, information, and belief. 1. I am over the age of 18 and am competent to testify in all respects. 2. Arvest Bank is a corporation authorized to conduct business in the state of Oklahoma. 3. I am familiar with the accounts of Defendant, Jason M. Parson a/k/a Jason Michael Parson (hereinafter “Defendant Parson”), and have personal knowledge of the events and allegations recited below. 4. Arvest Bank is the holder of the debt instruments referenced below. 5. On or about June 5, 2021, Defendant Parson made executed and delivered to Ajax Motorsports of OKC, a Retail Installment Sales Contract (hereinafter the “Contract”) in the principal amount of $20,270.96, bearing interest at the rate of 8.64% per annum. The Contract was assigned to Arvest Bank. 6. That Arvest Bank perfected its security interest in the vehicle by way of filing its Lien Entry Form with Service Oklahoma, on the vehicle described as follows: A) 2021 Kawasaki Teryx KRX 1000 VIN #JKARFCA16MB512493 7. Despite demand, the Contract was not paid when due and is in default. 8. Arvest Bank is the holder of the Contract, has exercised its right under the loan document, and has accelerated the balance of the Contract. Arvest Bank’s right to take possession of the vehicle is absolute. 9. Defendant Parson has failed to pay the balance due on the Contract and there is due and owing to Arvest Bank the principal amount of $9,096.59, plus accrued interest in the amount of $626.60, plus late fees in the amount of $157.50, all as of 29th day of January, 2026, with interest and late fees accruing thereon thereafter, plus attorney's fees, collection expenses, and all costs of this action accrued and accruing, all of which Arvest Bank should have judgment. 10. Pursuant to JD Power the average base trade-in value of the vehicle is $11,455.00. 11. Upon information and belief of the Plaintiff, the vehicle has not been taken for a tax or fine or under any order of Judgment of a court or seized under an execution or attachment. 12. Arvest Bank’s cause of action has accrued within the past two (2) years. FURTHER AFFIANT SAYETH NOT. [signature] DEE HARDWICK DAS - Legal Default Manager, Arvest Bank Affiant Subscribed and sworn to before me this 29 day of January, 2026, by Dee Hardwick, DAS - Legal Default Manager of Arvest Bank. (SEAL) My Commission Expires: 12/3/30 My Commission No.: 12379492 NANCY BANE Notary Public-Arkansas Benton County My Commission Expires 12-03-2030 Commission #12379692