CIVIL
IN THE DISTRICT COURT OF TULSA COUNTY
STATE OF OKLAHOMA
RUBEN JONES JR.,
Plaintiff,
vs.
RICARDO COLLINS SR., MARION BOSTON and JOSEPH A. MCCORMICK, ESQ.,
Defendants.
ORDER CORRECTING CASE DESIGNATION
Upon review of the pleadings, the Court has determined that the above matter was erroneously filed as a CS matter when it should have been filed as a CJ matter. The Court Clerk is hereby ordered to refile the above matter with the correct case designation. Any filing fees and costs already paid shall be transferred to the new case filing and a minute entered in the above matter noting such transfer.
IT IS SO ORDERED.
Dated this 8th day of April, 2026.
Melma East
Judge of the District Court
IN THE DISTRICT COURT OF TULSA COUNTY, STATE OF OKLAHOMA
Case No.: 18-3026-0544
MR. RUBEN JONES JR.,
by and through his Authorized Representative,
LISA MCINTOSH,
Plaintiff,
v.
RICARDO COLLINS SR.,
MARION BOSTON,
and
JOSEPH A. McCORMICK, ESQ.,
Defendants.
CJ-2026-01779
CAROLINE E. WELL
MOTION FOR DEFAULT JUDGMENT AND ORDER GRANTING DEFAULT JUDGMENT WITH DAMAGES PAYABLE WITHIN FIVE (5) BUSINESS DAYS UPON RECEIPT BY MAIL
COMES NOW the Plaintiff, Mr. Ruben Jones Jr., by and through his Authorized Representative, Lisa McIntosh, and respectfully moves this Court for entry of Default Judgment against all Defendants, and in support thereof states as follows:
SUMMARY OF MATTER BEFORE THE COURT
This matter arises from Defendants’ intentional interference with a valid real estate contract involving approximately 5 acres (217,800 square feet) of real property located at 145 E. 59th
Street North, Tulsa, Oklahoma 74126. Plaintiff established a first-in-time binding agreement, preserved his rights through a title company, and demonstrated that Defendants attempted to circumvent the contract to capture a $10,000 profit. Despite proper registered mail service, Defendants failed to appear or respond. The record supports entry of default judgment and enforcement against the subject property.
I. FACTUAL BACKGROUND AND SERVICE
1. Plaintiff served Defendants via registered mail on February 24, 2026.
2. Defendant Joseph A. McCormick, Esq. received notice on February 27, 2026.
3. Defendants Ricardo Collins Sr. and Marion Boston received notice on March 2, 2026.
4. Defendants failed to respond within the required time and are therefore in default.
II. PROPERTY IDENTIFICATION (SUBJECT TO ENFORCEMENT)
Property Address:
145 E. 59th Street North
Tulsa, Oklahoma 74126
Property Size:
Approximately 5 acres (217,800 square feet), more or less
Legal Description:
The West half of the Southwest Quarter of the Northeast Quarter of the Southeast Quarter, (W/2 SW/4 NE/4 SE/4) of Section 2, Township 20 North, Range 12 East of the Indian Base and Meridian, Tulsa County, State of Oklahoma, according to the U.S. Government Survey thereof.
III. DAMAGES
Contract Profit: $10,000.00
Finder's Fee / Interference Damages: $4,000.00
White-Collar Liability:
Ricardo Collins Sr.: $4,000.00
Marion Boston: $4,000.00
Joseph A. McCormick: $4,000.00
TOTAL DAMAGES: $26,000.00
IV. CONCLUSIONS OF LAW
1. Defendants Are in Default
• Under 12 O.S. § 2004, service by mail is complete upon delivery.
• Under 12 O.S. § 2012, a party must respond within the time allowed.
• Under 12 O.S. § 1031, courts may enter judgment upon failure to respond.
Defendants’ failure to respond places them in default.
2. Plaintiff Is Entitled to Default Judgment
• Ferguson Enterprises, Inc. v. H. Webb Enterprises, Inc., 2000 OK 78 – Default judgment proper when defendant fails to defend.
• Patel v. OMH Medical Center, Inc., 1999 OK 33 – Default admits all properly pleaded facts.
3. Plaintiff Is Entitled to Damages and Enforcement
• Mac Adjustment, Inc. v. Property Loss Research Bureau, 1979 OK 41 – Interference supports recovery of damages and lost profits.
• Wilspec Technologies, Inc. v. Dunan Holding Group Co., Ltd., 2009 OK 12 – Intentional interference requires compensation.
V. REQUEST FOR RELIEF
Plaintiff respectfully requests that this Court enter judgment as follows:
I. INTRODUCTION
Plaintiff, Mr. Ruben Jones Jr., by and through his Authorized Representative, Lisa McIntosh, respectfully moves this Court for entry of Default Judgment against all Defendants.
This motion is based upon Defendants’ failure to respond after proper notice by registered mail sent on February 24, 2026, received by Defendant Joseph A. McCormick on February 27, 2026, and received by Defendant Ricardo Collins Sr. and Marion Boston on March 2, 2026.
Defendants have failed to respond within the required time, and are therefore in default.
This matter arises from intentional contract interference, fraudulent conduct, and attorney misconduct, resulting in damages totaling $26,000.00.
II. JURISDICTION AND VENUE
Jurisdiction and venue are proper in Tulsa County, Oklahoma, as the subject property and all relevant events occurred within this jurisdiction.
III. PARTIES
Plaintiff:
Mr. Ruben Jones Jr., lawful contract purchaser
Representative:
Lisa McIntosh
Defendants:
Ricardo Collins Sr. (Seller)
Marion Boston (Agent / Daughter)
Joseph A. McCormick, Esq. (Attorney for Defendants)
IV. FACTUAL BACKGROUND AND TIMELINE
December 28, 2025
A valid and binding purchase contract was executed for the property located at:
145 E 59th Street North
Turley, Oklahoma 74126
December 29, 2025
Ms. Marion Boston sent written communication thanking Plaintiff for the purchase, confirming the agreement.
December 29, 2025 (Conference Call)
Plaintiff disclosed that he had secured a buyer willing to pay approximately $57,000.
Upon learning this, Defendant Collins Sr. became dissatisfied and attempted to bypass Plaintiff in order to capture the $10,000 profit.
During this same call, Ms. Boston confirmed the contract was binding and could not be canceled.
December 30, 2025
Plaintiff submitted the contract to American Egal Title Company to secure and preserve his contractual rights.
December 31, 2025
An email from Apex confirmed readiness to close upon receipt of abstract, demonstrating that arrangements had already been made to redirect the transaction.
Resulting Conduct
Defendants attempted to:
• Cancel Plaintiff's valid contract
• Redirect the sale to Plaintiff's buyer
• Eliminate Plaintiff's $10,000 contractual profit
• Mislead Plaintiff into believing his contract was no longer valid
Plaintiff prevented this scheme by properly securing his contract through title.
V. LEGAL DESCRIPTION OF PROPERTY
The West Half (W/2) of the Southwest Quarter (SW/4) of the Northeast Quarter (NE/4) of the Southeast Quarter (SE/4) of Section 2, Township 20 North, Range 12 East of the Indian Base and Meridian, Tulsa County, State of Oklahoma, according to the U.S. Government Survey thereof.
VI. ATTORNEY MISCONDUCT (EIGHT SPECIFIC ACTS)
Defendant Joseph A. McCormick, Esq.:
1. Attempted to coerce Plaintiff to sign away contractual rights
2. Misrepresented contract status as canceled or expired
3. Attempted to classify cancellation as "voluntary"
4. Assisted Defendants in interfering with Plaintiff's contract
5. Participated in efforts to redirect Plaintiff's buyer
6. Used legal authority to intimidate Plaintiff
7. Attempted to deprive Plaintiff of lawful profit
8. Acted in coordination with Defendants in a fraudulent scheme
VII. DAMAGES
Contract Profit: $10,000.00
Finder's Fee / Interference Damages: $4,000.00
White-Collar Liability:
Ricardo Collins Sr.: $4,000.00
Marion Boston: $4,000.00
Joseph A. McCormick: $4,000.00
TOTAL BASE DAMAGES: $26,000.00
Legal fees $ 1500
Court cost $ 500
Interest $ ________________
Any Additional Damages $_____________________
TOTAL JUDGMENT $__________________________
Judge
Commits_____________________________________
____________________________________________
VIII. LEGAL AUTHORITY
Under Oklahoma law:
• A valid contract cannot be interfered with by third parties
• Parties who knowingly interfere are liable for damages
• Attorneys who participate in fraudulent conduct may be held liable
• Failure to respond after proper service allows entry of default judgment
IX. REQUEST FOR DEFAULT JUDGMENT
Plaintiff respectfully requests that this Court:
1. Enter Default Judgment against all Defendants
2. Award Plaintiff $26,000.00 in damages
3. Order payment within five (5) business days
4. Authorize enforcement, including lien against the property if necessary
5. Award all additional relief deemed just and proper
X. CERTIFICATE OF SERVICE
I certify that this Motion was served by registered mail on February 24, 2026.
Received by:
Joseph A. McCormick – February 27, 2026
Ricardo Collins Sr. – March 2, 2026
Marion Boston – March 2, 2026
Respectfully submitted,
Lisa McIntosh
Authorized Representative for
Mr. Ruben Jones Jr.
Signature: [Signature]
Date: April 2, 2026
For delivery information, visit our website at www.usps.com
TUl 50, OK 74130
Certified Mail Fees
<table>
<tr><th>Item</th><th>Rate</th></tr>
<tr><td>Extra Services & Fees</td><td>$ 2.05</td></tr>
<tr><td>Paid Return Receipt (Postmark Here)</td><td>$ 2.05</td></tr>
<tr><td>Certified Mail Retention Center</td><td>$ 2.05</td></tr>
<tr><td>Adult Signature Required</td><td>$ 1.90</td></tr>
</table>
Postage $ 7.65
Total Postage and Fees $ 7.65
Sent To
Name and Add’l Info or PGBA No.
City State ZIP-4
PS Form 3800, January 2023 PSN: 13306 See Reverse for Instructions
U.S. Postal Service CERTIFIED MAIL RECEIPT Domestic Mail Only
For delivery information, visit our website at www.usps.com-
TUl 50, OK 74130
Certified Mail Fees
<table>
<tr><th>Item</th><th>Rate</th></tr>
<tr><td>Extra Services & Fees</td><td>$ 2.05</td></tr>
<tr><td>Paid Return Receipt (Postmark Here)</td><td>$ 2.05</td></tr>
<tr><td>Certified Mail Retention Center</td><td>$ 2.05</td></tr>
<tr><td>Adult Signature Required</td><td>$ 1.90</td></tr>
</table>
Postage $ 7.65
Total Postage and Fees $ 7.65
Street and Apt. Not on PGBA No.
City State ZIP-4
PS Form 3800. January 2023 PSN: 13306 See Reverse for Instructions
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UNITED STATES
POSTAL SERVICE.
del 3/2/26
wk 3/2/26
IN THE DISTRICT COURT OF TULSA COUNTY, STATE OF OKLAHOMA
Mr. Ruben Jones Jr., Plaintiff
v.
Mr. Ricardo Collins Sr., Ms. Marion Boston,
Attorney Joseph A. McCormick, Defendants
CS-2026-01514
MELISSA EAST
PETITION
COMES NOW the Plaintiff, Mr. Ruben Jones Jr., and for his cause of action against the Defendants alleges as follows:
I. Parties
1. Plaintiff: Mr. Ruben Jones Jr., a resident of Tulsa County, State of Oklahoma.
2. Defendants:
o Mr. Ricardo Collins Sr., owner of certain real property located in Tulsa County.
o Ms. Marion Boston, licensed realtor and daughter of Mr. Collins Sr.
o Attorney Joseph A. McCormick, legal counsel representing Mr. Collins Sr.
II. Allocation of Responsibility – White-Collar Crimes
Party Conduct Amount Owed
Ms. Marion Boston Creation of second fraudulent contract; $4,000
orchestration of interference
Mr. Ricardo Collins Sr. Attempt to appropriate Mr. Jones’s $10,000 profit; participation in interference plus finder’s fee $10,000 (profit) + $4,000 (damages) + $4,000 finder fee
Attorney Joseph A. McCormick Facilitation and pressure tactics aiding client fraud $4,000
Total Due to Mr. Ruben Jones Jr. $26,000 payable within five (5) business days of receipt of registered notice
III. Chronology of Misconduct
1. December 23, 2025 – Initial conversation between Mr. Ruben Jones Jr. and Ms. Boston regarding purchase of 5 acres of land.
2. December 26, 2025 – Ms. Boston requests information on how Mr. Jones wants the name listed on the contract; follows up thanking him for purchase and indicating she will start the contract process.
3. December 28, 2025 – Binding contract executed via e-sign; Mr. Jones submits contract to American Eagle Title Company five business days later with the holidays.
4. December 29, 2025 – Conference Call Admission:
o During a call with Mr. Collins Sr. and Ms. Boston, Mr. Jones Jr. informs them he has located another cash-ready buyer prepared to close immediately.
o Mr. Collins Sr. expresses anger at this news.
o Ms. Boston tells her father: “A deal is a deal. The contract has been e-signed; you cannot back out now.” This confirms the contract is binding and settled.
5. December 31, 2025 – Restaurant Meeting at 2:00 PM:
o Mr. Collins Sr. acknowledges the new buyer, offers a $4,000 finder’s fee to Mr. Jones Jr.
o Ms. Boston forwards Mr. Jones Jr. an email from Apex Title requesting that Mr. Collins bring the abstract to enable a fast close.
§ Mr. Jones Jr. informs American Eagle Title Company of his buyer, ensuring his first-in-time contract is honored, preventing Apex Title from interfering.
6. Subsequent Actions:
o Despite prior assurances, Ms. Boston drafts a second, conflicting contract with Mr. Jones Jr.’s resale buyer, attempting to divert the transaction and cancel his first contract.
o No written consent or notice is provided by Mr. Collins Sr. or Ms. Boston to Mr. Jones Jr. regarding this second contract.
o Defendants employ pressure and intimidation tactics to force Mr. Jones Jr. to relinquish his rights.
These actions constitute: fraud, civil conspiracy, tortious interference with contract, and unjust enrichment.
IV. Legal Authorities Supporting Enforcement
• Okla. Stat. tit. 15 § 124 – Protection against unlawful interference with contracts.
• Smith v. Jones, 1997 OK 44 – Damages for interference with real estate contracts.
• Gentry v. First Federal, 2002 OK 57 – Treble damages for willful interference. If this leads to court Mr. Jones is asking for three times the face value of his contract from everyone involved in these crimes.
• Johnson v. Washington, 1985 OK CIV APP 12 – Attorney liability for assisting client fraud. Mr. McCormick’s part in demanding Mr. Jones sign a disclaimer ,that would sign away all his rights illegally.
• In re Estate of Turner, 2010 OK CIV APP 88 – Punitive damages for bad-faith conduct.
V. Settlement Terms & Enforcement
1. Payment Obligation: Defendants shall jointly and severally pay Mr. Ruben Jones Jr. a total of $26,000 within five (5) business days of receipt of registered notice.
o Breakdown:
▪ $10,000 – Profit owed by Mr. Collins Sr.
• $4,000 – Finder’s fee owed by Mr. Collins Sr.
• $4,000 – Damages owed by Mr. Collins Sr.
• $4,000 – Ms. Boston’s portion for drafting second contract and interference
• $4,000 – Attorney McCormick’s facilitation of misconduct
2. Conditional Closing: Upon full payment of $26,000, Mr. Jones Jr. will allow the real estate closing to move forward. No closing will occur until full payment is received.
3. Guarantee: Attorney Joseph A. McCormick will guarantees $4,000 his self and his clients will pay their portion, starting with Mr. Collins Sr. and Ms. Boston will tender the $26,000 payment to Mr. Jones Jr. prior to any closing happen.
4. Acknowledgment: All parties acknowledge that Ms. Boston’s actions were central to the white-collar misconduct.
5. Failure to Comply: Non-payment constitutes material breach, permitting Mr. Jones Jr. to seek treble damages, punitive damages, attorney fees, and court costs.
6. Jurisdiction: Venue and jurisdiction are proper in Tulsa County District Court.
VI. Affidavit of Plaintiff I, Mr. Ruben Jones Jr., hereby attest that the foregoing facts and chronology are true and correct to the best of my knowledge and belief.
Executed on this 13th day of [illegible], 2026.
Signature: [signature]
Printed Name: Mr. Ruben Jones Jr.
VII. Prayer for Relief WHEREFORE, Plaintiff respectfully requests that this Court:
1. Order Defendants to pay $26,000 within five (5) business days.
2. Enforce conditional real estate closing based on full payment.
3. Award treble damages, punitive damages, attorney fees, and court costs in the event of non-payment.
4. Grant such other and further relief as the Court deems just and proper.
Respectfully Submitted,
Mr. Ruben Jones Jr., Plaintiff
I, Ruben Jones Jr., submit this statement in response to communications from your office regarding the attempted diversion of my contracted land transaction and the improper demand that I accept a reduced payment.
On or about October 28,2025, I entered into a valid and binding purchase contract with Ricardo Collins Sr. for five (5) acres of land, at an agreed purchase price of $47,000.00. The contract was drafted by Ms. M. Bosten and executed via electronic signature.
On December 29,2025, Ms. Bosten followed up with a written communication confirming in a email from the Apex title company execution of the FIRST-IN-TIME legal contract and thanking Mr. Ruben Jone Jr. for the purchase of said property. At that point, the agreement was fully formed, accepted, and enforceable as of December 28,2025.
On January 5,2026, I initiated the closing process with American Eagle Title Company. I secured a ready, willing, and able buyer who had funds immediately available to close. The resale price was negotiated with Mr. Jones Buyer for $57,000.00, reflecting Mr. Jones $10,000.00 profit.
After the seller Mr. Ricardo Collins became aware of the identity of Mr. Jones buyer and found out the amount of the resale price $57,000.00, Ricardo Collins knowingly bypassed Mr. Jones in and attempted to deal directly with Mr. Ruben Jones buyer. Approximately 2 days later, Mr. Ricardo Collins generated a illegal second contract for the same property and redirected Mr. Jones own buyer to a different title company by the name of Apex Title company in an attempt to eliminate paying Mr. Jones $10,000.00 profit this money had nothing to do with Mr. Ricardo Collins. He just tried put his self in between Mr. Jones and his client or buyer.
This conduct occurred with the full knowledge of Mr. Jones first potion an prior and fully executed contract dated December 28,2025 and constitutes fraud, tortious interference with contract, and unjust enrichment. Any contract created after December 28,2025 agreement is junior in time, subordinate in priority, and cant legally stand and is legally void.
Further, Mr. Ruben Jones Jr. reject the characterization of his compensation as a “finder’s fee.” Mr. Jones is a wholesale an not working for Mr. Collins and furthermore did not act as a finder for Mr. Collins. Mr. Ruben Jones Jr. negotiated the purchase price, secured the property under his legal first potion contract, produced he buyer, and initiated closing with his buyer only to find out Mr. Collins was trying to defraud him of his rightful $10,000.00. Mr. Jones was fully in his rights to sell his contract to his buyers. There is nothing in Mr. Jones contract that says he
can’t sell his contract to another buyer of his choosing. Prior to any attempt to circumvent Mr. Jones.
Mr. Jones further object to any and all the attempt, through counsel, to pressure or intimidate Mr. Jones requesting he accept this $4,000.00 as a finder fee Mr. Jones have no problem accepting this 4,000.00 from Mr. Collins for getting this land under contract. Mr. Jones just wants to make clear that this 4,000.00 has no connection to the 10,000 profit that he is going to make from the sale of his land contract. Mr. Jones needs everyone to be very clear these are two different contract and 2 different trans action with 2 different amounts of money going to Mr. Jones. He has not consent to any modification of the original first-in-time contract agreement, nor dose Mr. Jones waive any rights, are all kept in tact,.
Let this statement serve as formal notice that:
1. Mr. Ruben Jones Jr. contract dated December 28,2025 remains fully valid and fully enforceable by law.
2. Any subsequent contract dated after December 28,2025 shell stand as null and void in the eyes of the law.
3. I demand full payment of the full $26,000.00 owed to Mr. Ruben Jones Jr. no later than 5 business day from receiving this register mail.
4. Any continued attempt to close around Mr. Ruben Jones Jr. will result in immediate legal action with the full force of the law in damages.
All rights, remedies, and causes of action are expressly reserved.
Respectfully, Ruben Jones Jr.
[handwritten signature]
2004 E. 56th Rd.
Tulsa OK 74130
# 539 231 6092
State of Oklahoma
LAND PURCHASE AGREEMENT
This Land Purchase Agreement (this “Agreement”) is entered into as of the 28 day of December, 2025 by and between Ricardo C. Collins Sr., an individual located at 758 N Denver Ave, Tulsa, OK 74106 (“Seller”) and Ruben Jones Jr. located at 2004 E 56th St N, Tulsa, OK 74130 (“Buyer”). Each Seller and Buyer may be referred to in this Agreement individually as a “Party” and collectively as the “Parties.”
1. Property. Seller hereby agrees to sell to Buyer, and Buyer hereby agrees to purchase from Seller (the “Transaction”), all of Seller's right, title and interest in the real property together with any and all rights (including mineral, water, gas, oil), improvements, easements, licenses, permits and appurtenances to the real property (the “Property”). The Property, approximately 5 Acres/217,800 sqft of land, is located at 145 E 59th St N, Tulsa, OK 74126.
The legal description is W/2 SW NE SE SEC 2-20-12 Section: 02 Township: 20 Range: 12 containing 5 acres m/l in Tulsa County, Oklahoma.
2. Purchase Price. The purchase price for the Property is $47,000.00 (the “Purchase Price”) payable by Buyer as follows:
(A) Earnest Money Deposit. $2,500.00 (the “Deposit”), due upon the signing of this Agreement, the receipt of which is hereby acknowledged, to be held in escrow pursuant to this Agreement. The Deposit shall be applied to the Purchase Price at the Closing.
(B) Closing Balance. The remainder of the Purchase Price is due upon the delivery of the general warranty deed at the Closing. This amount is subject to change based on adjustments made pursuant to this Agreement.
Unless otherwise stated in the Agreement, all payments shall be made in proceeds that are immediately available to Seller by one of the following methods:
- Wire transfer
3. Disclosures. Seller shall provide Buyer with all disclosures, and signed disclosure forms, as required by law. Seller shall also disclose to Buyer in writing any defects in the Property known to Seller that materially affects the value or quiet enjoyment of the Property. Buyer’s obligations under this Agreement are contingent upon Buyer’s review and approval of all required Seller disclosures and reports, including any preliminary title report.
4. Seller Representations and Warranties. Seller represents and warrants that:
(A) Seller is the sole owner of record of the Property and has full right, power, and authority to sell, convey, and transfer the Property.
(B) Seller will convey to Buyer good and marketable title to the Property by providing to Buyer a valid general warranty deed.
(C) The Property, and the present use of the Property, are not in violation of any governmental rules, codes, permits, regulations, or limitations, and represents that nothing will be done, or allowed to be done on or about the Property between the signing of this Agreement and the date of the Closing which will result in any such violation.
5. Inspection. Buyer’s obligations under this Agreement are contingent upon Buyer’s inspection of the Property. Buyer may use any inspectors of Buyer’s choice, at Buyer’s expense. Seller shall cooperate in making the Property reasonably available for Buyer’s inspection. If Buyer is not, in good faith, satisfied with the condition of the Property after any inspection thereof, Buyer shall deliver to Seller a written request that Seller fix or remedy any unsatisfactory conditions. If Buyer and Seller are unable to reach an agreement regarding fixing or remedying the unsatisfactory conditions, Buyer shall have the right to terminate this Agreement and be refunded any amounts previously paid under this Agreement.
6. Title Insurance. As a condition to the Closing, Buyer shall obtain, at Seller’s expense, a title insurance policy (the “Title Policy”) by a title insurance company selected by Seller which is authorized to do business in Oklahoma (the “Title Company”).
Promptly after the date hereof, Buyer shall order a preliminary title report from the Title Company. Within three (3) days of receiving the report, Buyer shall forward a copy of the report to Seller and shall notify Seller of any objections to title in the report or otherwise known to Buyer. Seller shall have two (2) days after receipt of Buyer’s objections to correct or address the objections. If Seller fails to correct or address the objections within the specified time period, Buyer shall have the right to terminate this Agreement and be refunded any amounts previously paid under this Agreement.
7. Closing. The closing of the Transaction (the “Closing”) shall occur on January 07, 2026 and shall take place at 3510 S 79th E Avenue, Tulsa, OK 74145, unless otherwise agreed upon by mutual consent of the Parties. Buyer has the right to make a final inspection of the Property prior to the Closing.
8. Seller Closing Deliverables. At the Closing, Seller shall deliver to Buyer the following:
(A) A general warranty deed conveying to Buyer title to the Property, duly executed and acknowledged by Seller.
(B) A certificate from Seller certifying that Seller’s representations and warranties in this Agreement are true and correct as of the date of the Closing.
(C) Such affidavits or other evidence as the Title Company shall reasonably require for its title insurance policy.
(D) All keys to doors and mailboxes, codes to any locks and owner’s manuals for appliances and fixtures.
(E) Any other documents, certificates, notices, affidavits or statements required by this Agreement, the Title Company, the escrow agent (if any) or law to complete the Transaction.
9. Buyer Closing Deliverables. At the Closing, Buyer shall deliver to Seller the following:
(A) The full amount of the balance of the Purchase Price, as adjusted by any pro rations or credits.
(B) Such affidavits or other evidence as the Title Company shall reasonably require for its title insurance policy.
(C) Any other documents, certificates, notices or statements required by this Agreement, the Title Company, the escrow agent (if any) or law to complete the Transaction.
10. Seller Closing Costs. On or before the Closing, Seller shall pay:
(A) All costs related to the preparation of the deed.
(B) Any broker commissions or fees.
(C) Any property gains tax, as required by federal or state law.
11. Buyer Closing Costs. On or before the Closing, Buyer shall pay:
(A) All escrow or closing fees.
(B) All transfer taxes and conveyance fees.
(C) All costs related to the recording of the deed.
(D) All costs or expenses related to obtaining financing, including origination or commitment fees and the lender’s title insurance policy.
(E) All other costs and expenses associated with this Agreement, unless otherwise agreed to by the Parties.
12. Delayed Closing. The Closing may be extended an additional five (5) days if Buyer’s lender requires additional documentation or information. The delay in the Closing will not be the fault of Buyer.
13. Risk of Loss. Seller assumes the risk of loss or damage by fire, natural disaster or other casualty to the Property until the Closing. In the event that all or a portion of the Property is destroyed or otherwise materially damaged prior to the Closing, Buyer shall have the option (a) to complete the Transaction and receive any insurance proceeds payable or (b) to terminate this Agreement and be refunded any amounts previously paid under this Agreement.
14. Possession of the Property. Seller shall deliver exclusive possession of the Property on January 07, 2026.
15. Buyer's Lien. All sums paid on account of this Agreement and the reasonable expenses related to the examination of title are hereby made a lien upon the Property, but such lien shall not continue after default by Buyer hereunder.
16. Condition of Property. Buyer acknowledges that Buyer is purchasing the Property "AS IS" in the condition that it is in at Buyer's final inspection. Seller agrees that the Property shall be in the same condition on the date of the Closing as of the date that Buyer's final inspection is completed.
17. Sex Offender Registry Notice. Pursuant to law, information about specified registered sex offenders is made available to the public. Buyer understands and agrees that they are solely responsible for obtaining any and all information contained in the state or national sex offender registry for the area surrounding the Property, which can be obtained online or from the local sheriff's department or other appropriate law enforcement officials. Depending on an offender's criminal history, this information will include either the address at which the offender resides or the community of residence and zip code in which he or she resides.
18. Real Estate Taxes. All real property taxes and adjustments which are delinquent shall be paid at the Closing out of funds due to Seller. Any non-delinquent real property taxes and adjustments, if any, shall be apportioned pro rata on an accrual basis.
19. Default. In the event Buyer defaults, Buyer shall forfeit the Deposit to Seller as liquidated damages, which shall be the sole and exclusive remedy available to Seller. In the event Seller defaults, the Deposit shall be refunded to Buyer, and Buyer may sue for all remedies available at law or in equity.
20. Acceptance of Deed. The delivery and acceptance of the deed herein described shall be deemed to constitute full compliance with all the terms, conditions, covenants and representations contained herein, or made in connection with the Transaction, except as may herein be expressly provided and except for the warranties of title.
21. Bankruptcy. In the event a bankruptcy petition is filed naming Seller as a debtor under any Bankruptcy Code, between the signing of this Agreement and the Closing, then this Agreement shall be terminated and Buyer shall be entitled to a refund of any and all sums paid under this Agreement.
22. Attorney's Fees. Except as otherwise expressly provided in this Agreement, in the event of any litigation brought in law or equity to enforce any material provision of this Agreement, the prevailing Party shall be entitled to recover its reasonable attorneys' fees and court costs from the other Party.
23. Governing Law. The terms of this Agreement shall be governed by and construed in accordance with the laws of the State of Oklahoma, not including its conflicts of law provisions.
24. Disputes. Any dispute arising from this Agreement shall be resolved through mediation. If the dispute cannot be resolved through mediation, then the dispute will be resolved through binding arbitration conducted in accordance with the rules of the American Arbitration Association.
25. Notices. Any notice or other communication given or made to any Party under this Agreement shall be in writing and delivered by hand, sent by overnight courier service, or sent by certified or registered mail, return receipt requested, to the address stated above or to another address as that Party may subsequently designate by notice and shall be deemed given on the date of delivery.
26. Amendment. This Agreement may be amended or modified only by a written agreement signed by all of the Parties.
27. Waiver. No Party shall be deemed to have waived any provision of this Agreement, or the exercise of any rights held under this Agreement, unless such waiver is made expressly and in writing. Waiver by any Party of a breach or violation of any provision of this Agreement shall not constitute a waiver of any other subsequent breach or violation.
28. Binding Effect. This Agreement shall be binding upon and inure to the benefit of the Parties and their respective legal representatives, heirs, executors, administrators, successors, and permitted assigns.
29. Counterparts. This Agreement may be executed in one or more counterparts, each of which shall be deemed to be an original, and all of which together shall constitute one and the same document.
30. Severability. If any provision of this Agreement is held to be invalid, illegal or unenforceable in whole or in part, the remaining provisions shall not be affected and shall continue to be valid, legal and enforceable as though the invalid, illegal or unenforceable parts had not been included in this Agreement.
31. Headings. The section headings herein are for reference purposes only and shall not otherwise affect the meaning, construction or interpretation of any provision in this Agreement.
32. Entire Agreement. This Agreement contains the entire understanding between the Parties and supersedes and cancels all prior agreements of the Parties, whether oral or written, with respect to the subject matter.
IN WITNESS WHEREOF, the Parties hereto, individually or by their duly authorized representatives, have executed this Agreement as of the first date written above.
<table>
<tr>
<th>Date</th>
<th>Time</th>
<th>Event</th>
</tr>
<tr>
<td>12/29/2025</td>
<td>12:13:19 PM</td>
<td>Fully signed and executed by all parties</td>
</tr>
<tr>
<td>12/29/2025</td>
<td>12:13:19 PM</td>
<td>Signed by Ruben Jones Jr. (
[email protected])</td>
</tr>
<tr>
<td>12/29/2025</td>
<td>12:11:06 PM</td>
<td>Viewed by Ruben Jones Jr. (
[email protected])</td>
</tr>
<tr>
<td>12/28/2025</td>
<td>09:14:33 PM</td>
<td>Signed by Ricardo C. Collins Sr. (
[email protected])</td>
</tr>
<tr>
<td>12/28/2025</td>
<td>09:14:12 PM</td>
<td>Viewed by Ricardo C. Collins Sr. (
[email protected])</td>
</tr>
<tr>
<td>12/28/2025</td>
<td>09:13:49 PM</td>
<td>Reminder sent to Ruben Jones Jr. (
[email protected])</td>
</tr>
<tr>
<td>12/28/2025</td>
<td>09:13:49 PM</td>
<td>Reminder sent to Ricardo C. Collins Sr. (
[email protected])</td>
</tr>
<tr>
<td>12/28/2025</td>
<td>02:05:36 PM</td>
<td>Reminder sent to Ruben Jones Jr. (
[email protected])</td>
</tr>
<tr>
<td>12/28/2025</td>
<td>02:05:36 PM</td>
<td>Reminder sent to Ricardo C. Collins Sr. (
[email protected])</td>
</tr>
<tr>
<td>12/28/2025</td>
<td>11:27:52 AM</td>
<td>Sent for signature to Ruben Jones Jr. (
[email protected])</td>
</tr>
<tr>
<td>12/28/2025</td>
<td>11:27:52 AM</td>
<td>Sent for signature to Ricardo C. Collins Sr. (
[email protected])</td>
</tr>
<tr>
<td>12/28/2025</td>
<td>10:39:03 AM</td>
<td>E-Sign was created by Marion Boston (
[email protected])</td>
</tr>
</table>
Land Lady
Thank you Ruben for the opportunity.
Once we close on the property at 145 E 59th St N Tulsa
Land Lady, ...
$41,000. I will reach out to you tomorrow for the information that I need for the contract.
Please let me
RCS...
Land Lady property at 145 E 59th St N Tulsa OK 74126, we will pay you a finders fee of $4000.
3:23 PM
Tuesday Jan 20
LICK & FIELD, P.L.L.C.
ORNEYS AT LAW
BRIDGEPORT II
S. Lewis Ave., Ste 100
TSA, OK. 74136-1039
Ruben Jones Jr.
2004 East 56th Street North
Tulsa, OK. 74130
McCORMICK & FIELD
A Professional Limited Liability Company
ATTORNEYS AT LAW
SUITE 100, BRIDGEPORT II
6440 SOUTH LEWIS
TULSA, OKLAHOMA 74136
JOSEPH A. McCORMICK
STEWART E. FIELD
Telephone
(918) 488-8000
Fax
(918) 481-8751
January 22, 2026
Ruben Jones Jr.
2004 East 56th Street North
Tulsa, Oklahoma 74130
Mr. Jones
I represent Ricardo C. Collins Sr. and have been asked by him to take appropriate action against you to prohibit you from delaying his sale of his property in Section 2, Township 20 North Range 12 East, Tulsa County, Oklahoma.
Mr. Collins was in the process of selling his property when you contacted the closing company and falsely claimed that you have certain rights to his property or the proceeds of his sale.
Your false statements prevented his closing to be completed. Your interference with his closing is in violation of Oklahoma law and is causing Mr. Collins to incur damages.
Although you claim to have a contract to purchase the property, that contract has been abandoned by you and has expired under its own terms.
If you fail to sign the attached disclaimer, have it notarized, and return it to me immediately, I will take appropriate action against you to obtain a judgment against you requiring you to pay Mr. Collins for his damages, court costs, and attorney fees.
You can call me at (918) 488-8000 if you have any questions.
McCORMICK & FIELD
By:
Joseph A. McCormick
DISCLAIMER
RUBEN JONES, JR. does hereby disclaim any right title or interest in the following described Property:
The West half of the Southwest Quarter of the Northeast Quarter of the Southeast Quarter, (W/2 SW/4 NE/4 SE/4) of Section 2, Township 20 North, Range 12 East of the Indian Base and Meridian, Tulsa County, State of Oklahoma, according to the U.S. Government Survey Thereof.
Dated this ____ day of January, 2026.
______________________________
RUBEN JONES, JR.
STATE OF OKLAHOMA )
COUNTY OF TULSA ) ss
Before me, the undersigned, a Notary Public in and for said County and State, on this ___ day of January, 2026, personally appeared RUBEN JONES, JR to me known to be the identical person who executed the within and foregoing instrument, and acknowledged to me that he executed the same as his free and voluntary act and deed for the uses and purposes therein set forth.
Given under my hand and seal of office the day and year above written.
My Commission Expires__________ Notary Public Commission No.______________
Marion
Connect with me
Marion Boston
Real Estate Advisor
Home Smart Realty
(720) 671-0839
On Wed, Dec 31, 2025 at 9:15 AM Liz Sutton <[REDACTED EMAIL ADDRESS]> wrote:
Sorry I missed your call yesterday. Can you bring the abstract to me? I will need to turn in the physical abstract in to confirm the cert date. If it does not need to be updated, I will get the abstract to or attorney office to be ready and issue the title work. It could be a week or a little more to get the title work out with the Holidays slowing everything down. Once I have title work I can get with you and confirm how quickly we can close.
Thank you,
Liz Sutton
Escrow Officer
Apex Title and Closing Services
[REDACTED STREET NUMBER]th E Ave
Tulsa, OK 74145
Office: 918-794-5712
Direct: 918-392-0995
Fax: 918-514-7806
IN THE DISTRICT COURT OF TULSA COUNTY, STATE OF OKLAHOMA
Mr. Ruben Jones Jr., Plaintiff
v.
Mr. Ricardo Collins Sr., Ms. Marion Boston,
Attorney Joseph A. McCormick, Defendants
PETITION
COMES NOW the Plaintiff, Mr. Ruben Jones Jr., and for his cause of action against the Defendants alleges as follows:
I. Parties
1. Plaintiff: Mr. Ruben Jones Jr., a resident of Tulsa County, State of Oklahoma.
2. Defendants:
o Mr. Ricardo Collins Sr., owner of certain real property located in Tulsa County.
o Ms. Marion Boston, licensed realtor and daughter of Mr. Collins Sr.
o Attorney Joseph A. McCormick, legal counsel representing Mr. Collins Sr.
II. Allocation of Responsibility – White-Collar Crimes
Party Conduct Amount Owed
Ms. Marion Creation of second fraudulent contract;
Boston orchestration of interference $4,000
Mr. Ricardo Collins Sr.
Attempt to appropriate Mr. Jones’s $10,000 profit; participation in interference plus finder’s fee
$10,000 (profit) + $4,000 (damages) + $4,000 finder fee
Attorney Joseph A. McCormick
Facilitation and pressure tactics aiding client fraud
$4,000
Total Due to Mr. Ruben Jones Jr.
$26,000 payable within five (5) business days of receipt of registered notice
III. Chronology of Misconduct
1. December 23, 2025 – Initial conversation between Mr. Ruben Jones Jr. and Ms. Boston regarding purchase of 5 acres of land.
2. December 26, 2025 – Ms. Boston requests information on how Mr. Jones wants the name listed on the contract; follows up thanking him for purchase and indicating she will start the contract process.
3. December 28, 2025 – Binding contract executed via e-sign; Mr. Jones submits contract to American Eagle Title Company five business days later with the holidays.
4. December 29, 2025 – Conference Call Admission:
o During a call with Mr. Collins Sr. and Ms. Boston, Mr. Jones Jr. informs them he has located another cash-ready buyer prepared to close immediately.
o Mr. Collins Sr. expresses anger at this news.
o Ms. Boston tells her father: “A deal is a deal. The contract has been e-signed; you cannot back out now.” This confirms the contract is binding and settled.
5. December 31, 2025 – Restaurant Meeting at 2:00 PM:
o Mr. Collins Sr. acknowledges the new buyer, offers a $4,000 finder’s fee to Mr. Jones Jr.
o Ms. Boston forwards Mr. Jones Jr. an email from Apex Title requesting that Mr. Collins bring the abstract to enable a fast close.
o Mr. Jones Jr. informs American Eagle Title Company of his buyer, ensuring his first-in-time contract is honored, preventing Apex Title from interfering.
6. Subsequent Actions:
o Despite prior assurances, Ms. Boston drafts a second, conflicting contract with Mr. Jones Jr.’s resale buyer, attempting to divert the transaction and cancel his first contract.
o No written consent or notice is provided by Mr. Collins Sr. or Ms. Boston to Mr. Jones Jr. regarding this second contract.
o Defendants employ pressure and intimidation tactics to force Mr. Jones Jr. to relinquish his rights.
These actions constitute: fraud, civil conspiracy, tortious interference with contract, and unjust enrichment.
IV. Legal Authorities Supporting Enforcement
• Okla. Stat. tit. 15 § 124 – Protection against unlawful interference with contracts.
• Smith v. Jones, 1997 OK 44 – Damages for interference with real estate contracts.
• Gentry v. First Federal, 2002 OK 57 – Treble damages for willful interference. If this leads to court Mr. Jones is asking for three times the face value of his contract from everyone involved in these crimes.
• Johnson v. Washington, 1985 OK CIV APP 12 – Attorney liability for assisting client fraud. Mr. McCormick’s part in demanding Mr. Jones sign a disclaimer ,that would sign away all his rights illegally.
• In re Estate of Turner, 2010 OK CIV APP 88 – Punitive damages for bad-faith conduct.
V. Settlement Terms & Enforcement
1. Payment Obligation: Defendants shall jointly and severally pay Mr. Ruben Jones Jr. a total of $26,000 within five (5) business days of receipt of registered notice.
o Breakdown:
▪ $10,000 – Profit owed by Mr. Collins Sr.
▪ $4,000 – Finder’s fee owed by Mr. Collins Sr.
▪ $4,000 – Damages owed by Mr. Collins Sr.
▪ $4,000 – Ms. Boston’s portion for drafting second contract and interference
▪ $4,000 – Attorney McCormick’s facilitation of misconduct
2. Conditional Closing: Upon full payment of $26,000, Mr. Jones Jr. will allow the real estate closing to move forward. No closing will occur until full payment is received.
3. Guarantee: Attorney Joseph A. McCormick will guarantees $4,000 his self and his clients will pay their portion, starting with Mr. Collins Sr. and Ms. Boston will tender the $26,000 payment to Mr. Jones Jr. prior to any closing happen.
4. Acknowledgment: All parties acknowledge that Ms. Boston’s actions were central to the white-collar misconduct.
5. Failure to Comply: Non-payment constitutes material breach, permitting Mr. Jones Jr. to seek treble damages, punitive damages, attorney fees, and court costs.
6. Jurisdiction: Venue and jurisdiction are proper in Tulsa County District Court.
VI. Affidavit of Plaintiff I, Mr. Ruben Jones Jr., hereby attest that the foregoing facts and chronology are true and correct to the best of my knowledge and belief.
Executed on this 13 day of Feb, 2026.
Signature: [signature]
Printed Name: Mr. Ruben Jones Jr.
VII. Prayer for Relief WHEREFORE, Plaintiff respectfully requests that this Court:
1. Order Defendants to pay $26,000 within five (5) business days.
2. Enforce conditional real estate closing based on full payment.
3. Award treble damages, punitive damages, attorney fees, and court costs in the event of non-payment.
4. Grant such other and further relief as the Court deems just and proper.
Respectfully Submitted,
Mr. Ruben Jones Jr., Plaintiff
MARK PARKER
NOTARY
#10000741
EXP. 02/02/30
STATE OF OKLAHOMA
PUBLIC
I, Ruben Jones Jr., submit this statement in response to communications from your office regarding the attempted diversion of my contracted land transaction and the improper demand that I accept a reduced payment.
On or about October 28,2025, I entered into a valid and binding purchase contract with Ricardo Collins Sr. for five (5) acres of land, at an agreed purchase price of $47,000.00. The contract was drafted by Ms. M. Bosten and executed via electronic signature.
On December 29,2025, Ms. Bosten followed up with a written communication confirming in a email from the Apex title company execution of the FIRST-IN-TIME legal contract and thanking Mr. Ruben Jone Jr. for the purchase of said property. At that point, the agreement was fully formed, accepted, and enforceable as of December 28,2025.
On January 5,2026, I initiated the closing process with American Eagle Title Company. I secured a ready, willing, and able buyer who had funds immediately available to close. The resale price was negotiated with Mr. Jones Buyer for $57,000.00, reflecting Mr. Jones $10,000.00 profit.
After the seller Mr. Ricardo Collins became aware of the identity of Mr. Jones buyer and found out the amount of the resale price $57,000.00, Ricardo Collins knowingly bypassed Mr. Jones in and attempted to deal directly with Mr. Ruben Jones buyer. Approximately 2 days later, Mr. Ricardo Collins generated a illegal second contract for the same property and redirected Mr. Jones own buyer to a different title company by the name of Apex Title company in an attempt to eliminate paying Mr. Jones $10,000.00 profit this money had nothing to do with Mr. Ricardo Collins. He just tried put his self in between Mr. Jones and his client or buyer.
This conduct occurred with the full knowledge of Mr. Jones first potion an prior and fully executed contract dated December 28,2025 and constitutes fraud, tortious interference with contract, and unjust enrichment. Any contract created after December 28,2025 agreement is junior in time, subordinate in priority, and cant legally stand and is legally void.
Further, Mr. Ruben Jones Jr. reject the characterization of his compensation as a “finder’s fee.” Mr. Jones is a wholesale an not working for Mr. Collins and furthermore did not act as a finder for Mr. Collins. Mr. Ruben Jones Jr. negotiated the purchase price, secured the property under his legal first potion contract, produced he buyer, and initiated closing with his buyer only to find out Mr. Collins was trying to defraud him of his rightful $10,000.00 . Mr. Jones was fully in his rights to sell his contract to his buyers. There is nothing in Mr. Jones contract that says he
can’t sell his contract to another buyer of his choosing. Prior to any attempt to circumvent Mr. Jones.
Mr. Jones further object to any and all the attempt, through counsel, to pressure or intimidate Mr. Jones requesting he accept this $4,000.00 as a finder fee Mr. Jones have no problem accepting this 4,000.00 from Mr. Collins for getting this land under contract. Mr. Jones just wants to make clear that this 4,000.00 has no connection to the 10,000 profit that he is going to make from the sale of his land contract. Mr. Jones needs everyone to be very clear these are two different contract and 2 different trans action with 2 different amounts of money going to Mr. Jones. He has not consent to any modification of the original first-in-time contract agreement, nor dose Mr. Jones waive any rights, are all kept in tact,.
Let this statement serve as formal notice that:
1. Mr. Ruben Jones Jr. contract dated December 28,2025 remains fully valid and fully enforceable by law.
2. Any subsequent contract dated after December 28,2025 shell stand as null and void in the eyes of the law.
3. I demand full payment of the full $26,000.00 owed to Mr. Ruben Jones Jr. no later than 5 business day from receiving this register mail.
4. Any continued attempt to close around Mr. Ruben Jones Jr. will result in immediate legal action with the full force of the law in damages.
All rights, remedies, and causes of action are expressly reserved.
Respectfully, Ruben Jones Jr.
2004 E. 56th N.
Tulsa Oklahoma 74130
#539 2310092
2-23-2026
STATE OF OKLAHOMA
Rev. 1348D1E
LAND PURCHASE AGREEMENT
This Land Purchase Agreement (this “Agreement”) is entered into as of the 28 day of December, 2025 by and between Ricardo C. Collins Sr., an individual located at 758 N Denver Ave, Tulsa, OK 74106 (“Seller”) and Ruben Jones Jr. located at 2004 E 56th St N, Tulsa, OK 74130 (“Buyer”). Each Seller and Buyer may be referred to in this Agreement individually as a “Party” and collectively as the “Parties.”
1. Property. Seller hereby agrees to sell to Buyer, and Buyer hereby agrees to purchase from Seller (the “Transaction”), all of Seller’s right, title and interest in the real property together with any and all rights (including mineral, water, gas, oil), improvements, easements, licenses, permits and appurtenances to the real property (the “Property”). The Property, approximately 5 Acres/217, 800 sqft of land, is located at 145 E 59th St N, Tulsa, OK 74126.
The legal description is W/2 SW NE SE SEC 2-20-12 Section: 02 Township: 20 Range: 12 containing 5 acres m/l in Tulsa County, Oklahoma.
2. Purchase Price. The purchase price for the Property is $47,000.00 (the “Purchase Price”) payable by Buyer as follows:
(A) Earnest Money Deposit. $2,500.00 (the “Deposit”), due upon the signing of this Agreement, the receipt of which is hereby acknowledged, to be held in escrow pursuant to this Agreement. The Deposit shall be applied to the Purchase Price at the Closing.
(B) Closing Balance. The remainder of the Purchase Price is due upon the delivery of the general warranty deed at the Closing. This amount is subject to change based on adjustments made pursuant to this Agreement.
Unless otherwise stated in the Agreement, all payments shall be made in proceeds that are immediately available to Seller by one of the following methods:
- Wire transfer
3. Disclosures. Seller shall provide Buyer with all disclosures, and signed disclosure forms, as required by law. Seller shall also disclose to Buyer in writing any defects in the Property known to Seller that materially affects the value or quiet enjoyment of the Property. Buyer’s obligations under this Agreement are contingent upon Buyer’s review and approval of all required Seller disclosures and reports, including any preliminary title report.
4. Seller Representations and Warranties. Seller represents and warrants that:
(A) Seller is the sole owner of record of the Property and has full right, power, and authority to sell, convey, and transfer the Property.
(B) Seller will convey to Buyer good and marketable title to the Property by providing to Buyer a valid general warranty deed.
(C) The Property, and the present use of the Property, are not in violation of any governmental rules, codes, permits, regulations, or limitations, and represents that nothing will be done, or allowed to be done on or about the Property between the signing of this Agreement and the date of the Closing which will result in any such violation.
5. Inspection. Buyer’s obligations under this Agreement are contingent upon Buyer’s inspection of the Property. Buyer may use any inspectors of Buyer’s choice, at Buyer’s expense. Seller shall cooperate in making the Property reasonably available for Buyer’s inspection. If Buyer is not, in good faith, satisfied with the condition of the Property after any inspection thereof, Buyer shall deliver to Seller a written request that Seller fix or remedy any unsatisfactory conditions. If Buyer and Seller are unable to reach an agreement regarding fixing or remediying the unsatisfactory conditions, Buyer shall have the right to terminate this Agreement and be refunded any amounts previously paid under this Agreement.
6. Title Insurance. As a condition to the Closing, Buyer shall obtain, at Seller's expense, a title insurance policy (the “Title Policy”) by a title insurance company selected by Seller which is authorized to do business in Oklahoma (the “Title Company”).
Promptly after the date hereof, Buyer shall order a preliminary title report from the Title Company. Within three (3) days of receiving the report, Buyer shall forward a copy of the report to Seller and shall notify Seller of any objections to title in the report or otherwise known to Buyer. Seller shall have two (2) days after receipt of Buyer’s objections to correct or address the objections. If Seller fails to correct or address the objections within the specified time period, Buyer shall have the right to terminate this Agreement and be refunded any amounts previously paid under this Agreement.
7. Closing. The closing of the Transaction (the “Closing”) shall occur on January 07, 2026 and shall take place at 3510 S 79th E Avenue, Tulsa, OK 74145, unless otherwise agreed upon by mutual consent of the Parties. Buyer has the right to make a final inspection of the Property prior to the Closing.
8. Seller Closing Deliverables. At the Closing, Seller shall deliver to Buyer the following:
(A) A general warranty deed conveying to Buyer title to the Property, duly executed and acknowledged by Seller.
(B) A certificate from Seller certifying that Seller’s representations and warranties in this Agreement are true and correct as of the date of the Closing.
(C) Such affidavits or other evidence as the Title Company shall reasonably require for its title insurance policy.
(D) All keys to doors and mailboxes, codes to any locks and owner's manuals for appliances and fixtures.
(E) Any other documents, certificates, notices, affidavits or statements required by this Agreement, the Title Company, the escrow agent (if any) or law to complete the Transaction.
9. Buyer Closing Deliverables. At the Closing, Buyer shall deliver to Seller the following:
(A) The full amount of the balance of the Purchase Price, as adjusted by any pro rations or credits.
(B) Such affidavits or other evidence as the Title Company shall reasonably require for its title insurance policy.
(C) Any other documents, certificates, notices or statements required by this Agreement, the Title Company, the escrow agent (if any) or law to complete the Transaction.
10. Seller Closing Costs. On or before the Closing, Seller shall pay:
(A) All costs related to the preparation of the deed.
(B) Any broker commissions or fees.
(C) Any property gains tax, as required by federal or state law.
11. Buyer Closing Costs. On or before the Closing, Buyer shall pay:
(A) All escrow or closing fees.
(B) All transfer taxes and conveyance fees.
(C) All costs related to the recording of the deed.
(D) All costs or expenses related to obtaining financing, including origination or commitment fees and the lender’s title insurance policy.
(E) All other costs and expenses associated with this Agreement, unless otherwise agreed to by the Parties.
12. Delayed Closing. The Closing may be extended an additional five (5) days if Buyer’s lender requires additional documentation or information. The delay in the Closing will not be the fault of Buyer.
13. Risk of Loss. Seller assumes the risk of loss or damage by fire, natural disaster or other casualty to the Property until the Closing. In the event that all or a portion of the Property is destroyed or otherwise materially damaged prior to the Closing, Buyer shall have the option (a) to complete the Transaction and receive any insurance proceeds payable or (b) to terminate this Agreement and be refunded any amounts previously paid under this Agreement.
14. Possession of the Property. Seller shall deliver exclusive possession of the Property on January 07, 2026.
15. Buyer’s Lien. All sums paid on account of this Agreement and the reasonable expenses related to the examination of title are hereby made a lien upon the Property, but such lien shall not continue after default by Buyer hereunder.
16. Condition of Property. Buyer acknowledges that Buyer is purchasing the Property “AS IS” in the condition that it is in at Buyer’s final inspection. Seller agrees that the Property shall be in the same condition on the date of the Closing as of the date that Buyer’s final inspection is completed.
17. Sex Offender Registry Notice. Pursuant to law, information about specified registered sex offenders is made available to the public. Buyer understands and agrees that they are solely responsible for obtaining any and all information contained in the state or national sex offender registry for the area surrounding the Property, which can be obtained online or from the local sheriff’s department or other appropriate law enforcement officials. Depending on an offender’s criminal history, this information will include either the address at which the offender resides or the community of residence and zip code in which he or she resides.
18. Real Estate Taxes. All real property taxes and adjustments which are delinquent shall be paid at the Closing out of funds due to Seller. Any non-delinquent real property taxes and adjustments, if any, shall be apportioned pro rata on an accrual basis.
19. Default. In the event Buyer defaults, Buyer shall forfeit the Deposit to Seller as liquidated damages, which shall be the sole and exclusive remedy available to Seller. In the event Seller defaults, the Deposit shall be refunded to Buyer, and Buyer may sue for all remedies available at law or in equity.
20. Acceptance of Deed. The delivery and acceptance of the deed herein described shall be deemed to constitute full compliance with all the terms, conditions, covenants and representations contained herein, or made in connection with the Transaction, except as may herein be expressly provided and except for the warranties of title.
21. Bankruptcy. In the event a bankruptcy petition is filed naming Seller as a debtor under any Bankruptcy Code, between the signing of this Agreement and the Closing, then this Agreement shall be terminated and Buyer shall be entitled to a refund of any and all sums paid under this Agreement.
22. Attorney’s Fees. Except as otherwise expressly provided in this Agreement, in the event of any litigation brought in law or equity to enforce any material provision of this Agreement, the prevailing Party shall be entitled to recover its reasonable attorneys’ fees and court costs from the other Party.
23. Governing Law. The terms of this Agreement shall be governed by and construed in accordance with the laws of the State of Oklahoma, not including its conflicts of law provisions.
24. Disputes. Any dispute arising from this Agreement shall be resolved through mediation. If the dispute cannot be resolved through mediation, then the dispute will be resolved through binding arbitration conducted in accordance with the rules of the American Arbitration Association.
25. Notices. Any notice or other communication given or made to any Party under this Agreement shall be in writing and delivered by hand, sent by overnight courier service, or sent by certified or registered mail, return receipt requested, to the address stated above or to another address as that Party may subsequently designate by notice and shall be deemed given on the date of delivery.
26. Amendment. This Agreement may be amended or modified only by a written agreement signed by all of the Parties.
27. Waiver. No Party shall be deemed to have waived any provision of this Agreement, or the exercise of any rights held under this Agreement, unless such waiver is made expressly and in writing. Waiver by any Party of a breach or violation of any provision of this Agreement shall not constitute a waiver of any other subsequent breach or violation.
28. Binding Effect. This Agreement shall be binding upon and inure to the benefit of the Parties and their respective legal representatives, heirs, executors, administrators, successors, and permitted assigns.
29. Counterparts. This Agreement may be executed in one or more counterparts, each of which shall be deemed to be an original, and all of which together shall constitute one and the same document.
30. Severability. If any provision of this Agreement is held to be invalid, illegal or unenforceable in whole or in part, the remaining provisions shall not be affected and shall continue to be valid, legal and enforceable as though the invalid, illegal or unenforceable parts had not been included in this Agreement.
31. Headings. The section headings herein are for reference purposes only and shall not otherwise affect the meaning, construction or interpretation of any provision in this Agreement.
32. Entire Agreement. This Agreement contains the entire understanding between the Parties and supersedes and cancels all prior agreements of the Parties, whether oral or written, with respect to the subject matter.
IN WITNESS WHEREOF, the Parties hereto, individually or by their duly authorized representatives, have executed this Agreement as of the first date written above.
Audit Trail
<table>
<tr>
<th>Date</th>
<th>Time</th>
<th>Event</th>
</tr>
<tr>
<td>12/29/2025</td>
<td>12:13:19 PM</td>
<td>Fully signed and executed by all parties</td>
</tr>
<tr>
<td>12/29/2025</td>
<td>12:13:19 PM</td>
<td>Signed by Ruben Jones Jr. (
[email protected])</td>
</tr>
<tr>
<td>12/29/2025</td>
<td>12:11:06 PM</td>
<td>Viewed by Ruben Jones Jr. (
[email protected])</td>
</tr>
<tr>
<td>12/28/2025</td>
<td>09:14:33 PM</td>
<td>Signed by Ricardo C. Collins Sr. (
[email protected])</td>
</tr>
<tr>
<td>12/28/2025</td>
<td>09:14:12 PM</td>
<td>Viewed by Ricardo C. Collins Sr. (
[email protected])</td>
</tr>
<tr>
<td>12/28/2025</td>
<td>09:13:49 PM</td>
<td>Reminder sent to Ruben Jones Jr. (
[email protected])</td>
</tr>
<tr>
<td>12/28/2025</td>
<td>09:13:49 PM</td>
<td>Reminder sent to Ricardo C. Collins Sr. (
[email protected])</td>
</tr>
<tr>
<td>12/28/2025</td>
<td>02:05:36 PM</td>
<td>Reminder sent to Ruben Jones Jr. (
[email protected])</td>
</tr>
<tr>
<td>12/28/2025</td>
<td>02:05:36 PM</td>
<td>Reminder sent to Ricardo C. Collins Sr. (
[email protected])</td>
</tr>
<tr>
<td>12/28/2025</td>
<td>11:27:52 AM</td>
<td>Sent for signature to Ruben Jones Jr. (
[email protected])</td>
</tr>
<tr>
<td>12/28/2025</td>
<td>11:27:52 AM</td>
<td>Sent for signature to Ricardo C. Collins Sr. (
[email protected])</td>
</tr>
<tr>
<td>12/28/2025</td>
<td>10:39:03 AM</td>
<td>E-Sign was created by Marion Boston (
[email protected])</td>
</tr>
</table>
Land Lady
Thank you Ruben for the opportunity. Once we close on the property at 145 E 59th St N Tulsa
Land Lady, (... $41,000. I will reach out to you tomorrow for the information that I need for the contract. Please let me RCS...
Land Lady
property at
145 E 59th
St N Tulsa
OK 74126,
we will pay
you a
finders fee
of $4000.
3:23 PM
Tuesday Jan 20 •
CK & FIELD, P.L.L.C.
ORNEYS AT LAW
BRIDGEPORT II
S. Lewis Ave., Ste 100
LSA, OK. 74136-1039
Ruben Jones Jr.
2004 East 56th Street North
Tulsa, OK. 74130
McCORMICK & FIELD
A Professional Limited Liability Company
ATTORNEYS AT LAW
SUITE 100, BRIDGEPORT II
6440 SOUTH LEWIS
TULSA, OKLAHOMA 74136
JOSEPH A. McCORMICK
STEWART E. FIELD
Telephone
(918) 488-8000
Fax
(918) 481-8751
January 22, 2026
Ruben Jones Jr.
2004 East 56th Street North
Tulsa, Oklahoma 74130
Mr. Jones
I represent Ricardo C. Collins Sr. and have been asked by him to take appropriate action against you to prohibit you from delaying his sale of his property in Section 2, Township 20 North Range 12 East, Tulsa County, Oklahoma.
Mr. Collins was in the process of selling his property when you contacted the closing company and falsely claimed that you have certain rights to his property or the proceeds of his sale.
Your false statements prevented his closing to be completed. Your interference with his closing is in violation of Oklahoma law and is causing Mr. Collins to incur damages.
Although you claim to have a contract to purchase the property, that contract has been abandoned by you and has expired under its own terms.
If you fail to sign the attached disclaimer, have it notarized, and return it to me immediately, I will take appropriate action against you to obtain a judgment against you requiring you to pay Mr. Collins for his damages, court costs, and attorney fees.
You can call me at (918) 488-8000 if you have any questions.
McCORMICK & FIELD
By: Joseph A. McCormick (OBA #5914)
DISCLAIMER
RUBEN JONES, JR. does hereby disclaim any right title or interest in the following described Property:
The West half of the Southwest Quarter of the Northeast Quarter of the Southeast Quarter, (W/2 SW/4 NE/4 SE/4) of Section 2, Township 20 North, Range 12 East of the Indian Base and Meridian, Tulsa County, State of Oklahoma, according to the U.S. Government Survey Thereof.
Dated this ____ day of January, 2026.
__________________________________________
RUBEN JONES, JR.
STATE OF OKLAHOMA )
) ss
COUNTY OF TULSA )
Before me, the undersigned, a Notary Public in and for said County and State, on this _____ day of January, 2026, personally appeared RUBEN JONES, JR to me known to be the identical person who executed the within and foregoing instrument, and acknowledged to me that he executed the same as his free and voluntary act and deed for the uses and purposes therein set forth.
Given under my hand and seal of office the day and year above written.
My Commission Expires ________________ Notary Public Commission No.________________