Braden Huff v. Ashley Dixon

IN THE DISTRICT COURT IN AND FOR WAGONER COUNTY STATE OF OKLAHOMA Braden and Carissa Huff, Plaintiffs, v. Ashley Dixon and Rustin Dixon, Individuals, Two Unknown Buyers, Future Parties in interest, Defendants. Case No.: CJ-26-67 ATTORNEY LIEN CLAIMED PETITION COMES NOW, Braden and Carissa Huff ("Plaintiffs"), by and through their attorney of record, Alex Sprenger of Boston Avenue Law PLLC, and alleges and states as follows in support of its claim against Defendants Ashley Dixon ("Ashley") and Rustin Dixon ("Rustin", collectively "Dixons" or "Landlords") and Two Unknown Buyers, Future Parties in Interest. JURISDICTION AND VENUE 1. This Court is one of competent jurisdiction and venue to adjudicate this civil action. 2. The property at issue lies within the geographical boundaries of Wagoner County. 3. All of the events and unlawful actions alleged occurred within the geographical boundaries of Wagoner County. FACTS 4. On or about September 13, 2025, Plaintiffs executed a valid lease for the home located at 1500 S 28th St, Broken Arrow Oklahoma ("The Home"). 5. A true and correct copy of such lease is attached as Exhibit A. 6. This lease grants physical possession of the home to Plaintiffs until October 1, 2026. 7. At the time of executing the lease, Plaintiffs were in negotiations with Defendant to purchase the home. 8. However, negotiations were unsuccessful and Defendants listed the home for sale on or about January 22, 2026. 9. Since executing the lease, Plaintiffs have not missed a single rent payment. 10. Since executing the lease, Plaintiffs have kept the home in good condition. 11. Since executing the lease, Plaintiffs have trained their dogs to stay off of the carpet generally. 12. Since executing the lease, Plaintiffs received permission to make material alterations to the home. 13. On or about January 28, 2026, Defendants told Plaintiffs that they would need to leave the property during “showings” of the house. 14. However, the lease agreement states that Defendant may show the home for sale “within forty-five (45) days before the expiration of the lease. 15. Thus, Defendant listed and displayed the house for sale over 200 days before they were contractually permitted to do so. 16. On or about February 3, 2026, Defendants contacted Plaintiffs and informed them that the house had been sold. 17. Defendant then told Plaintiffs that Defendant was ending the lease and Plaintiffs must vacate within 30 days. Exhibit B. 18. Defendant did so by serving Plaintiffs with a legal notice of lease termination. 19. Plaintiffs objected to the unilateral and unlawful termination of their lease and stated that they did not agree to Defendant’s new terms. 20. In retaliation for not agreeing to their unlawful demand, Defendant began to plot ways to harass, endanger, humiliate, and evict Plaintiffs from their home. 21. On or about February 5, 2026, Defendants told Plaintiffs that an appraiser would need access to their home the following day. 22. Defendants did not say that anyone other than the appraiser would be coming to the home or that the home would be inspected. 23. The following day, the inspector arrived and viewed the home under the supervision of Plaintiffs. 24. However, Defendant Ashely Dixon used the distraction to unlawfully enter into the home. 25. Defendant Ashley Dixon did not knock or announce her arrival. 26. Instead, Dixon entered the home stealthily and began searching the home and taking photos of whatever she wanted. 27. This search included private places including the drawers and cabinets of the master bedroom, master bathroom, and master closet. 28. When caught, Defendant ignored Plaintiff’s questions of what she was doing or why she was there. 29. Plaintiff believes further discovery will show that Defendant unlawfully took photos and videos of private places in the home for the purposes of harassing Plaintiffs. 30. Plaintiff believes further discovery will show that Defendant altered the premises by causing damage to the home or otherwise taking personal property belonging to Plaintiffs. 31. On or about February 5, 2026, Plaintiff told Defendant that they did not approve of the illegal lease termination and stated that they would not be vacating the home until the end of lease in October. 32. On or about February 6, 2026, Defendants sent Plaintiffs a 10-day notice to cure. Exhibit C 33. This notice to cure contained a number of false allegations and required ridiculous and expensive mitigation processes for those false allegations. 34. These include: a. False allegations of pet waste in the home. b. Guttering issues which Defendants had a duty to fix, but failed to do so, c. Cigarette odor from the previous tenant which Defendants had duty to remediate but failed to do so, d. Removal of a lawfully permitted dog that has not been in the home for months, e. Removal of alterations that were approved in writing pursuant to the contract, f. Removal of security cameras that could capture Defendants’ unlawful behavior, g. A demand that Plaintiffs organize their garage because the stored items “Obstruct access to the water heater and attic/furnace, preventing proper inspection…” 35. These allegations are false. 36. Defendant also created a number of insane and expensive “cures” to remedy their fake issues. These include a. A demand to “properly fill, grade, compact, and stabilize, the area to restore drainage away from the structure.” b. A demand for a “licensed, insured, and commercial established” company specializing in “pet waste” and “biohazard remediation” to clean the property. c. “Mandatory” carpet cleaning by a “truck-mounted how water extraction” vehicle that “use[s] enzymatic and bio-active pet waste neutralizers.’ d. “Professional treatment” of baseboards, subfloor transitions, and flooring utilizing “enzymatic or bio-neutralizing products designed for cleaning animal waste.” e. “Ozone or Hydroxyl treatment” for “odor neutralization.” f. Removal of all alterations that were previously approved in writing despite the fact that such alterations are only to be removed at the end of the lease. g. Time consuming preapproval of every correction prior to purchase or install to include “manufacturer” and model, “retailer SKU” “specification sheet” “licensed installer information,1” “proof of insurance2,” “Written scope of work,” and “proposed install date.” 37. Defendants created fake problems for Plaintiffs to “cure” to justify their unlawful eviction and attempted breach of contract. 38. Defendants’ “cures” are exceedingly expensive, unnecessary, and merely interposed to create impossible barriers to continuing the lease. 39. Many of the “cures” are impossible such as proof of insurance prior to purchasing equipment or biohazard remediation. 40. Defendants’ complaints in their 10-day notice to cure are purely pretextual. COUNT 1: BREACH OF CONTRACT 41. Plaintiffs and Defendants entered into a valid contract for the lease of The Home. 42. This agreement was in writing and clearly laid out the duties of the parties. 43. Defendants breached this contract by repudiating their obligations via termination notice on February 3, 2026. Exhibit B. ______________________________ 1 Licensed installer information is generally not presented until after purchase. 2 It is unknown what insurance could be purchased prior to the purchase of materials or what would be insured. 44. Defendants breached this contract by showing and listing the home for sale 200 days prior to date allowed by contract. Exhibit A ¶ 13. 45. Defendants breached this contract by interfering with Plaintiffs’ contractual right of quiet enjoyment. Exhibit A ¶ 18. 46. Defendants breached this contract by failing to repair the premises as required by contract. 47. Defendants breached this contract by entering the property without the consent of Plaintiffs and without a valid 24-hour notice. 48. Defendants’ actions constitute a material breach of the agreement. 49. Plaintiffs were harmed by Defendant’s Breach in the amount to be determined at trial. Defendants’ breach is ongoing and cannot be fully calculated at this time. 50. Defendants’ breach also caused consequential damages as stated below. 51. As such, Defendant is indebted to Plaintiff in an amount to be determined at trial. COUNT 2: CONSEQUENTIAL DAMAGES 52. At the time of contracting, Defendants were aware that breach would cause harm to Plaintiffs. 53. Plaintiffs have sustained emotional and financial harm as a result of the breach. 54. Such damages were foreseeable. 55. As such, Plaintiffs should recover consequential damages in the amount of to be determined at trial. COUNT 3: TRESPASS 56. Plaintiffs have a right to exclusive possession of The Home. 57. Defendant did not have permission or legal authority to enter The Home without sending Plaintiffs a notice, 24 hours in advance, that she would be entering The Home. 58. Defendant did not make such notice. 59. Instead, Defendant Ashley Dixon entered by stealth and guile. 60. Such trespass was unlawful. 61. Thus, Plaintiffs were harmed in an amount to be determined at trial. COUNT 4: INTRUSION INTO SECLUSION 62. While Trespassing, Defendant Ashley Dixon searched private places in Plaintiffs’ home. 63. Plaintiffs believe that further discovery will show that Ashely Dixon took photos or videos of such private places. 64. Defendant Ashley Dixon knew that she did not have permission to do so. 65. Defendant Ashely Dixon did so for the purpose of harassing, intimidating, and coercing Plaintiffs. 66. Plaintiffs suffered emotional harm from unlawful and tortious intrusion. 67. Plaintiffs have been harmed in an amount to be determined at trial. COUNT 5: OUTRAGE 68. Defendants created fake and unreasonable demands to unlawfully evict Plaintiffs from their home. 69. Defendants attempted to unlawfully terminate their lease with Plaintiffs for material gain. 70. When Defendants were unsuccessful in scaring Plaintiffs away, they trespassed and searched Plaintiffs’ Home, including private places. 71. Defendants’ actions were so outrageous that they could not be tolerated in a civilized society. 72. Defendants’ actions were intended to cause emotional harm. 73. Defendants’ actions were successful in causing severe emotional harm, including physical manifestations of that harm 74. Thus, Plaintiffs have been harmed in an amount to be determined at trial. COUNT 6: Violations of the Landlord Tenant Act 75. Oklahoma law requires that “Every duty under this act and every act which must be performed as a condition precedent to the exercise of a right or remedy under this act imposes an obligation of good faith in its performance or enforcement.” 41 O.S. § 107. 76. Defendants have failed to act in good faith when dealing with Plaintiffs. 77. Defendants offered a leasing contract to Plaintiffs that was validly executed. 78. However, this agreement contained unlawful and unenforceable provisions including: a. An agreement to pay the lessor’s attorney’s fees (41 O.S. §113 (A)(1)). b. An agreement to the exculpation, limitation or indemnification of any liability arising under law for damages or injuries to persons or property caused by or resulting from the acts or omissions of either party, their agents, servants or employees in the operation or maintenance of the dwelling unit or the premises of which it is a part; (41 O.S. §113 (A)(4)). 79. A landlord shall not abuse the right of access or use it to harass the tenant. 41 O.S. § 128(c). 80. Defendant Ashley Dixon unlawfully entered The Home in violation of 41 O.S. § 124. 81. In the alternative, Defendant Ashley Dixon lawfully entered The Home in an unreasonable manner in violation of 41 O.S. § 124. 82. Defendant Ashley Dixon harassed Plaintiffs by making repeated unreasonable demands for entry in violation of 41 O.S. § 124. 83. Defendant created new rules in their 10-day notice to cure which were arbitrary, unfair, and intended to impossible to follow. This alteration is a substantial modification of such tenant's bargain. 84. Plaintiffs have been harmed in an amount to be determined at trial. 85. Plaintiffs are entitled to attorney’s fees at the adjudication of this action. 86. Plaintiffs are entitled to injunctive relief pursuant to 41 O.S. § 124. COUNT 7: Declaratory Judgement. 87. Defendants sent a notice stating that the lease has been terminated unilaterally with 30 days’ notice. 88. Plaintiffs do not believe that Defendants have the right to terminate such lease. 89. Defendants then sent a 10-day notice to cure alleged defects. 90. Plaintiffs do not believe that the defects exist. 91. Plaintiffs believe that any alleged defects that might exist are not terminable offenses under the lease. 92. Plaintiffs believe that any alleged defects that might exist are the responsibility of Defendants. 93. Defendant’s 10-day notice to cure is fraudulent and created to create a pretextual reason for eviction. 94. Thus, Defendants do not have the power to terminate the lease. 95. Plaintiffs believe that further discovery will show that Defendants told the two unknown Buyers that they could move into the home before October 1, 2026. 96. However, Plaintiffs have a right to exclusive possession of the property up to and until October 1, 2026. 97. Plaintiffs ask that the Court enter a binding order stating: a. Defendants do not have the right to unilaterally terminate the lease with 30 days’ notice, b. Defendants’ 10-day notice to cure includes fraudulent allegations, c. Defendants’ 10-day notice to cure was created to unlawfully evict Plaintiffs, d. The Two Unknown Buyers will be bound by the lease originally created between Plaintiffs and Defendants. e. Plaintiffs have a right to exclusive possession of the property up to and until October 1, 2026, f. Plaintiffs have not materially breached the Lease, g. The Two Unknown Buyers do not have a right to interfere with Plaintiffs’ exclusive possession of the property upon the purchase of the Home. 98. Plaintiffs request attorneys’ fees upon prevailing on this action. WHEREFORE, premise considered, Plaintiff prays for judgment against Defendant in a sum not expected to exceed $75,000 in damages as determined at a jury trial, a reasonable attorney’s fee, the costs of this action, an injunction preventing Defendants from entering the home, a declaratory judgement in favor of Plaintiff, reasonable sanctions, post judgment interest as specified by 12 O.S. 2013 Supp. §727.1, and for any and all further relief the Court deems is just and proper. SIGNATURE ON FOLLOWING PAGE RESPECTFULLY SUBMITTED, Alex Sprenger OBA NO 35843 BOSTON AVENUE LAW PLLC 320 S. Boston Ave., Suite 718 Tulsa, OK 74103 (t) 539.777.1287 / (f) 405.509.7100 Email: [email protected] ATTORNEY FOR PLAINTIFF RESIDENTIAL LEASE AGREEMENT THIS LEASE AGREEMENT (hereinafter referred to as the "Agreement") made and entered into this 13 day of September 2025 by and between Ashley J. Dixon and Rustin E. Dixon whose address is 1517 E Roanoke St. Broken Arrow OK 74011 hereinafter referred to as ("Lessor") and Braden Huff and Carissa Huff (hereinafter referred to as "Lessee"). WITNESSETH: WHEREAS, Lessor is the fee owner of certain real property being, lying and situated in WAGONER County, OKLAHOMA, such real property having a street address of 1500 S 28TH ST BROKEN ARROW OK 74014 WHEREAS, Lessor is desirous of leasing the Premises to Lessee upon the terms and conditions as contained herein; and NOW, THEREFORE, the covenants and obligations contained herein and other good and valuable consideration, the receipt and sufficiency of which is hereby acknowledged, the parties hereto hereby agree as follows: 1. TERM. Lessor leases to Lessee and Lessee leases from Lessor the above described Premises together with any and all appurtenances thereto, for a term of 1 year, such term beginning on OCTOBER 1ST 2025 at 12:01' clock am, and ending at 12 o'clock midnight on OCTOBER 1ST 2026. a. This Lease Agreement shall be for a term of twelve (12) months, commencing on OCTOBER 1ST 2025 and ending on OCTOBER 1ST 2026. Notwithstanding the stated term, Tenant shall have the right to terminate the lease early, without penalty, upon thirty (30) days’ written notice to Landlord, for the purpose of purchasing the property located at 1500 S. 28TH ST BROKEN ARROW OK 74014. 2. RENT. The total rent for the term hereof is the sum of TWENTY THOUSAND FOUR HUNDRED DOLLARS ($20,400.00). All payments must be made on the 1st of each succeeding month IN THE SUM OF $1700. All such payments shall be made to Lessor at Lessor's address as set forth in the preamble to this Agreement on or before the due date and without demand. Acceptable forms of payment include official cashier’s check payable to Lessor(s) or Venmo @Ashley-dixon-31. 3. DAMAGE DEPOSIT. Upon the due execution of this Agreement, Lessee WILL DEPOSIT BY OCTOBER 18TH 2024 with Lessor the sum of ($1700) ONE THOUSAND SEVEN HUNDRED receipt of which is hereby acknowledged by Lessor as security for any damage caused to the Premises during the term hereof. Such deposit shall be returned to Lessee, without interest, and less any set off for damages to the Premises upon the termination of this Agreement. 4. USE OF PREMISES. The Premises shall be used and occupied by Lessee and Lessee's immediate family, consisting exclusively, as a private single family dwelling, and no part of the Premises shall be used at any time during the term of this Agreement by Lessee for the purpose of carrying on any business, profession, or trade of any kind, or for any purpose other than as a private single family dwelling. Lessee shall not allow any other person, other than Lessee's immediate family or transient relatives and friends who are guests of Lessee, to use or occupy the Premises without first obtaining Lessor's written consent to such use. Lessee shall comply with any and all laws, ordinances, rules and orders of any and all governmental or quasi-governmental authorities affecting the cleanliness, use, occupancy and preservation of the Premises. 5. CONDITION OF PREMISES. Lessee stipulates, represents and warrants that Lessee has examined the Premises, and that they are at the time of this Lease in good order, repair, and in a safe, clean and tenantable condition. 6. ASSIGNMENT AND SUB-LETTING. Lessee shall not assign this Agreement, or sub-let or grant any license to use the Premises or any part thereof without the prior written consent of Lessor. A consent by Lessor to one such assignment, sub-letting or license shall not be deemed to be a consent to any subsequent assignment, sub-letting or license. An assignment, sub-letting or license without the prior written consent of Lessor or an assignment or sub-letting by operation of law shall be absolutely null and void and shall, at Lessor's option, terminate this Agreement. 7. ALTERATIONS AND IMPROVEMENTS. Lessee shall make no alterations to the buildings or improvements on the Premises or construct any building or make any other improvements on the Premises without the prior written consent of Lessor. Any and all alterations, changes, and/or improvements built, constructed or placed on the Premises by Lessee shall, unless otherwise provided by written agreement between Lessor and Lessee, be and become the property of Lessor and remain on the Premises at the expiration or earlier termination of this Agreement. 8. NON-DELIVERY OF POSSESSION. In the event Lessor cannot deliver possession of the Premises to Lessee upon the commencement of the Lease term, through no fault of Lessor or its agents, then Lessor or its agents shall have no liability, but the rental herein provided shall abate until possession is given. Lessor or its agents shall have thirty (30) days in which to give possession, and if possession is tendered within such time, Lessee agrees to accept the demised Premises and pay the rental herein provided from that date. In the event possession cannot be delivered within such time, through no fault of Lessor or its agents, then this Agreement and all rights hereunder shall terminate. 9. HAZARDOUS MATERIALS. Lessee shall not keep on the Premises any item of a dangerous, flammable or explosive character that might unreasonably increase the danger of fire or explosion on the Premises or that might be considered hazardous or extra hazardous by any responsible insurance company. 10. UTILITIES. LESSEE WILL BE RESPONSIBLE FOR ALL UTILITIES 12. APPLIANCES- STOVE, RANGE, DISHWASHER, FRIDGE, MICROWAVE PROVIDED BY LANDLORD 11. MAINTENANCE AND REPAIR; RULES. Lessee will, at its sole expense, keep and maintain the Premises and appurtenances in good and sanitary condition and repair during the term of this Agreement and any renewal thereof. Without limiting the generality of the foregoing, Lessee shall: (a) Not obstruct the driveways, sidewalks, courts, entry ways, stairs and/or halls, which shall be used for the purposes of ingress and egress only; (b) Keep all windows, glass, window coverings, doors, locks and hardware in good, clean order and repair; (c) Not obstruct or cover the windows or doors; (d) Not leave windows or doors in an open position during any inclement weather; (e) Not hang any laundry, clothing, sheets, etc. from any window, rail, porch or balcony nor air or dry any of same within any yard area or space; (f) Not cause or permit any locks or hooks to be placed upon any door or window without the prior written consent of Lessor; (g) Keep all air conditioning filters clean and free from dirt; (h) Keep all lavatories, sinks, toilets, and all other water and plumbing apparatus in good order and repair and shall use same only for the purposes for which they were constructed. Lessee shall not allow any sweepings, rubbish, grease, sand, rags, ashes or other substances to be thrown or deposited therein. Any damage to any such apparatus and the cost of clearing stopped plumbing resulting from misuse shall be borne by Lessee; (i) And Lessee's family and guests shall at all times maintain order in the Premises and at all places on the Premises, and shall not make or permit any loud or improper noises, or otherwise disturb other residents; (j) Keep all radios, television sets, stereos, phonographs, etc., turned down to a level of sound that does not annoy or interfere with other residents; (k) Deposit all trash, garbage, rubbish or refuse in the locations provided therefor and shall not allow any trash, garbage, rubbish or refuse to be deposited or permitted to stand on the exterior of any building or within the common elements; (l) Abide by and be bound by any and all rules and regulations affecting the Premises or the common area appurtenant thereto which may be adopted or promulgated by the Condominium or Homeowners' Association having control over them. (m) Tenant will be responsible for testing the smoke detectors and to replace batteries in those units as needed. Detectors will make a chirping noise when the battery is weak. Should the unit not respond when tested with fresh batteries the tenant is to alert the landlord and the unit will be replaced. The tenant may install a carbon monoxide detector but must also test and replace batteries in that unit on a continual basis. (N) Tenant shall keep the premises clean and sanitary inside and out, using proper cleaning products for various surfaces. (O) Tenant must provide a working telephone number for the landlord. (P) Tenant shall keep home free of extreme dust, especially around electrical components and heating/cooling components. (Q) Drain stoppages, light bulb replacement, filter replacements, and any standard homeowners maintenance items that are under $50.00 will be the responsibility of the tenant. (r) Tenant will be responsible for any pest treatment required of the property during their occupancy outside of 60 days of move-in. (s) Tenant will keep the electricity on until the date of the final walk-thru with management. (t) No satellites or outdoor antennas are allowed without permission. 12. DAMAGE TO PREMISES. In the event the Premises are destroyed or rendered wholly untenantable by fire, storm, earthquake, or other casualty not caused by the negligence of Lessee, this Agreement shall terminate from such time except for the purpose of enforcing rights that may have then accrued hereunder. The rental provided for herein shall then be accounted for by and between Lessor and Lessee up to the time of such injury or destruction of the Premises, Lessee paying rentals up to such date and Lessor refunding rentals collected beyond such date. Should a portion of the Premises thereby be rendered untenantable, the Lessor shall have the option of either repairing such injured or damaged portion or terminating this Lease. In the event that Lessor exercises its right to repair such untenantable portion, the rental shall abate in the proportion that the injured parts bears to the whole Premises, and such part so injured shall be restored by Lessor as speedily as practicable, after which the full rent shall recommence and the Agreement continue according to its terms. 13. INSPECTION OF PREMISES. Lessor and Lessor's agents shall have the right at all reasonable times during the term of this Agreement and any renewal thereof to enter the Premises for the purpose of inspecting the Premises and all buildings and improvements thereon. And for the purposes of making any repairs, additions or alterations as may be deemed appropriate by Lessor for the preservation of the Premises or the building. Lessor and its agents shall further have the right to exhibit the Premises and to display the usual "for sale", "for rent" or "vacancy" signs on the Premises at any time within forty-five (45) days before the expiration of this Lease. The right of entry shall likewise exist for the purpose of removing placards, signs, fixtures, alterations or additions, but do not conform to this Agreement or to any restrictions, rules or regulations affecting the Premises. 14. SUBORDINATION OF LEASE. This Agreement and Lessee's interest hereunder are and shall be subordinate, junior and inferior to any and all mortgages, liens or encumbrances now or hereafter placed on the Premises by Lessor, all advances made under any such mortgages, liens or encumbrances (including, but not limited to, future advances), the interest payable on such mortgages, liens or encumbrances and any and all renewals, extensions or modifications of such mortgages, liens or encumbrances. 15. LESSEE'S HOLD OVER. If Lessee remains in possession of the Premises with the consent of Lessor after the natural expiration of this Agreement, a new tenancy from month-to-month shall be created between Lessor and Lessee which shall be subject to all of the terms and conditions hereof except that rent shall then be due and owing at $1800 per month and except that such tenancy shall be terminable upon thirty (30) days written notice served by either party. 16. SURRENDER OF PREMISES. Upon the expiration of the term hereof, Lessee shall surrender the Premises in as good a state and condition as they were at the commencement of this Agreement, reasonable use and wear and tear thereof and damages by the elements expected. 17. ANIMALS. Lessee shall be entitled to keep no more than (2) domestic dogs, however, at such time as Lessee shall actually keep any such animal on the Premises, Lessee shall pay to Lessor a pet FEE of ONE HUNDRED ($100) PER DOG, of which shall be non-refundable. 18. QUIET ENJOYMENT. Lessee, upon payment of all of the sums referred to herein as being payable by Lessee and Lessee's performance of all Lessee's agreements contained herein and Lessee's observance of all rules and regulations, shall and may peacefully and quietly have, hold and enjoy said Premises for the term hereof. 19. INDEMNIFICATION. Lessor shall not be liable for any damage or injury of or to the Lessee, Lessee's family, guests, invitees, agents or employees or to any person entering the Premises or the building of which the Premises are a part or to goods or equipment, or in the structure or equipment of the structure of which the Premises are a part, and Lessee hereby agrees to indemnify, defend and hold Lessor harmless from any and all claims or assertions of every kind and nature. 20. DEFAULT. If Lessee fails to comply with any of the material provisions of this Agreement, other than the covenant to pay rent, or of any present rules and regulations or any that may be hereafter prescribed by Lessor, or materially fails to comply with any duties imposed on Lessee by statute, within FIVE (5) days after delivery of written notice by Lessor specifying the non-compliance and indicating the intention of Lessor to terminate the Lease by reason thereof, Lessor may terminate this Agreement. If Lessee fails to pay rent when due and the default continues for FIVE (5) days thereafter, Lessor may, at Lessor's option, declare the entire balance of rent payable hereunder to be immediately due and payable and may exercise any and all rights and remedies available to Lessor at law or in equity or may immediately terminate this Agreement. 21. LATE CHARGE. In the event that any payment required to be paid by Lessee hereunder is not made within eight (8) days of when due, Lessee shall pay to Lessor, in addition to such payment or other charges due hereunder, a "late fee" in the amount of ONE HUNDRED dollars ($100) for each month the rent is late. 22. ABANDONMENT. If at any time during the term of this Agreement Lessee abandons the Premises or any part thereof, Lessor may, at Lessor's option, obtain possession of the Premises in the manner provided by law, and without becoming liable to Lessee for damages or for any payment of any kind whatever. Lessor may, at Lessor's discretion, as agent for Lessee, relet the Premises, or any part thereof, for the whole or any part thereof, for the whole or any part of the then unexpired term, and may receive and collect all rent payable by virtue of such reletting, and, at Lessor's option, hold Lessee liable for any difference between the rent that would have been payable under this Agreement during the balance of the unexpired term, if this Agreement had continued in force, and the net rent for such period realized by Lessor by means of such reletting. If Lessor's right of reentry is exercised following abandonment of the Premises by Lessee, then Lessor shall consider any personal property belonging to Lessee and left on the Premises to also have been abandoned, in which case Lessor may dispose of all such personal property in any manner Lessor shall deem proper and Lessor is hereby relieved of all liability for doing so. 23. ATTORNEYS' FEES. Should it become necessary for Lessor to employ an attorney to enforce any of the conditions or covenants hereof, including the collection of rentals or gaining possession of the Premises, Lessee agrees to pay all expenses so incurred, including a reasonable attorneys' fee. 24. RECORDING OF AGREEMENT. Lessee shall not record this Agreement on the Public Records of any public office. In the event that Lessee shall record this Agreement, this Agreement shall, at Lessor's option, terminate immediately and Lessor shall be entitled to all rights and remedies that it has at law or in equity. 25. GOVERNING LAW. This Agreement shall be governed, construed and interpreted by, through and under the Laws of the State of Oklahoma. 26. SEVERABILITY. If any provision of this Agreement or the application thereof shall, for any reason and to any extent, be invalid or unenforceable, neither the remainder of this Agreement nor the application of the provision to other persons, entities or circumstances shall be affected thereby, but instead shall be enforced to the maximum extent permitted by law. 27. BINDING EFFECT. The covenants, obligations and conditions herein contained shall be binding on and inure to the benefit of the heirs, legal representatives, and assigns of the parties hereto. 28. DESCRIPTIVE HEADINGS. The descriptive headings used herein are for convenience of reference only and they are not intended to have any effect whatsoever in determining the rights or obligations of the Lessor or Lessee. 29. CONSTRUCTION. The pronouns used herein shall include, where appropriate, either gender or both, singular and plural. 30. NON-WAIVER. No indulgence, waiver, election or non-election by Lessor under this Agreement shall affect Lessee's duties and liabilities hereunder. 31. MODIFICATION. The parties hereby agree that this document contains the entire agreement between the parties and this Agreement shall not be modified, changed, altered or amended in any way except through a written amendment signed by all of the parties hereto. 31. KEYS- Tenant will be given 2 keys, the house key will be $5.00 to replace along with a garage code. All codes are newly established between each agreement. Lessor(s) must be notified if the code is changed from what is provided on SEPTEMBER 18TH 2024 to ensure access in the event of an emergency. Lessor(s) will not access premises without written notification given at least 24 hours in advance to Lessee. 9/13/2025 Lessor Date 9/13/2025 Lessee Date 9/13/2025 Lessor Date 9/14/2025 Lessee Date Disclosure Form for Target Housing Rentals and Leases Disclosure of Information on Lead-Based Paint and/or Lead-Based Paint Hazards Lead Warning Statement Housing built before 1978 may contain lead-based paint. Lead from paint, paint chips, and dust can pose health hazards if not managed properly. Lead exposure is especially harmful to young children and pregnant women. Before renting pre-1978 housing, lessors must disclose the presence of known lead-based paint and/or lead-based paint hazards in the dwelling. Lessees must also receive a federally approved pamphlet on lead poisoning prevention. Lessor's Disclosure (initial) __________(a) Presence of lead-based paint or lead-based paint hazards (check one below): ☐ Known lead-based paint and/or lead-based paint hazards are present in the housing (explain). ☒ Lessor has no knowledge of lead-based paint and/or lead-based paint hazards in the housing. __________(b) Records and reports available to the lessor (check one below): ☐ Lessor has provided the lessee with all available records and reports pertaining to lead-based paint and/or lead-based paint hazards in the housing (list documents below). ☒ Lessor has no reports or records pertaining to lead-based paint and/or lead-based paint hazards in the housing. Lessee's Acknowledgment (initial) __________(c) Lessee has received copies of all information listed above. __________(d) Lessee has received the pamphlet Protect Your Family From Lead in Your Home. Certification of Accuracy The following parties have reviewed the information above and certify, to the best of their knowledge, that the information provided by the signatory is true and accurate. [Signature] 9/13/2025 [Signature] 9/13/2025 Lessor Date Lessor Date [Signature] 9/13/2025 [Signature] 9/14/2025 Lessee Date Lessee Date . . Notice of Lease Termination and Move-Out Requirements Braden and Carissa, This message serves as formal written notice of lease termination for the property located at 1500 S 28th St, Broken Arrow, OK 74014, pursuant to the lease provisions allowing termination with thirty (30) days' written notice in the event of a sale. Notice Date: February 3, 2026 Effective Date (Day 1): February 4, 2026 Final Day of Occupancy: Thursday, March 5, 2026 The property must be fully vacated by the end of the day on March 5, 2026, with possession surrendered at that time. Tenant-Owned / Tenant-Installed Items to Be Removed Please confirm and ensure the following tenant-owned or tenant-installed items are removed prior to move-out and do not remain with the property: • Front bedroom ceiling fan • Smart/high-tech thermostat • Smart front door lock and access hardware • Security system and cameras (including garage, exterior, doorbell, and interior components) • Walkway lighting installed by tenant • Television mount and wall outlet behind TV • Modified rear door with dog door (door for the original Condition of Premises at Surrender At move-out, the property should be returned in a neat, presentable condition, consistent with the lease and standard move-out expectations, including: • All personal belongings removed from the home, garage, and yard • All trash removed from the property • Yard and exterior areas fully picked up; with no pet waste remaining on the property Notice of Lease... • Yard and exterior areas fully picked up, with no pet waste remaining on the property • The pet waste bin emptied prior to move-out so no waste remains on site • No new damage beyond normal wear and tear • Utilities remaining active through the move-out date The attached Tenant Move-Out Checklist applies in full and is provided for clarity and consistency. Utilities As outlined in the lease, utilities must remain active and in the tenant's name through the entire lease responsibility period, including the full move-out date of March 5, 2026. Please schedule termination of utility Utilities As outlined in the lease, utilities must remain active and in the tenant's name through the entire lease responsibility period, including the full move-out date of March 6, 2026. Please schedule termination of utility services effective end of day March 5, 2026. We will establish service in our name beginning March 6, 2026, so no transfer action is needed beyond confirming your end date. Keys, Access & Final Walkthrough All keys, garage openers, and access devices are to be returned upon move-out. Final walkthrough and turnover coordination details will be provided closer to the move-out date. NOTICE OF TERMINATION AND NOTICE TO CURE LEASE VIOLATIONS Pursuant to Oklahoma Law and Residential Lease Agreement Date: February 6, 2026 Property: 1500 S 28th St, Broken Arrow, OK 74014 Tenants: Braden Huff and Carissa Huff Lessor: Ashley J. Dixon and Rustin E. Dixon EX C NOTICE OF TERMINATION (CONDITIONAL) Pursuant to 41 O.S. § 132(B), you are hereby notified that your Residential Lease Agreement SHALL TERMINATE on February 21, 2026, which is not less than fifteen (15) days after receipt of this Notice, unless the material noncompliance and lease violations specified below are fully remedied and cured within ten (10) days of your receipt of this Notice. If the breaches are not fully cured no later than the end of day February 16, 2026, the Lease shall terminate as provided herein, and you must vacate the Premises no later than February 21, 2026. If you remain in possession after the termination date, a Forcible Entry and Detainer (FED) action will be filed in Wagoner County District Court to recover possession of the Premises, together with court costs, attorney fees, and any other relief allowed by law. NOTICE TO CURE LEASE VIOLATIONS This Notice is issued pursuant to the Residential Lease Agreement dated September 13, 2025 ("Lease") and applicable Oklahoma law. It serves as formal notice of multiple material lease violations requiring cure. ALL violations listed herein must be fully cured within ten (10) days of the date of this Notice. Failure to timely and fully cure any violation will result in enforcement as described herein. I. MAINTENANCE, HEALTH & SAFETY VIOLATIONS Deadline to Cure: Ten (10) Days 1. Obstruction of Mechanical Systems Lease References: Sections 11(a); 13 Stored items and personal property obstruct access to the water heater and attic/furnace, preventing proper inspection, servicing, and emergency access. Required Cure: Remove all obstructions so these systems are fully and unobstructedly accessible at all times. Partial clearance or temporary relocation does not constitute compliance. 2. Unsanitary Conditions – Pet Waste & Pest Activity Lease References: Sections 11(n), 11(o), 11(q) Excessive pet waste accumulation, waste tracked indoors, and conditions contributing to pest activity have resulted in unsanitary and unhealthy conditions inside and outside the Premises. Required Cure: Immediate remediation and restoration of the Premises to a clean, sanitary, and health-safe condition, interior and exterior. 3. Exterior Ground Disturbance & Drainage Impact Lease References: Sections 11; 12 A hole dug near the rear exterior has exposed the foundation and altered drainage toward the structure. Required Cure: Properly fill, grade, compact, and stabilize the area to restore drainage away from the structure. II. INTERIOR SANITATION – PROFESSIONAL BIOHAZARD-LEVEL CLEANING REQUIRED (Animal Fecal Contamination / Unsanitary Conditions) Deadline to Cure: Ten (10) Days Lease References: Sections 11(n), 11(o), 11(q) The interior of the Premises has been contaminated by animal fecal matter and biological waste, affecting carpets, padding, flooring, baseboards, and living surfaces. These conditions constitute unsanitary conditions beyond ordinary wear and tear. REQUIRED CURE – STRICT COMPLIANCE / NO SUBSTITUTIONS / NO EXCEPTIONS 1. Professional Cleaning Company Requirements • Must be licensed, insured, and commercially established • Must document experience in pet waste, fecal, or biohazard remediation • Residential or consumer cleaning services are not acceptable 2. Carpet & Padding Treatment (MANDATORY) • Truck-mounted hot water extraction only • Minimum two full extraction passes per affected area • Use of enzymatic and bio-active pet waste neutralizers • Portable units, rental machines, or consumer-grade equipment strictly prohibited • If contamination has penetrated carpet padding, padding replacement may be required 3. Hard Surfaces & Structural Components Professional treatment is required for all affected: • Baseboards • Subfloor transitions • Tile, vinyl, or laminate flooring • Door thresholds and lower wall areas Cleaning agents must be enzymatic or bio-neutralizing products designed for animal waste. 4. Odor Neutralization • Masking agents or fragrances do not constitute remediation • Odors must be eliminated at the source • Ozone or hydroxyl treatment may be required if recommended by the remediation company 5. Proof of Completion – DOCUMENTATION REQUIRED Tenant must submit all of the following: 1. Paid invoice (not estimate) 2. Company name, license, and insurance information 3. Itemized scope identifying: o Fecal / pet waste remediation o Areas treated o Equipment and chemicals used 4. Date(s) of service 5. Written confirmation the Premises was restored to a sanitary condition 6. VERIFICATION • Documentation alone does not establish cure • Lessor reserves the right to inspect upon 24-hour notice • If odors, residue, or contamination remain, cure is deemed incomplete • Re-cleaning or landlord-performed remediation may occur at Tenant’s expense III. UNAUTHORIZED ALTERATIONS & IMPROVEMENTS Deadline to Cure: Ten (10) Days III.A. PRIOR WRITTEN CONSENT REQUIRED (APPLIES TO ITEMS 4–9) No repair, replacement, restoration, installation, or modification of any kind shall be performed by Tenant without the Lessor’s prior written consent. Verbal discussions, text messages, estimates, receipts, or contractor communications do not constitute approval. Consent must be express, written, and issued by the Lessor after review of required documentation. Any work commenced without prior written consent shall be deemed unauthorized, shall not constitute cure, and shall be treated as an additional lease violation. 4. Front Entry Door – Unauthorized Electronic Lock Lease References: Sections 7; 31 Original keyed lock hardware was removed and replaced with an electronic lock without consent. Required Cure: Restore compliant keyed access. All electronic locking devices must be removed. 5. Thermostat – Unauthorized Replacement Lease References: Sections 7; 12 Restore original thermostat or install a builder-grade, non-smart thermostat with prior written approval. 6. Doorbell – Unauthorized Ring Installation Lease References: Sections 7; 12 Remove Ring doorbell and restore original or Lessor-approved equivalent. 7. Middle Room Light Fixture Lease Reference: Section 7 Restore original fixture or Lessor-approved equivalent. 8. Rear Exterior Entry Door – STRICT RESTORATION REQUIRED Lease References: Sections 7; 12 Tenant installed a dog door into the rear exterior entry door without consent, constituting a material alteration and permanent damage. Required Cure (STRICT COMPLIANCE – NON-NEGOTIABLE): Replace the door in its entirety with a new, unmodified door matching the original builder-installed door in all material respects, subject to prior written approval. Required Specifications (ALL MANDATORY): • 36 in. x 80 in. • Half-lite clear glass • Insulated steel • Pre-hung • 6-9/16 in. jamb • Inswing • Exterior: Black | Interior: White • No pet openings or modifications PRE-APPROVAL REQUIREMENTS Before ordering or installing, Tenant must submit: • Manufacturer and model • Retailer SKU • Specification sheet • Licensed installer information • Proof of insurance • Written scope of work • Proposed install date Approval is not automatic and may be withheld at Lessor’s discretion. INSTALLATION & VERIFICATION • Installation only after written approval • Paid invoice required • Subject to inspection • No cure until confirmed by Lessor 9. Exterior Wall Penetration – Garage Installation Lease References: Sections 7; 12 Unauthorized exterior wall penetration. Required Cure: Professional repair restoring a weather-tight condition, subject to prior written approval. IV. ANIMAL VIOLATION Deadline to Cure: Ten (10) Days Lease Reference: Section 17 A third dog was present without consent. Required Cure: Immediate compliance with the Lease animal limit. V. VERIFICATION OF CURE & RIGHT OF INSPECTION Lease Reference: Section 13 Documentation alone does not verify compliance. Lessor reserves the right to inspect upon 24-hour notice. Partial compliance does not constitute cure. VI. ENFORCEMENT & NO-EXTENSION PROVISIONS • No extensions will be granted • No substitutions permitted • No further notice required prior to remediation • Lessor is the sole authority determining whether cure is complete VII. FAILURE TO CURE If violations remain uncured, Lessor may remediate immediately and recover all costs. Failure to reimburse constitutes a continuing default under Section 20 of the Lease. DELIVERY OF NOTICE Delivered in accordance with the Lease and Oklahoma law by physical posting, electronic transmission, and mail. Ashley J. Dixon Rustin E. Dixon IN THE DISTRICT COURT IN AND FOR WAGONER COUNTY STATE OF OKLAHOMA Braden and Carissa Huff, Plaintiffs, v. Ashley Dixon and Rustin Dixon, Individuals, Two Unknown Buyers, Future Parties in interest, Defendants. Case No.: CJ 20-47 ENTRY OF APPEARANCE Comes now, Alexandr Sprenger of Boston Avenue Law PLLC, and appears as counsel for Plaintiffs in the present case. Plaintiff further asks that all documents, notices, and communication regarding this case be sent to the address listed in the signature block below. RESPECTFULLY SUBMITTED Alexandr Sprenger, OBA #35843 BOSTON AVENUE LAW PLLC 320 S. Boston Ave., Suite 718 Tulsa, OK 74103 (t) 539.777.1287 / (f) 405.509.7100 [email protected] ATTORNEYS FOR PLAINTIFF