Preview
AI s RM BER:
Client! MARK .L. HOOSE County: Oklahoma imber: CS~
CABINET OUTLETLING - Plaintiff(s)
ys FLED IN DISTRICT COURT
OXLAHOMA COUNTY
CHAD BLACK ETAL - Defendant(s)
JAN ~ 8 2018
Date Served: 1/8/2018 12:25:00 PM RICK WARREN
Served By. JOHN SHADID (PSS-2014-83 COURT CLERK
48
County of Origin: Oklahoma Proof of Service Case Number: CS-2018-61
DOCUMENTS SERVED: I, being duly METHOD OF SERVICE:
sworn, certify that | received the
forgoing, to wit:
*Summons with Petition
And served the same according to the law in the following manner]
to wit:
Personal Service
by delivering a true copy of said process
*Exhibits personally to CHAD BLACK at 1800 NE
135TH, OKLA CITY, OK 73131-0000. Date
and Time: 1/8/2018 12:25:00 PM
Other Information:
282920
Subscribed and sworn Jasieafgre me this Undersigned declares under penalty of perjury
(oe os My re 03: that the foregoing is true and correct.
: YAN UG!
2: eS). JAN 08 2017
Notary Public ‘
(SEAL) (date)IN THE DISTRICT COURT OF OKLAHOMA COUNTY
STATE OF OKLAHOMA
CABINET OUTLET, INC., )
an Oklahoma corporation, )
)
Plaintiff, )
) Case No. CS-2018-
v. )
)
MIDAS INVESTMENTS, LLC, an Oklahoma, )
limited liability company, and CHAD BLACK, )
an individual, | )
) )
Defendant(s). )
SUMMONS
To the above-named Defendant: CHAD BLACK
1% iP #OENE 135”
Oklahoma City, OK 73131
Or Wherever Found.
You have been sued by the above-named Plaintiff and you are directed to file a written
answer to the attached Petition of said Plaintiffin the Court at the address listed below within Thirty-
five (35) days after service of this Summons upon you, exclusive of the day of service. A copy of
your answer must be delivered or mailed to the Attorney for the Plaintiff. Unless you answer the
Petition within the time stated, judgment will be rendered against you with costs of the action.
bh «
ISSUED: Y Aww GO| y RICK WARREN, COURT CLERK
U0 DISTRICT COURT OF OKLAHOMA COUNTY
Oklahoma County Courthouse
320 Robert S. Kerr
Oklahoma City, OK 73120
Aub Gels
Deputy Court Clerk Sg
[SEAL]Summons
Page 2
Approved:
MARK L. HOOSE, P.C.
Mark L. Hoose, OBA# 14083
17 East First Street
Post Office Box 753
Edmond, Oklahoma 73083-0753
Tel: (405) 340-6401
Fax: (405) 348-5040
hooselawoffice@gmail.com
_ _—
This Summons was served on G ( S and you must answer the Petition
(Date of Service)
within Thirty-five (35) days after this date.
y (Sighature of Person Serving Summons)
YOU MAY SEEK THE ADVICE OF AN ATTORNEY ON ANY MATTER CONNECTED
WITH THIS SUIT OR YOUR ANSWER. SUCH ATTORNEY SHOULD BE CONSULTED
IMMEDIATELY SO THAT AN ANSWER MAY BE FILED WITHIN THE TIME LIMIT
STATED IN THE SUMMONS.
\\SVRHOOSEI\Docs\CLIENT Holbrock, DaniMidas&eBlack\Summons-Chad.wpd
JAN 08 7919FILED IN DISTRICT COURT
OKLAHOMA COUNTY
IN THE DISTRICT COURT OF OKLAHOMA COUNTY | jay - 4 2018
STATE OF OKLAHOMA
RICK WARREN
CABINET OUTLET, INC., 95 COURT CLERK
an Oklahoma corporation,
Plaintiff,
Case No. CS-2018-
Lavy JJd76h ag
Vv.
MIDAS INVESTMENTS, LLC, an Oklahoma,
limited liability company, and CHAD BLACK,
an individual,
weer we
Defendant(s).
PETITION
Plaintiff, Cabinet Outlet, Inc., for its cause of action against the Defendants, Midas
Investments, LLC, and Chad Black, alleges and states as follows:
Jurisdiction and Venue
1. Plaintiff, Cabinet Outlet, Inc. is an Oklahoma corporation doing business in the State
of Oklahoma.
2. Defendant, Midas Investments, LLC, is an Oklahoma limited liability company doing
business in the State of Oklahoma.
3. Defendant, Chad Black, is an individual residing in Oklahoma County, State of
Oklahoma.
4. This court has jurisdiction over the Defendants and venue is proper in this court.
Cause of Action
5. Plaintiff entered into an agreement with Defendants to provide materials at the request
of and for the benefit of Defendants pursuant to an Open Account Agreement attached hereto as
Exhibit “A”.6. Plaintiff provided the materials and has otherwise fulfilled all contractual obligations
to Defendants. Plaintiff was owed $2,525.76 for the materials provided to Defendants from June 13,
2017 through June 30, 2017, pursuant to the agreement referenced in paragraph 5 herein above. A
copy of the invoices for the materials provided are attached hereto as Exhibit “B”.
7. There remains due and owing to Plaintiff $2,525.76, plus interest at a rate of 1.5%
per month pursuant to 15 O.S. § 275, from and after June 30, 2017, for materials provided to
Defendants, pursuant to the agreement referenced in paragraph 4 herein above.
8. That Defendant, Chad Black, executed a personal guarantee as part of the Open
Account Agreement referenced in paragraph 5 herein above.
9. Defendants have not paid Plaintiff and are in default of the agreement referenced in
paragraph 4 herein above. Said default is continuing.
10. The amount owed to Plaintiff pursuant to the above referenced agreement is
$2,525.76, plus interest at 1.5% per month from and after June 30, 2017, pursuant to Okla. stat. Tit.
15, § 275. Plaintiff is also entitled to recover a reasonable attorney fee pursuant to Okla. Stat. tit.
12, § 936. Plaintiff seeks a reasonable attorney fee to be determined by the court at time judgment
is entered (but a sum of not less than $1,500.00). Plaintiff is also entitled to costs against Defendants
pursuant to Okla. Stat. tit. 12, § 928.
Prayer for Relief
WHEREFORE, for its causes of action against the Defendants, Midas Investments, LLC,
and Chad Black, Plaintiff asks that:
Plaintiff be granted an in personam money judgment against Defendants in the amount of
$2,525.76, plus interest at 1.5% per month from and after June 30, 2017, through date of judgment;
Plaintiff be granted an in personam money judgment against Defendants for a reasonable attorney’sfee to be set and determined by the court at time of judgment (but a sum of not less than $1,500.00);
Plaintiff be awarded judgment against Defendants for costs, including all post judgment costs;
Plaintiff’ s in personam money judgment against Defendants shall state that it accrues post judgment
interest at the rates prescribed to Okla. Stat. tit. 12 § 727.1; and Plaintiff be granted such other relief
as the court deems just.
MARK L. HOOSE, P.C.
loose, OBA# 14083
Law
17 East First Street
Post Office Box 753
Edmond, Oklahoma 73083-0753
Tel: (405) 340-6401
Fax: (405) 348-5040
Hooselawoffice@gmail.com
Attorney for Plaintiff
FDCPA NOTICE
UNLESS YOU NOTIFY THIS OFFICE, WITHIN THIRTY (30) DAYS AFTER RECEIVING
THIS NOTICE, THAT YOU DISPUTE THE VALIDITY OF THE DEBT, OR ANY
PORTION THEREOF, THIS OFFICE WILL ASSUME THIS DEBT TO BE VALID. IF
YOU NOTIFY THE ATTORNEY FOR THE PLAINTIFF IN WRITING WITHIN THE
THIRTY (30) DAY PERIOD OF ANY DISPUTE, VERIFICATION OF THE DEBT WILL
BE OBTAINED, AND A COPY OF SUCH VERIFICATION WILL BE FURNISHED TO
YOU BY THE ATTORNEY FOR PLAINTIFF, INCLUDING THE NAME AND ADDRESS
OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM THE CURRENT CREDITOR.
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE.
\\SVRHOOSE I\Docs\CLIENT \Holbrock,Dan\MidasdeBlack Petition wpdOO PM I nt
MAN/2:/2015/021 00 t oan memanagene canner FAX No, 4054716347 P. 00:
405-719-4297
FAX 405-789.3468
Batting Name Mjoas yramwsn, LUC Phone 40S “L26-C256_-
Billing Adtreee/P.O.Bex_ticA WE cES% sytem, S04 /laags
City_ OC State OL Zip 73(31 Year Basiness Stastea_L0o7
Stiowing Adin ee Proprietorship
ta aac ee
speate payment of all das frum Applicont to Cobinet Outlet lnc, now
Oe ta Re teeny, Agelionet ee cece
ppp SEE eee roe 2317p F24ey
Y°T-226-Gase 1-9-8
‘TelephoesCabinet Outlet, Inc. Invoice
(45 NW 10TH ST —
OKLAHOMA CITY,OKLA 73127 Sete seen 6
405-789-4297 6/13/2017 28471
FAX 405-789-3468
BiTo ‘Ship To
MIDAS INVESTMENTS ,LLC ceu
1801 NE 135TH
OKLA CITY,OKLA 73131
P.O. Number Tess Rep Ship Va F.0.8. Project
‘Nez30 6/13/2017 ctu
Quantity tem Code Description Price Each Amount
1 | Cabinets GEORGETOWN WHITE PANTRIES 2-3083,1-2484 1,831.50 1,831.50T |
|Okiahoma City Sales Tax. 8.375% 19339
Total $1,984.89
Ex (BilCabinet Outlet, inc. Invoice
7145 NW 10TH ST
OKLAHOMA CITY,OKLA 73127 Date srvice #
408-789-4297 6/30/2017 25343
FAX 405-789-3468
BU To Ship To |
MIDAS | LLC 627NW 22ND
1801 NE 138TH OKc 1
OKLA CITY,OKLA 73131
P.O. Number Terms Rep Ship Via F.0.B. Project
Net3o E2017 Delivered 627
1] Cabinets SHAKER ALDER CABINETS AND ACCESSORIES: 371.07 SI.O7T
ol | Accessories REP2A96 72.00 72.007 |
Oklahoma City Sales Tax 8.375% 41.80
Total $540.87
Preview
AI s RM BER: Client! MARK .L. HOOSE County: Oklahoma imber: CS~ CABINET OUTLETLING - Plaintiff(s) ys FLED IN DISTRICT COURT OXLAHOMA COUNTY CHAD BLACK ETAL - Defendant(s) JAN ~ 8 2018 Date Served: 1/8/2018 12:25:00 PM RICK WARREN Served By. JOHN SHADID (PSS-2014-83 COURT CLERK 48 County of Origin: Oklahoma Proof of Service Case Number: CS-2018-61 DOCUMENTS SERVED: I, being duly METHOD OF SERVICE: sworn, certify that | received the forgoing, to wit: *Summons with Petition And served the same according to the law in the following manner] to wit: Personal Service by delivering a true copy of said process *Exhibits personally to CHAD BLACK at 1800 NE 135TH, OKLA CITY, OK 73131-0000. Date and Time: 1/8/2018 12:25:00 PM Other Information: 282920 Subscribed and sworn Jasieafgre me this Undersigned declares under penalty of perjury (oe os My re 03: that the foregoing is true and correct. : YAN UG! 2: eS). JAN 08 2017 Notary Public ‘ (SEAL) (date)IN THE DISTRICT COURT OF OKLAHOMA COUNTY STATE OF OKLAHOMA CABINET OUTLET, INC., ) an Oklahoma corporation, ) ) Plaintiff, ) ) Case No. CS-2018- v. ) ) MIDAS INVESTMENTS, LLC, an Oklahoma, ) limited liability company, and CHAD BLACK, ) an individual, | ) ) ) Defendant(s). ) SUMMONS To the above-named Defendant: CHAD BLACK 1% iP #OENE 135” Oklahoma City, OK 73131 Or Wherever Found. You have been sued by the above-named Plaintiff and you are directed to file a written answer to the attached Petition of said Plaintiffin the Court at the address listed below within Thirty- five (35) days after service of this Summons upon you, exclusive of the day of service. A copy of your answer must be delivered or mailed to the Attorney for the Plaintiff. Unless you answer the Petition within the time stated, judgment will be rendered against you with costs of the action. bh « ISSUED: Y Aww GO| y RICK WARREN, COURT CLERK U0 DISTRICT COURT OF OKLAHOMA COUNTY Oklahoma County Courthouse 320 Robert S. Kerr Oklahoma City, OK 73120 Aub Gels Deputy Court Clerk Sg [SEAL]Summons Page 2 Approved: MARK L. HOOSE, P.C. Mark L. Hoose, OBA# 14083 17 East First Street Post Office Box 753 Edmond, Oklahoma 73083-0753 Tel: (405) 340-6401 Fax: (405) 348-5040 hooselawoffice@gmail.com _ _— This Summons was served on G ( S and you must answer the Petition (Date of Service) within Thirty-five (35) days after this date. y (Sighature of Person Serving Summons) YOU MAY SEEK THE ADVICE OF AN ATTORNEY ON ANY MATTER CONNECTED WITH THIS SUIT OR YOUR ANSWER. SUCH ATTORNEY SHOULD BE CONSULTED IMMEDIATELY SO THAT AN ANSWER MAY BE FILED WITHIN THE TIME LIMIT STATED IN THE SUMMONS. \\SVRHOOSEI\Docs\CLIENT Holbrock, DaniMidas&eBlack\Summons-Chad.wpd JAN 08 7919FILED IN DISTRICT COURT OKLAHOMA COUNTY IN THE DISTRICT COURT OF OKLAHOMA COUNTY | jay - 4 2018 STATE OF OKLAHOMA RICK WARREN CABINET OUTLET, INC., 95 COURT CLERK an Oklahoma corporation, Plaintiff, Case No. CS-2018- Lavy JJd76h ag Vv. MIDAS INVESTMENTS, LLC, an Oklahoma, limited liability company, and CHAD BLACK, an individual, weer we Defendant(s). PETITION Plaintiff, Cabinet Outlet, Inc., for its cause of action against the Defendants, Midas Investments, LLC, and Chad Black, alleges and states as follows: Jurisdiction and Venue 1. Plaintiff, Cabinet Outlet, Inc. is an Oklahoma corporation doing business in the State of Oklahoma. 2. Defendant, Midas Investments, LLC, is an Oklahoma limited liability company doing business in the State of Oklahoma. 3. Defendant, Chad Black, is an individual residing in Oklahoma County, State of Oklahoma. 4. This court has jurisdiction over the Defendants and venue is proper in this court. Cause of Action 5. Plaintiff entered into an agreement with Defendants to provide materials at the request of and for the benefit of Defendants pursuant to an Open Account Agreement attached hereto as Exhibit “A”.6. Plaintiff provided the materials and has otherwise fulfilled all contractual obligations to Defendants. Plaintiff was owed $2,525.76 for the materials provided to Defendants from June 13, 2017 through June 30, 2017, pursuant to the agreement referenced in paragraph 5 herein above. A copy of the invoices for the materials provided are attached hereto as Exhibit “B”. 7. There remains due and owing to Plaintiff $2,525.76, plus interest at a rate of 1.5% per month pursuant to 15 O.S. § 275, from and after June 30, 2017, for materials provided to Defendants, pursuant to the agreement referenced in paragraph 4 herein above. 8. That Defendant, Chad Black, executed a personal guarantee as part of the Open Account Agreement referenced in paragraph 5 herein above. 9. Defendants have not paid Plaintiff and are in default of the agreement referenced in paragraph 4 herein above. Said default is continuing. 10. The amount owed to Plaintiff pursuant to the above referenced agreement is $2,525.76, plus interest at 1.5% per month from and after June 30, 2017, pursuant to Okla. stat. Tit. 15, § 275. Plaintiff is also entitled to recover a reasonable attorney fee pursuant to Okla. Stat. tit. 12, § 936. Plaintiff seeks a reasonable attorney fee to be determined by the court at time judgment is entered (but a sum of not less than $1,500.00). Plaintiff is also entitled to costs against Defendants pursuant to Okla. Stat. tit. 12, § 928. Prayer for Relief WHEREFORE, for its causes of action against the Defendants, Midas Investments, LLC, and Chad Black, Plaintiff asks that: Plaintiff be granted an in personam money judgment against Defendants in the amount of $2,525.76, plus interest at 1.5% per month from and after June 30, 2017, through date of judgment; Plaintiff be granted an in personam money judgment against Defendants for a reasonable attorney’sfee to be set and determined by the court at time of judgment (but a sum of not less than $1,500.00); Plaintiff be awarded judgment against Defendants for costs, including all post judgment costs; Plaintiff’ s in personam money judgment against Defendants shall state that it accrues post judgment interest at the rates prescribed to Okla. Stat. tit. 12 § 727.1; and Plaintiff be granted such other relief as the court deems just. MARK L. HOOSE, P.C. loose, OBA# 14083 Law 17 East First Street Post Office Box 753 Edmond, Oklahoma 73083-0753 Tel: (405) 340-6401 Fax: (405) 348-5040 Hooselawoffice@gmail.com Attorney for Plaintiff FDCPA NOTICE UNLESS YOU NOTIFY THIS OFFICE, WITHIN THIRTY (30) DAYS AFTER RECEIVING THIS NOTICE, THAT YOU DISPUTE THE VALIDITY OF THE DEBT, OR ANY PORTION THEREOF, THIS OFFICE WILL ASSUME THIS DEBT TO BE VALID. IF YOU NOTIFY THE ATTORNEY FOR THE PLAINTIFF IN WRITING WITHIN THE THIRTY (30) DAY PERIOD OF ANY DISPUTE, VERIFICATION OF THE DEBT WILL BE OBTAINED, AND A COPY OF SUCH VERIFICATION WILL BE FURNISHED TO YOU BY THE ATTORNEY FOR PLAINTIFF, INCLUDING THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM THE CURRENT CREDITOR. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. \\SVRHOOSE I\Docs\CLIENT \Holbrock,Dan\MidasdeBlack Petition wpdOO PM I nt MAN/2:/2015/021 00 t oan memanagene canner FAX No, 4054716347 P. 00: 405-719-4297 FAX 405-789.3468 Batting Name Mjoas yramwsn, LUC Phone 40S “L26-C256_- Billing Adtreee/P.O.Bex_ticA WE cES% sytem, S04 /laags City_ OC State OL Zip 73(31 Year Basiness Stastea_L0o7 Stiowing Adin ee Proprietorship ta aac ee speate payment of all das frum Applicont to Cobinet Outlet lnc, now Oe ta Re teeny, Agelionet ee cece ppp SEE eee roe 2317p F24ey Y°T-226-Gase 1-9-8 ‘TelephoesCabinet Outlet, Inc. Invoice (45 NW 10TH ST — OKLAHOMA CITY,OKLA 73127 Sete seen 6 405-789-4297 6/13/2017 28471 FAX 405-789-3468 BiTo ‘Ship To MIDAS INVESTMENTS ,LLC ceu 1801 NE 135TH OKLA CITY,OKLA 73131 P.O. Number Tess Rep Ship Va F.0.8. Project ‘Nez30 6/13/2017 ctu Quantity tem Code Description Price Each Amount 1 | Cabinets GEORGETOWN WHITE PANTRIES 2-3083,1-2484 1,831.50 1,831.50T | |Okiahoma City Sales Tax. 8.375% 19339 Total $1,984.89 Ex (BilCabinet Outlet, inc. Invoice 7145 NW 10TH ST OKLAHOMA CITY,OKLA 73127 Date srvice # 408-789-4297 6/30/2017 25343 FAX 405-789-3468 BU To Ship To | MIDAS | LLC 627NW 22ND 1801 NE 138TH OKc 1 OKLA CITY,OKLA 73131 P.O. Number Terms Rep Ship Via F.0.B. Project Net3o E2017 Delivered 627 1] Cabinets SHAKER ALDER CABINETS AND ACCESSORIES: 371.07 SI.O7T ol | Accessories REP2A96 72.00 72.007 | Oklahoma City Sales Tax 8.375% 41.80 Total $540.87