Brittany Gilpin v. Six Flags Entertainment Corp.

IN THE DISTRICT COURT OF OKLAHOMA COUNTY STATE OF OKLAHOMA BRITTANY GILPIN, as parent and next friend of H.L., a minor, Plaintiff, vs. SIX FLAGS ENTERTAINMENT CORP., SIX FLAGS FRONTIER, LLC, an Oklahoma limited liability company, Defendant. FILED DISTRICT COURT OKLAHOMA COUNTY, OKLAHOMA March 5, 2026 1:59 PM RICK WARREN, COURT CLERK Case No. Case Number CJ-2026-1663 PLAINTIFF’S ORIGINAL PETITION COMES NOW, the Plaintiff, H. L., a minor, by and through said minor’s parent and next friend, Brittany Gilpin, and for Plaintiff’s causes of action and theories of liability against Defendants, Six Flags Entertainment Corp., a foreign for-profit business, and Six Flags Frontier, LLC, an Oklahoma limited liability company, and would allege and state as follows: PARTIES 1. Plaintiff, H.L., is a minor child, who resides with his parent and next friend, Brittany Gilpin, and is a citizen and resident of Oklahoma County, State of Oklahoma. 2. Defendant Six Flags Entertainment Corp., is a foreign, for-profit corporation, with its principal headquarters located at 8701 Red Oak Blvd, Charlotte, North Carolina 28217 3. Defendant Six Flags Frontier, LLC, is an Oklahoma limited liability company doing business in Oklahoma City, Oklahoma County, State of Oklahoma, who may be served in accordance with Oklahoma law by and through its Registered Agent, Corporation Service Company, 10300 Greenbriar Place, Oklahoma City, Oklahoma 73159-7653. JURISDICTION & VENUE 4. Venue in this Honorable Court is appropriate pursuant to 12 O.S. §131 as Defendant, Six Flags Frontier, LLC, is located and does business in Oklahoma County, State of Oklahoma. 5. Venue is also proper pursuant to 12 O.S. § 137, as Plaintiff’s cause of action arose in Oklahoma County, State of Oklahoma. 6. The amount in controversy exceeds $100,000.00 exclusive of interest and costs thus giving this Honorable Court jurisdiction. 7. Further, this Court has personal jurisdiction over Defendants as Defendants conduct substantial business within the State of Oklahoma, specifically Oklahoma County, and the acts and omissions giving rise to this lawsuit occurred in Oklahoma County, State of Oklahoma. GENERAL FACTS AND ALLEGATIONS 8. Plaintiff incorporates herein by reference all preceding paragraphs as though fully set forth hereinbelow. 9. On May 5, 2024, Plaintiff, a minor child, was a business invitee and paying customer at Frontier City amusement park in Oklahoma City, Oklahoma. 10. Upon information and belief, Frontier City is a fictitious trade name under which Defendant, Six Flags Frontier, LLC, operates the amusement park. 11. At approximately 6:20 pm, Plaintiff boarded the Silver Bullet roller coaster, an amusement ride owned, operated, maintained, inspected, and controlled by Defendants. 12. The Silver Bullet is a steel roller coaster that travels at high speeds and subjects riders to significant g-forces, sudden accelerations, and decelerations. 13. Plaintiff was properly seated in the roller coaster car and secured with a lap bar restraint system as directed by Defendants' employees. 14. During the course of the ride, and without warning, the Silver Bullet roller coaster abruptly and violently stopped trapping the riders for approximately 30 minutes before the riders were extricated. 15. As a direct and proximate result of the abrupt stop, Plaintiff was thrust forward into the lap bar with extreme force. 16. The violent impact caused catastrophic internal injuries to Plaintiff, including an acute, inflamed appendix. 17. Plaintiff immediately experienced severe abdominal pain and distress. 18. Plaintiff required emergency medical attention and was transported to OU Medical Center where he underwent emergent surgery to address the inflamed appendix. 19. Plaintiff suffered severe physical pain, emotional distress, medical expenses, and other damages as a result of the injuries sustained. 20. Upon information and belief, the abrupt stopping of the Silver Bullet roller coaster was caused by one or more of the following: mechanical failure, improper maintenance, operator error, defective design, inadequate inspection, improper operation, and/or other failures by Defendants. 21. At all times mentioned herein, Defendants owed a duty to Plaintiff to exercise the highest degree of care to ensure the safety of all amusement park rides, including the Silver Bullet roller coaster. 22. Amusement park operators in Oklahoma owe their patrons a non-delegable duty to maintain their premises and equipment in a reasonably safe condition and to warn of known or discoverable dangers. 23. Defendants breached their duties to Plaintiff as set forth herein, which caused Plaintiff’s injuries and other harms and losses. FIRST CAUSE OF ACTION: NEGLIGENCE (All Defendants) 24. Plaintiff incorporates herein by reference all preceding paragraphs as though fully set forth hereinbelow. 25. At all times relevant hereto, Defendants owed Plaintiff, as a business invitee and minor child, a duty to exercise reasonable care for his safety, including but not limited to: a. A duty to maintain the Silver Bullet roller coaster in a safe condition; b. A duty to properly inspect the Silver Bullet roller coaster; c. A duty to properly maintain all mechanical, electrical, and safety systems of the Silver Bullet roller coaster; d. A duty to properly train employees operating the Silver Bullet roller coaster; e. A duty to properly operate the Silver Bullet roller coaster; f. A duty to ensure the lap bar restraint system was adequate and properly designed; g. A duty to warn of known or discoverable dangers associated with the Silver Bullet roller coaster; h. A duty to implement adequate safety protocols and emergency procedures; i. A duty to comply with all applicable state and federal regulations regarding amusement ride safety; and j. A duty to protect Plaintiff from foreseeable harm. 26. Defendants breached their duties of care owed to Plaintiff in the following ways, among others: a. Failed to properly maintain the Silver Bullet roller coaster; b. Failed to properly inspect the Silver Bullet roller coaster; c. Failed to discover and repair mechanical defects in the Silver Bullet roller coaster; d. Failed to properly train employees in the operation of the Silver Bullet roller coaster; e. Failed to properly operate the Silver Bullet roller coaster; f. Allowed the Silver Bullet roller coaster to be operated with known or discoverable mechanical defects; g. Failed to implement adequate safety protocols to prevent abrupt stops; h. Failed to adequately design and implement restraint systems that would protect riders in the event of an abrupt stop; i. Failed to warn Plaintiff of the dangers associated with abrupt stops on the Silver Bullet roller coaster; j. Failed to comply with applicable safety regulations and industry standards; k. Failed to implement adequate inspection schedules and maintenance protocols; l. Failed to properly monitor the operation of the Silver Bullet roller coaster; m. Operated the Silver Bullet roller coaster when it was not safe to do so; n. Failed to implement adequate quality control measures; o. Failed to properly supervise employees; and p. Were otherwise negligent in ways to be proven at trial. 27. As a direct and proximate result of Defendants' negligence, Plaintiff suffered severe injuries including but not limited to a ruptured appendix requiring emergent surgery, physical pain and suffering, emotional distress, medical expenses, loss of enjoyment of life, and other damages. 28. Plaintiff's injuries were foreseeable and could have been prevented by the exercise of reasonable care on the part of Defendants. 29. WHEREFORE, Plaintiff prays for judgment against Defendants as set forth in the Prayer for Relief below. SECOND CAUSE OF ACTION: PREMISES LIABILITY (All Defendants) 30. Plaintiff incorporates by reference each and every allegation contained in preceding paragraphs as though fully set forth herein. 31. At all times relevant hereto, Defendants owed Plaintiff, as a business invitee and minor child, a duty to exercise reasonable care for his safety, including but not limited to: a. A duty to maintain the Silver Bullet roller coaster in a safe condition; b. A duty to properly inspect the Silver Bullet roller coaster; c. A duty to properly maintain all mechanical, electrical, and safety systems of the Silver Bullet roller coaster; d. A duty to properly train employees operating the Silver Bullet roller coaster; e. A duty to properly operate the Silver Bullet roller coaster; f. A duty to ensure the lap bar restraint system was adequate and properly designed; g. A duty to warn of known or discoverable dangers associated with the Silver Bullet roller coaster; h. A duty to implement adequate safety protocols and emergency procedures; i. A duty to comply with all applicable state and federal regulations regarding amusement ride safety; and j. A duty to protect Plaintiff from foreseeable harm. 32. Defendants breached their duties of care owed to Plaintiff in the following ways, among others: a. Failed to properly maintain the Silver Bullet roller coaster; b. Failed to properly inspect the Silver Bullet roller coaster; c. Failed to discover and repair mechanical defects in the Silver Bullet roller coaster; d. Failed to properly train employees in the operation of the Silver Bullet roller coaster; e. Failed to properly operate the Silver Bullet roller coaster; f. Allowed the Silver Bullet roller coaster to be operated with known or discoverable mechanical defects; g. Failed to implement adequate safety protocols to prevent abrupt stops; h. Failed to adequately design and implement restraint systems that would protect riders in the event of an abrupt stop; i. Failed to warn Plaintiff of the dangers associated with abrupt stops on the Silver Bullet roller coaster; j. Failed to comply with applicable safety regulations and industry standards; k. Failed to implement adequate inspection schedules and maintenance protocols; l. Failed to properly monitor the operation of the Silver Bullet roller coaster; m. Operated the Silver Bullet roller coaster when it was not safe to do so; n. Failed to implement adequate quality control measures; o. Failed to properly supervise employees; and p. Were otherwise negligent in ways to be proven at trial. 33. As a direct and proximate result of Defendants’ negligence, Plaintiff suffered severe injuries, physical pain and suffering, emotional distress, medical expenses, loss of enjoyment of life, and other harms and losses. 34. Plaintiff’s injuries were foreseeable and could have been prevented by the exercise of reasonable care on the part of Defendants. WHEREFORE, Plaintiff prays for judgment against Defendants as set forth in the Prayer for Relief below. THIRD CAUSE OF ACTION: STRICT LIABILITY (All Defendants) 35. Plaintiff incorporates by reference each and every allegation contained in preceding paragraphs as though fully set forth herein. 36. The operation of high-speed roller coasters, including the Silver Bullet, constitutes an abnormally dangerous activity under Oklahoma law. 37. The operation of the Silver Bullet roller coaster involves: a. A high degree of risk of harm to persons; b. A likelihood that harm that results will be catastrophic; c. An inability to eliminate the risk through the exercise of reasonable care; d. Risks that are not matters of common usage; and e. An activity whose value to the community may be outweighed by its dangerous attributes. 38. The Silver Bullet roller coaster subjects riders to extreme speeds, g-forces, and mechanical forces that, if not perfectly controlled, can result in catastrophic injury or death. 39. Even with the exercise of reasonable care, the operation of high-speed roller coasters carries inherent and unavoidable risks of catastrophic harm. 40. As the operator of an abnormally dangerous activity, Defendants are strictly liable for all harm that results from the activity, regardless of the degree of care exercised. 41. The injuries sustained by Plaintiff were a direct result of the abnormally dangerous activity conducted by Defendants. 42. Plaintiff's injuries were within the scope of risks that make the activity abnormally dangerous. WHEREFORE, Plaintiff prays for judgment against Defendants as set forth in the Prayer for Relief below. FOURTH CAUSE OF ACTION: BREACH OF WARRANTY OF MERCHANTABILITY (All Defendants) 56. Plaintiff incorporates by reference each and every allegation set forth in the preceding paragraphs as though fully set forth herein. 57. Defendants, by selling tickets for rides on the Silver Bullet roller coaster, impliedly warranted that the ride was merchantable and fit for the ordinary purpose for which such rides are used, namely to provide safe entertainment and amusement. 58. The Silver Bullet roller coaster was not merchantable and was not fit for its ordinary purpose in that: a. It was not safe for its intended use; b. It was prone to abrupt and dangerous stops; c. The restraint system was inadequate to protect riders; d. It would not pass without objection in the trade for rides of its kind; and e. It was not of fair average quality within its description. 59. Defendants breached the implied warranty of merchantability. 60. As a direct and proximate result of Defendants' breach of warranty, Plaintiff suffered severe injuries and damages. 61. At the time Plaintiff purchased admission to Defendants' amusement park and boarded the Silver Bullet roller coaster, it was foreseeable that the breach of warranty would cause injury. WHEREFORE, Plaintiff prays for judgment against Defendants as set forth in the Prayer for Relief below. FIFTH CAUSE OF ACTION: BREACH OF WARRANTY OF FITNESS FOR A PARTICULAR PURPOSE (All Defendants) 62. Plaintiff incorporates by reference each and every allegation set forth in the preceding paragraphs as though fully set forth herein. 63. At the time Plaintiff purchased admission and boarded the Silver Bullet roller coaster, Defendants had reason to know of the particular purpose for which the ride was required, specifically to provide safe amusement and entertainment to minor children and other patrons. 64. Plaintiff relied on Defendants' skill and judgment to select and provide a ride that was suitable for that particular purpose. 65. Defendants impliedly warranted that the Silver Bullet roller coaster was fit for the particular purpose of safely entertaining minor children and other patrons. 66. The Silver Bullet roller coaster was not fit for its particular purpose in that it was unsafe and caused catastrophic injury to Plaintiff during normal operation. 67. Defendants breached the implied warranty of fitness for a particular purpose. 68. As a direct and proximate result of Defendants' breach of warranty, Plaintiff suffered severe injuries and damages. WHEREFORE, Plaintiff prays for judgment against Defendants as set forth in the Prayer for Relief below. SIXTH CAUSE OF ACTION: NEGLIGENT MAINTENANCE (All Defendants) 69. Plaintiff incorporates by reference each and every allegation set forth in the preceding paragraphs as though fully set forth herein. 70. Defendants had a duty to properly maintain the Silver Bullet roller coaster in a safe condition. 71. Proper maintenance of a roller coaster includes, but is not limited to: a. Regular inspection of all mechanical components; b. Replacement of worn or damaged parts; c. Lubrication and adjustment of moving parts; d. Testing of braking systems; e. Testing of emergency stop systems; f. Inspection and maintenance of restraint systems; g. Inspection and maintenance of track and support structures; h. Documentation of all maintenance activities; and i. Compliance with manufacturer recommendations and industry standards. 72. Defendants negligently maintained the Silver Bullet roller coaster in that they: a. Failed to conduct adequate inspections; b. Failed to discover mechanical defects; c. Failed to repair known defects; d. Failed to replace worn or damaged components; e. Failed to properly maintain braking and emergency stop systems; f. Failed to follow manufacturer maintenance recommendations; g. Failed to comply with industry standards; and h. Were otherwise negligent in maintaining the ride. 73. Defendants' negligent maintenance was a direct and proximate cause of the abrupt stop that resulted in Plaintiff's injuries. WHEREFORE, Plaintiff prays for judgment against Defendants as set forth in the Prayer for Relief below. SEVENTH CAUSE OF ACTION NEGLIGENT INSPECTION (All Defendants) 74. Plaintiff incorporates by reference each and every allegation set forth in the preceding paragraphs as though fully set forth herein. 75. Defendants had a duty to properly inspect the Silver Bullet roller coaster to ensure it was safe for operation. 76. Proper inspection of a roller coaster includes, but is not limited to: a. Daily visual inspections before operation; b. Regular detailed inspections of all mechanical systems; c. Testing of safety systems; d. Non-destructive testing of critical components; e. Documentation of all inspection results; f. Investigation of any unusual occurrences or rider complaints; and g. Compliance with state regulations and industry standards. 77. Defendants negligently inspected the Silver Bullet roller coaster in that they: a. Failed to conduct adequate inspections; b. Failed to conduct inspections at appropriate intervals; c. Failed to properly train inspection personnel; d. Failed to utilize appropriate inspection methods and equipment; e. Failed to document inspection results; f. Failed to identify mechanical defects during inspections; g. Failed to investigate prior incidents or complaints; and h. Were otherwise negligent in inspecting the ride. 78. Had Defendants properly inspected the Silver Bullet roller coaster, they would have discovered the mechanical defects and/or dangerous conditions that caused the abrupt stop. 79. Defendants' negligent inspection was a direct and proximate cause of Plaintiff's injuries. WHEREFORE, Plaintiff prays for judgment against Defendants as set forth in the Prayer for Relief below. EIGHTH CAUSE OF ACTION NEGLIGENT OPERATION (All Defendants) 80. Plaintiff incorporates by reference each and every allegation set forth in the preceding paragraphs as though fully set forth herein. 81. Defendants had a duty to properly operate the Silver Bullet roller coaster in a safe manner. 82. Proper operation of a roller coaster includes, but is not limited to: a. Ensuring all safety systems are functioning before operation; b. Properly securing all riders with appropriate restraints; c. Monitoring the ride during operation; d. Following established operating procedures; e. Responding appropriately to any malfunctions; f. Ensuring weather conditions are appropriate for safe operation; and g. Ceasing operation when unsafe conditions are present. 83. Defendants negligently operated the Silver Bullet roller coaster in that they: a. Failed to ensure all safety systems were functioning properly; b. Operated the ride despite known or discoverable mechanical problems; c. Failed to properly monitor the ride during operation; d. Failed to follow established operating procedures; e. Failed to respond appropriately to the malfunction that caused the abrupt stop; f. Failed to implement adequate operational protocols; and g. Were otherwise negligent in operating the ride. 84. Defendants' negligent operation was a direct and proximate cause of Plaintiff's injuries. WHEREFORE, Plaintiff prays for judgment against Defendants as set forth in the Prayer for Relief below. NINTH CAUSE OF ACTION NEGLIGENT TRAINING AND SUPERVISION (All Defendants) 85. Plaintiff incorporates by reference each and every allegation set forth in the preceding paragraphs as though fully set forth herein. 86. Defendants had a duty to properly train and supervise their employees who operated, maintained, and inspected the Silver Bullet roller coaster. 87. Proper training includes, but is not limited to: a. Instruction on safe operation procedures; b. Instruction on emergency procedures; c. Instruction on proper maintenance techniques; d. Instruction on proper inspection methods; e. Instruction on identifying mechanical problems; f. Ongoing refresher training; and g. Competency testing. 88. Defendants negligently trained and supervised their employees in that they: a. Failed to provide adequate training; b. Failed to ensure employees were competent to perform their duties; c. Failed to provide ongoing training; d. Failed to adequately supervise employees; e. Failed to implement adequate training protocols; f. Allowed unqualified or inadequately trained employees to operate, maintain, or inspect the Silver Bullet roller coaster; and g. Were otherwise negligent in training and supervising employees. 89. Defendants' negligent training and supervision was a direct and proximate cause of Plaintiff's injuries. WHEREFORE, Plaintiff prays for judgment against Defendants as set forth in the Prayer for Relief below. TENTH CAUSE OF ACTION NEGIGENCE PER SE - VIOLATION OF SAFETY REGULATIONS (All Defendants) 90. Plaintiff incorporates by reference each and every allegation set forth in the preceding paragraphs as though fully set forth herein. 91. At all times relevant hereto, Oklahoma statutes and regulations, including but not limited to Title 40 O.S. § 165.1 et seq. (Oklahoma Amusement Ride Safety Act), and applicable federal regulations, imposed duties upon Defendants with regard to the operation, maintenance, and inspection of amusement rides. 92. These statutes and regulations were enacted for the purpose of protecting members of the public, including Plaintiff, from the type of harm that occurred in this case. 93. Plaintiff is a member of the class of persons the statutes and regulations were designed to protect. 94. Defendants violated said statutes and regulations in the following ways, among others: a. Failed to properly maintain the Silver Bullet roller coaster; b. Failed to properly inspect the Silver Bullet roller coaster; c. Failed to comply with manufacturer specifications; d. Failed to maintain required documentation; e. Failed to ensure the ride was operated safely; f. Failed to train employees in accordance with regulations; and g. Violated other safety regulations to be proven at trial. 95. Defendants' violations of these statutes and regulations constitute negligence per se. 96. Defendants' violations were a direct and proximate cause of Plaintiff's injuries. WHEREFORE, Plaintiff prays for judgment against Defendants as set forth in the Prayer for Relief below. ELEVENTH CAUSE OF ACTION VICARIOUS LIABILITY/RESPONDEAT SUPERIOR (All Defendants) 97. Plaintiff incorporates by reference each and every allegation contained in paragraphs 1 through 96 as though fully set forth herein. 98. At all times relevant hereto, the employees and agents of Defendants who operated, maintained, inspected, and supervised the Silver Bullet roller coaster were acting within the course and scope of their employment. 99. The negligent, grossly negligent, and wrongful acts of Defendants' employees and agents, as alleged herein, were committed while said employees and agents were acting within the course and scope of their employment and agency. 100. Under the doctrine of respondeat superior, Defendants are vicariously liable for the negligent, grossly negligent, and wrongful acts of their employees and agents. 101. Defendants' vicarious liability extends to all acts and omissions of their employees and agents that proximately caused Plaintiff's injuries and damages. WHEREFORE, Plaintiff prays for judgment against Defendants as set forth in the Prayer for Relief below. TWELFTH CAUSE OF ACTION FAILURE TO WARN (All Defendants) 107. Plaintiff incorporates by reference each and every allegation contained in paragraphs 1 through 106 as though fully set forth herein. 108. Defendants had a duty to warn Plaintiff of known or discoverable dangers associated with the Silver Bullet roller coaster. 109. Defendants knew or should have known that: a. The Silver Bullet roller coaster was prone to abrupt stops; b. Abrupt stops could cause catastrophic internal injuries; c. The restraint system was inadequate to protect riders from injury during abrupt stops; d. The Silver Bullet roller coaster had mechanical defects or issues; and e. Other dangers associated with the ride. 110. Defendants failed to adequately warn Plaintiff of these known or discoverable dangers. 111. Had Defendants provided adequate warnings, Plaintiff and/or [his/her] parents/guardians would not have allowed Plaintiff to ride the Silver Bullet roller coaster. 112. Defendants' failure to warn was a direct and proximate cause of Plaintiff's injuries. WHEREFORE, Plaintiff prays for judgment against Defendants as set forth in the Prayer for Relief below. THIRTEENTH CAUSE OF ACTION BREACH OF DUTY OF REASONABLE CARE TO MINOR CHILD (All Defendants) 113. Plaintiff incorporates by reference each and every allegation set forth in the preceding paragraphs as though fully set forth herein. 114. At all times relevant hereto, Plaintiff was a minor child entitled to special protection under the law. 115. Defendants owed Plaintiff, as a minor child, a heightened duty of care to ensure [his/her] safety. 116. Because of Plaintiff's age and status as a minor, Defendants had a duty to: a. Exercise a higher degree of care commensurate with Plaintiff's age and inability to appreciate dangers; b. Anticipate that a minor child would not appreciate the risks associated with the Silver Bullet roller coaster; c. Take additional precautions to protect minor children from foreseeable harm; d. Ensure that amusement rides were especially safe for minor children; e. Provide adequate supervision; and f. Protect Plaintiff from dangers that [he/she] could not reasonably be expected to avoid. 117. Defendants breached their heightened duty of care owed to Plaintiff as a minor child. 118. Defendants' breach of duty was a direct and proximate cause of Plaintiff's injuries. WHEREFORE, Plaintiff prays for judgment against Defendants as set forth in the Prayer for Relief below. SIXTEENTH CAUSE OF ACTION RES IPSA LOQUITUR (All Defendants) 119. Plaintiff incorporates by reference each and every allegation set forth in the preceding paragraphs as though fully set forth herein. 120. The instrumentality that caused Plaintiff's injuries (the Silver Bullet roller coaster) was under the exclusive control and management of Defendants. 121. The accident that caused Plaintiff’s injuries (the abrupt stop of the roller coaster resulting in Plaintiff being thrust into the lap bar) is of a type that ordinarily does not occur in the absence of negligence. 122. Plaintiff did not contribute to the accident or [his/her] injuries in any way. 123. Under the doctrine of res ipsa loquitur, the circumstances of this accident give rise to an inference of negligence on the part of Defendants. 124. The inference of negligence is sufficient to establish Defendants' liability absent evidence to the contrary. WHEREFORE, Plaintiff prays for judgment against Defendants as set forth in the Prayer for Relief below. PRAYER FOR RELIEF WHEREFORE, premises considered, Plaintiff prays for judgment against Defendants, and each of them, as follows: 1. For general damages according to proof at trial in excess of $100,000.00; 2. For special damages including past and future medical expenses according to proof at trial in excess of $100,000.00; 3. For damages for physical pain and suffering, both past and future, according to proof at trial in excess of $100,000.00; 4. For damages for emotional distress and mental anguish, both past and future, according to proof at trial in excess of $100,000.00; 5. For damages for loss of enjoyment of life according to proof at trial in excess of $100,000.00; 6. For punitive damages in an amount sufficient to punish Defendants and deter similar conduct, pursuant to 23 O.S. § 9.1 in excess of $100,000.00; 7. For pre-judgment and post-judgment interest as allowed by law; 8. For costs of suit incurred herein; 9. For attorney's fees to the extent permitted by law; and 10. For such other and further relief as the Court deems just and proper. Respectfully submitted, __________________________ Nathan D. Richter, OBA No. 22003 Mark Van Paaschen, OBA No. 31431 BISON LAW FIRM 1609 Professional Circle Yukon, Oklahoma 73099 Tel: 405-407-0111 Fax: 405-407-0211 [email protected] [email protected] And __________________________ Gessica Sewell McLanahan OBA #33048 Milly Daniels OBA #31531 MD Law, PLLC 1435 N. Rockwell Avenue Oklahoma City, OK 73127 Tel: (405) 768-2570 [email protected] [email protected] ATTORNEYS FOR PLAINTIFF ATTORNEY LIEN CLAIMED JURY TRIAL DEMANDED