White Rock Energy, LLC v. Wilford Steve Boling

IN THE DISTRICT COURT OF McCLAIN COUNTY STATE OF OKLAHOMA WHITE ROCK ENERGY, LLC, and WHITE ROCK OIL & GAS, LLC Plaintiffs, v. WILFORD STEVE BOLING, SHARON L. BOLING, JONATHAN ALLEN STAMPER, AND ARICA SHAREE STAMPER, Defendants. PETITION Plaintiffs White Rock Oil and Gas, LLC and White Rock Energy, LLC (collectively “White Rock”), for their Petition against Defendants Wilford Steve Boling ("Mr. Boling"), and Sharon L. Boling ("Mrs. Boling"), Jonathan Allen Stamper ("Mr. Stamper"), Arica Sharee Stamper ("Mrs. Stamper"), (collectively “Defendants”), allege as follows: PARTIES, JURISDICTION, AND VENUE 1. Plaintiff White Rock Energy, LLC is a Texas limited liability company. 2. Plaintiff White Rock Oil & Gas, LLC is a Texas limited liability company. 3. Defendant Wilford Steve Boling is an individual residing in the State of Oklahoma. 4. Defendant Sharon L. Boling is an individual residing in the State of Oklahoma. 5. Defendant Jonathan Allen Stamper is an individual residing in the State of Oklahoma. 6. Defendant Arica Sharee Stamper is an individual residing in the State of Oklahoma. 7. Upon information and belief, Defendants Wilford Steve Boling and Sharon L. Boling are the parents of Defendant Arica Sharee Stamper. 8. Upon information and belief, Mr. Stamper and Mrs. Stamper are married. 9. Upon information and belief, Mr. Stamper and Mrs. Stamper reside at real property located at 1766 S. Main Ave, Washington, Oklahoma (the “Subject Property”). 10. This Court has subject matter jurisdiction over this action pursuant to Article VII of the Oklahoma Constitution and 12 O.S. § 1. 11. Venue is proper in McClain County pursuant to 12 O.S. § 131 because the real property at issue is located in McClain County. FACTUAL BACKGROUND A. The Underlying Fraud and Judgment 12. This action arises from Mr. Stamper’s deliberate and ongoing pattern of fraudulent conduct – a pattern that has manifested not only in the underlying dispute giving rise to the Judgment described herein, but in a sustained course of deception, fabrication, and asset concealment by the Stampers. 13. Through approximately February 2022 to December 2022, Mr. Stamper engaged in fraudulent conduct resulting in damages to Plaintiffs in the amount of $465,000.00. 14. On October 16, 2025, in Case No. CJ-2022-168 styled White Rock Energy, LLC and White Rock Oil & Gas, LLC v. Stampede Lift Solutions, LLC and Jonathan Stamper, the District Court of Garvin County, State of Oklahoma, entered judgment in favor of Plaintiffs and against Mr. Stamper in the amount of $465,000.00 (the “Judgment”). 15. On October 27, 2025, Plaintiffs recorded a Statement of Judgment with the McClain County Clerk at Book 3039, Page 637-638. 16. Plaintiffs are creditors of Mr. Stamper within the meaning of 24 O.S. § 113(4). 17. Mr. Stamper is a debtor of Plaintiffs within the meaning of 24 O.S. § 113(6). B. The Settlement Agreement and Breach 18. Prior to the entry of the Judgment, Mr. Stamper and Plaintiffs entered into a Settlement Agreement pursuant to which Mr. Stamper agreed to pay Plaintiffs the amount $465,000.00. 19. Mr. Stamper breached the Settlement Agreement by failing to make any attempt to make payment required thereunder and Judgement was entered in favor of Plaintiff in the amount of $465,000.00, together with post-judgment interest and reasonable attorney's fees and costs C. Mr. Stamper's History of Fraudulent Conduct 20. Mr. Stamper’s breach of the Settlement Agreement was not an isolated act of noncompliance but is rather the latest episode in a sustained pattern of fraudulent conduct documented by the Garvin County District Court across the full course of the underlying litigation. 21. On October 27, 2025, Mr. Stamper, through new counsel, filed a Motion to Reconsider or Modify Judgment, asserting that he never authorized or signed the Settlement Agreement and that his prior counsel had entered into it without his approval and forged his signature – notwithstanding that the Settlement Agreement had been negotiated over weeks, executed in writing, agreed to by defense counsel of record, and expressly referenced in communications with the Court. 22. On December 1, 2025, the Court held a hearing on the Motion to Reconsider and announced that it would conduct an evidentiary hearing requiring Mr. Stamper’s personal appearance. The Court recessed to allow Mr. Stamper’s counsel to confirm the proposed hearing date and time with Mr. Stamper directly. Mr. Stamper lodged no objection. 23. At that same hearing on December 1, 2025, Mr. Stamper’s counsel presented the Court and Plaintiffs’ counsel with a document entitled “Dismissal with Prejudice” bearing a Garvin County Court Clerk file stamp and a purported signature of Plaintiffs’ counsel, which on its face purported to dismiss with prejudice all claims against Mr. Stamper. The document had never been filed with the Garvin County Court Clerk. Plaintiffs’ counsel denied ever having signed or executed it. When questioned about the document’s origins, Mr. Stamper’s counsel stated that he had received it from his client, Mr. Stamper. The “file stamped” Dismissal with Prejudice was fraudulently created by Stamper. 24. The evidentiary hearing came before the Court on December 29, 2025. Mr. Stamper failed to appear. His counsel represented to the Court that Mr. Stamper was presently undergoing emergency surgery for kidney stones and could not appear at the hearing. His counsel them submitted as evidence a letter purportedly from Norman Urology Associates, dated that same day and authored by Lara Green, P.A.. 25. With the agreement of all parties, the Court took a brief recess and contacted Norman Urology Associates directly. The receptionist confirmed that Mr. Stamper had not been seen at the facility since July, that he was not currently being treated there, and that Lara Green, P.A. had not been employed at the facility for approximately two months. The letter presented to the Court by Mr. Stamper was fabricated. 26. On December 30, 2025, the Court entered an Order for Show Cause pursuant to 12 O.S. § 2011(C), ordering Mr. Stamper’s counsel to show cause why he should not be sanctioned for presenting fabricated and false documents to the Court on behalf of his client after having notice of Mr. Stamper’s prior fraudulent conduct in the case. In that Order, the Court documented Mr. Stamper’s history of fraudulent conduct in the underlying litigation, including the following: a. Mr. Stamper responded to Plaintiffs’ initial Motion for Summary Judgment with a sworn Motion to Dismiss asserting that he had never been served with the Petition. Plaintiffs’ process server appeared with photographic evidence depicting service of Mr. Stamper, and the claim was abandoned. b. On July 25, 2023, Stampede Lift Solutions, LLC – a company previously owned and operated by Mr. Stamper – attached fabricated bills of lading, a fabricated invoice, and a forged or fabricated affidavit of Justin Clifton to its Response to Plaintiffs’ Motion for Summary Judgment. The affidavit had been notarized by Mrs. Stamper. The fraudulent documents were subsequently withdrawn. c. On January 29, 2024, Stampede provided invoices from a company called “Titan Transport” to support its counterclaims for setoff. Upon inquiry by Plaintiffs, it was determined that Titan Transport’s listed address was a mailbox at a UPS Store in Norman, Oklahoma that had been opened by Mrs. Stamper in October 2023 – just four days before Stampede’s request for setoff. The invoices, however, had been fraudulently created and were retroactively back-dated. d. Several matters arising from the foregoing fraudulent conduct by Mr. Stamper remain under advisement by the Garvin County District Court. 27. Mr. Stamper’s sustained pattern of fraudulent conduct – spanning the underlying dispute, the subsequent litigation, and his dealings with his creditors – is directly relevant to the claims asserted herein. It reflects Stamper’s deliberate and ongoing intent to hinder, delay, and defraud his creditors by any means available, including the transfer and concealment of assets as described below. D. The Subject Property and Insider Relationship 28. Mr. and Mrs. Boling are the record owners of real property legally described as follows: A part of the Northeast Quarter (NE/4) of Section Thirty-Five (35), Township Eight (8) North, Range Three (3) West, McClain County, Oklahoma, more particularly described as follows: Beginning at a point S00°2'12"E (assumed bearing) of the NE/Cornor of said Section a distance of 2346.70 feet along the East Section line to the point of beginning; thence S00°02'12"E a distance of 303.74; thence N89°54'13"W a distance of 1321.20 feet; thence N00°10'59"E a distance of 300.84 feet; thence N89°54'13"W a distance of 1321.20 feet to the point of beginning; also described as 1766 S. Main Avenue, Washington, Oklahoma, (the “Subject Property”). 29. Upon information and belief, Mr. and Mrs. Boling acquired the Subject Property via Warranty Deed recorded January 25, 2006, at Book 1779, Page 549, McClain County Clerk's Office. 30. Upon information and belief, the Subject Property was valued at approximately $100,000.00 at the time of acquisition in 2006, exclusive of any improvements. 31. According to records maintained by the McClain County Assessor, the Subject Property currently carries a Total Estimated Market Value of $1,152,842.00, of which $1,063,842.00 is attributable to improvements. The land value exclusive of improvements is estimated at $89,000.00 – approximately consistent with the acquisition price paid by Mr. and Mrs. Boling in 2006. Accordingly, the improvement value reflected in the County Assessor’s records represents an increase of approximately $1,063,842.00 over the baseline land value, substantially all of which, upon information and belief, is attributable to the improvement expenditures made by Mr. Stamper as described herein. 32. Mr. and Mrs. Boling are the parents of Mrs. Stamper and parents-in-law of Mr. Stamper. As such, Mr. and Mrs. Boling qualify as “insiders” with respect to Mr. Stamper within the meaning of 24 O.S. § 113(7)(a). 33. Upon information and belief, at all times relevant hereto, Mr. and Mrs. Stamper have resided on the Subject Property. E. Mr. Stamper’s Pattern of Transferring Assets to Insiders 34. Consistent with his broader pattern of fraudulent conduct and asset concealment described above, Mr. Stamper has engaged in a deliberate course of transferring and concealing assets by placing them in the names of family members and other insiders (including his wife’s parents) without receiving reasonably equivalent value in return, for the purpose of placing those assets beyond the reach of his creditors. 35. For example, on July 1, 2021, Mr. Stamper executed a Quit Claim Deed conveying real property located in Garvin County, Oklahoma, legally described as follows: A part of the NE/4 NE/4 of Section 9, Township 4 North, Range 4 West of the I.B.M, Garvin County, Oklahoma, being more particularly described as follows: Beginning 326.00 feet N00°18′49″W and 321.87 feet S89°57′11″W a distance of 706.04 feet of the Southeast corner of the NE/4 NE/4 of said section; thence S89°57′11″W a distance of 706.04 feet; thence N00°04′13″E a distance of 632.60 feet; thence S80°58′48″E a distance of 143.21 feet; thence S00°04′13″W a distance of 102.18 feet; thence S82°05′50″E a distance of 566.99 feet; thence S00°18′49″E a distance of 429.45 feet to the Point of Beginning to Mr. Boling, which deed was recorded in the Garvin County Clerk's Office, Book 2352, Page 475 (the “2021 Deed Transfer”). 36. Upon information and belief, Mr. Stamper did not receive reasonably equivalent value in exchange for the 2021 Deed Transfer. 37. Upon information and belief, the 2021 Deed Transfer was for the purpose of and was a part of Stamper’s broader pattern of asset concealment described herein and constitutes circumstantial evidence of Mr. Stamper’s intent to place assets beyond the reach of his creditors. To the extent the facts and circumstances establish that the 2021 Deed Transfer was made with actual intent to hinder, delay, or defraud any creditor within the meaning of 24 O.S. § 116(A)(1), Plaintiffs assert such claim in Count I below. F. The Fraudulent Improvement Expenditures 38. Upon information and belief, Mr. Stamper expended substantial sums of money to construct improvements on the Subject Property (property owned of record by his in-laws, Mr. and Mrs. Boling), including but not limited to the construction of a residence, swimming pool, barns, stables, fencing, gates, and related improvements (the “Improvement Expenditures”). The Improvement Expenditures are believed to be part of the broader pattern of asset concealment described herein. FIRST CAUSE OF ACTION (Fraudulent Transfer – Actual Intent 24 O.S. § 116(A)(1)) 39. Plaintiffs incorporate by reference the allegations of Paragraphs 1 through 38 as if fully set forth herein. 40. Pursuant to 24 O.S. § 116(A)(1), a transfer made by a debtor is fraudulent as to a creditor, whether the creditor’s claim arose before or after the transfer was made, if the debtor made the transfer with actual intent to hinder, delay, or defraud any creditor of the debtor. 41. Upon information and belief, each of the Improvement Expenditures constitutes a "transfer" within the meaning of 24 O.S. § 113(12) and was made by Mr. Stamper with actual intent to hinder, delay, or defraud his creditors, including Plaintiffs. To the extent the facts and circumstances support such a finding, the 2021 Deed Transfer was likewise made with actual intent to hinder, delay, or defraud creditors. 42. Mr. Stamper’s actual intent is established not only by the badges of fraud enumerated below, but by his court-documented history of fraudulent conduct described in Paragraphs 18 through 27 above, which reflects a pervasive and deliberate pattern of deception and asset concealment directed at evading accountability to his creditors – a pattern of which the transfers described herein are a direct continuation. 43. In determining actual intent under 24 O.S. § 116(A)(1), the Court may consider the circumstances surrounding a transfer, including the factors enumerated in 24 O.S. § 116(B). The following factors are present here and constitute badges of fraud supporting a finding of actual intent: a. Transfer to an insider (24 O.S. § 116(B)(1)): Upon information and belief, the Improvement Expenditures were made to and for the benefit of Mr. and Mrs. Boling, who are insiders within the meaning of 24 O.S. § 113(7)(a) by virtue of their familial relationship with Mr. Stamper, and to and for the benefit of Mrs. Stamper, who is an insider as Mr. Stamper’s spouse. Upon information and belief, the 2021 Deed Transfer was likewise made directly to Mr. Boling as an insider. Mr. Stamper’s consistent practice of directing assets to family members without receiving reasonably equivalent value in return reflects a deliberate strategy of placing assets beyond the reach of creditors through insider transfers. b. Retention of possession and control (24 O.S. § 116(B)(2)): Upon information and belief, following both the 2021 Deed Transfer and the Improvement Expenditures, Mr. Stamper retained possession of and continued to reside on and use the Subject Property, exercising effective dominion over the improved property despite holding no record ownership interest therein. This pattern – transferring legal title or expending funds while retaining the practical benefits of ownership – is a hallmark of fraudulent asset concealment. c. Pendency of litigation and existence of debt (24 O.S. § 116(B)(4)): Upon information and belief, the Improvement Expenditures were made after Mr. Stamper incurred substantial obligations to Plaintiffs arising from his fraudulent conduct in August 2022, and after Plaintiffs initiated legal proceedings against Mr. Stamper to recover the resulting damages. d. Lack of reasonably equivalent value (24 O.S. § 116(B)(8)): Upon information and belief, Mr. Stamper did not receive reasonably equivalent value in exchange for the Improvement Expenditures or the 2021 Deed Transfer within the meaning of 24 O.S. § 115. Mr. Stamper received no ownership interest in the Subject Property and no other consideration of equivalent value in return for the funds expended or the property conveyed. e. Insolvency (24 O.S. § 116(B)(9)): Upon information and belief, Mr. Stamper became insolvent, or his insolvency was materially deepened, as a result of the Improvement Expenditures and the 2021 Deed Transfer, in that the diversion of substantial assets to insider-owned property left him unable to satisfy his outstanding obligations to creditors within the meaning of 24 O.S. § 114. In the alternative, upon information and belief, Mr. Stamper was already insolvent at the time of one or more of the Improvement Expenditures in that the sum of his debts exceeded the fair value of his remaining assets. f. Transfer shortly after incurring substantial debt (24 O.S. § 116(B)(10)): Upon information and belief, the Improvement Expenditures were made shortly after Mr. Stamper incurred obligations to Plaintiffs in the amount of $465,000.00 arising from his fraudulent conduct in August 2022, such that the transfers occurred in close temporal proximity to the incurrence of a substantial debt. g. Concealment of assets (24 O.S. § 116(B)(7)): By directing assets toward insider-owned real property – and by conveying real property to an insider via the 2021 Deed Transfer – Mr. Stamper is believed to have concealed assets from his creditors by converting them into property he did not own and in which he held no record interest. This conduct is consistent with and a continuation of Mr. Stamper’s broader court-documented pattern of fraudulent evasion described herein. 44. By reason of the foregoing, the Improvement Expenditures – and, to the extent the Court so finds, the 2021 Deed Transfer – are voidable as to Plaintiffs pursuant to 24 O.S. § 119(A). Plaintiffs are entitled to avoidance of the transfers to the extent necessary to satisfy the Judgment, an attachment or levy on the Subject Property, an injunction against further disposition of the Subject Property, and any other relief the Court deems appropriate under 24 O.S. § 119. SECOND CAUSE OF ACTION (Fraudulent Transfer – Constructive Fraud (24 O.S. §§ 116(A)(2), 117)) 45. Plaintiffs incorporate by reference the allegations of Paragraphs 1 through 44 as if fully set forth herein. 46. This Cause is pleaded in the alternative to the First Cause and is not intended as an admission that Plaintiffs’ claim for actual fraudulent transfer is unavailable. 47. Under 24 O.S. § 116(A)(2), a transfer is fraudulent as to a creditor whose claim arose before the transfer was made if the debtor made the transfer without receiving reasonably equivalent value in exchange and the debtor was insolvent at that time or became insolvent as a result of the transfer. Under 24 O.S. § 117(A), a transfer is independently fraudulent as to a creditor whose claim arose before the transfer was made if the debtor made the transfer to or for the benefit of an insider for an antecedent debt, the debtor was insolvent at the time, and the insider had reasonable cause to believe that the debtor was insolvent. 48. Plaintiffs’ claim against Mr. Stamper arose on or about August 2022 and was reduced to the Judgment on October 16, 2025. However, his scheme to defraud Plaintiffs began in February 2022. To the extent any of the Improvement Expenditures were made after August 2022, Plaintiffs were present creditors with respect to those transfers within the meaning of 24 O.S. § 116(A)(2), and the constructive fraud theories asserted in this Count apply to those transfers accordingly. To the extent any of the Improvement Expenditures were made before August 2022, such transfers are addressed under First Cause of Action actual intent theory, which extends to transfers made with intent to hinder, delay, or defraud any creditor whether the creditor’s claim arose before or after the transfer was made. 24 O.S. § 116(A)(1). 49. Lack of Reasonably Equivalent Value. Upon information and belief, Mr. Stamper expended substantial funds to construct improvements on and maintain the Subject Property without receiving any ownership interest in the Subject Property or any other reasonably equivalent value in return within the meaning of 24 O.S. § 115. The sole beneficiaries of the Improvement Expenditures were Mr. and Mrs. Boling as record owners of the Subject Property and Mrs. Stamper as a resident and occupant thereof. 50. Insolvency. Upon information and belief, Mr. Stamper became insolvent, or his insolvency was materially deepened, as a result of the Improvement Expenditures, in that the diversion of substantial assets to insider-owned property left him unable to satisfy his outstanding obligations to creditors within the meaning of 24 O.S. § 114. In the alternative, upon information and belief, Mr. Stamper was already insolvent at the time of one or more of the Improvement Expenditures in that the sum of his debts exceeded the fair value of his remaining assets. 51. Transfer to Insider. The Improvement Expenditures were made to and for the benefit of Mr. and Mrs. Boling and Mrs. Stamper as insiders within the meaning of 24 O.S. § 113(7). To the extent the Improvement Expenditures were made on account of any antecedent obligation owed by Mr. Stamper to any of the foregoing insiders, such transfers are independently voidable under 24 O.S. § 117(A). Upon information and belief, Mr. and Mrs. Boling and Mrs. Stamper had reasonable cause to believe that Mr. Stamper was insolvent at the time of the Improvement Expenditures, given their close familial relationships with Mr. Stamper and their direct receipt of the benefits of those expenditures. 52. By reason of the foregoing, the Improvement Expenditures are fraudulent and voidable as to Plaintiffs pursuant to 24 O.S. § 119(A), and Plaintiffs are entitled to avoidance of the transfers to the extent necessary to satisfy the Judgment, together with all other remedies available under 24 O.S. § 119. THIRD CAUSE OF ACTION (Constructive Trust / Equitable Lien) 53. Plaintiffs incorporate by reference the allegations of Paragraphs 1 through 52 as if fully set forth herein. 54. This Cause is pleaded in the alternative to, and in conjunction with, the First and Second Causes, and is not intended as an admission that Plaintiffs’ claims under the Oklahoma Uniform Fraudulent Transfer Act are unavailable. 55. As set forth above, Mr. Stamper is believed to have expended substantial funds to construct improvements on the Subject Property owned of record by Mr. and Mrs. Boling, as part of a deliberate pattern of diverting and hiding assets to insider-owned property without receiving reasonably equivalent value in return. Upon information and belief, these expenditures were made without Mr. Stamper receiving any ownership interest or other reasonably equivalent value. The Improvement Expenditures materially and substantially increased the fair market value of the Subject Property for the benefit of Mr. and Mrs. Boling. 56. Under these circumstances, Mr. and Mrs. Boling hold legal title to the Subject Property – specifically, the portion of its value attributable to the Improvement Expenditures – as constructive trustees for the benefit of Plaintiffs. To permit Mr. and Mrs. Boling to retain that value free and clear of Plaintiffs’ claims would be inequitable and unconscionable. 57. Plaintiffs are therefore entitled to the imposition of a constructive trust on the Subject Property to the extent of the value of the improvements funded by Mr. Stamper, and to an order directing Mr. and Mrs. Boling to account for and convey or satisfy that interest because it is inequitable under the circumstances to permit the legal titleholder to retain the property. 58. In the alternative, and to the extent a constructive trust is not imposed, Plaintiffs are entitled to the imposition of an equitable lien on the Subject Property. An equitable lien may be imposed where a party has expended funds to improve property owned by another under circumstances where it would be inequitable for the property owner to retain the benefit of those improvements without compensating the party whose funds were used. 59. Upon information and belief, Mr. Stamper’s expenditure of substantial funds to hide them from his creditors for the benefit Mr. and Mrs. Boling – insiders who provided no reasonably equivalent value in return – resulted in a direct and traceable enhancement of the fair market value of the Subject Property. Equity therefore requires the imposition of an equitable lien on the Subject Property in favor of Plaintiffs in an amount equal to the increase in fair market value of the Subject Property attributable to the Improvement Expenditures, to be determined at trial. 60. Upon information and belief, Mr. Stamper did not receive reasonably equivalent value in exchange for the property conveyed by the 2021 Deed Transfer, and Mr. Boling received the benefit of that conveyance without providing reasonably equivalent value in return. Plaintiffs are therefore entitled, to the extent the 2021 Deed Transfer is found to have been made without the receipt of reasonable equivalent value, an order directing Mr. Boling to account for and convey or satisfy Plaintiffs' interest therein. In the alternative, Plaintiffs are entitled to the imposition of an equitable lien on such property in an amount equal to the fair market value thereof, to be determined at trial. FOURTH CAUSE OF ACTION (Unjust Enrichment) 61. Plaintiffs incorporate by reference the allegations of Paragraphs 1 through 60 as if fully set forth herein. 62. This Cause is pleaded in the alternative to the First, Second, and Third Causes, and is not intended as an admission that Plaintiffs’ claims under the Oklahoma Uniform Fraudulent Transfer Act or Plaintiffs’ claims for constructive trust or equitable lien are unavailable. Pursuant to 12 O.S. § 2008(E), Plaintiffs are entitled to plead alternative and inconsistent claims, and nothing in this Count shall be construed as an admission inconsistent with the allegations set forth in any other Count. While the Third Cause seeks the imposition of a constructive trust or equitable lien on the Subject Property as an in rem remedy, this Count seeks a personal money judgment against Defendants Wilford Steve Boling, Sharon Boling, and Arica Sharee Stamper for the value of the benefit each has received, and is pleaded in the alternative to and as a supplement to the Third Cause to the extent that the in rem relief sought therein proves unavailable, insufficient, or otherwise inadequate to satisfy the Judgment. FIFTH CAUSE OF ACTION (Declaratory Judgment and Injunctive Relief) 63. Plaintiffs incorporate by reference the allegations of Paragraphs 1 through 62 as if fully set forth herein. 64. An actual, present, and justiciable controversy exists between Plaintiffs and Defendants concerning the rights of the parties with respect to the Subject Property and the Improvement Expenditures made thereon. 65. Pursuant to 12 O.S. §§ 1651 et seq. (the “Declaratory Judgment Act”), Plaintiffs are entitled to a declaration that: a. The Improvement Expenditures constitute voidable transfers within the meaning of 24 O.S. § 116(A)(1) and/or § 116(A)(2); b. The Improvement Expenditures constituted transfers of Mr. Stamper’s assets to insider-owned property without reasonably equivalent value being received in return, as part of a deliberate pattern of asset concealment; and c. Plaintiffs hold an equitable interest in the Subject Property to the extent of the increase in fair market value attributable to the Improvement Expenditures. 66. To the extent the Court finds that the 2021 Deed Transfer was made with actual intent to hinder, delay, or defraud creditors within the meaning of 24 O.S. § 116(A)(1), Plaintiffs are further entitled to a declaration that the 2021 Deed Transfer is void and of no effect as to Plaintiffs. 67. Pursuant to 24 O.S. § 119(A)(3)(a), Plaintiffs are entitled to an injunction restraining Defendants, and each of them, from transferring, conveying, encumbering, mortgaging, leasing, or otherwise disposing of the Subject Property, or any interest therein, pending resolution of this action and satisfaction of the Judgment. 68. Plaintiffs have no adequate remedy at law. Absent injunctive relief, and in light of Mr. Stamper’s court-documented history of fraudulent conduct and asset concealment, there is a substantial and imminent risk that Defendants will transfer, encumber, or otherwise dispose of the Subject Property, rendering any judgment in Plaintiffs’ favor uncollectable and causing Plaintiffs irreparable harm. PRAYER FOR RELIEF WHEREFORE, Plaintiffs respectfully request that this Court enter judgment in their favor and against Defendants as follows: 1. Declaring the Improvement Expenditures to be voidable transfers pursuant to 24 O.S. § 119(A) and avoiding the same to the extent necessary to satisfy the Judgment and all amounts owed to Plaintiffs under the Settlement Agreement; 2. To the extent the Court finds the 2021 Deed Transfer was made with actual intent to hinder, delay, or defraud creditors, declaring the 2021 Deed Transfer void and of no effect as to Plaintiffs and avoiding the same pursuant to 24 O.S. § 119(A); 3. Imposing a constructive trust on the Subject Property to the extent of the increase in fair market value attributable to the Improvement Expenditures, and ordering Mr. and Mrs. Boling to account for and convey or satisfy Plaintiffs’ interest therein; 4. In the alternative, impressing an equitable lien on the Subject Property in favor of Plaintiffs in an amount equal to the increase in fair market value of the Subject Property attributable to the Improvement Expenditures, to be determined at trial; 5. Entering judgment against Mr. and Mrs. Boling, jointly and severally, and against Mrs. Stamper, for unjust enrichment in amounts to be determined at trial, not to exceed the amount of the Judgment remaining unsatisfied together with accruing interest; 6. To the extent the Court finds the 2021 Deed Transfer voidable, entering judgment against Mr. Boling for unjust enrichment in an amount equal to the lesser of the fair market value of the property conveyed thereby or the amount of the Judgment remaining unsatisfied, to be determined at trial; 7. Enjoining Defendants, and each of them, from transferring, conveying, encumbering, mortgaging, leasing, or otherwise disposing of the Subject Property or any interest therein, pending resolution of this action and full satisfaction of the Judgment and all amounts owed under the Settlement Agreement; 8. Awarding Plaintiffs prejudgment and post-judgment interest on all amounts owed, including interest accruing from the date payment was due under the Settlement Agreement until the date of full satisfaction, at the applicable statutory rate or at the rate provided in the Settlement Agreement, whichever is greater; 9. Awarding Plaintiffs their reasonable attorney's fees incurred in connection with this action and in enforcing their rights under the Settlement Agreement, pursuant to the terms of the Settlement Agreement and applicable Oklahoma law; 10. Awarding Plaintiffs their costs of this action; and 11. Granting such other and further equitable relief as the Court deems just and proper. Respectfully submitted, John R. Arrowood, OBA No. 32346 ARROWOOD LAW GROUP, PLLC Two Leadership Square 211 N. Robinson Ave., Suite 1425 Oklahoma City, OK 73102 Telephone/Facsimile: (405) 754-1133 [email protected] ATTORNEY FOR PLAINTIFFS WHITE ROCK ENERGY, LLC, AND WHITE ROCK OIL & GAS, LLC