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TULSA COUNTY • CJ-2026-889

Union Station South Homeowners Association, Inc. v. Warren S. Clarke

Filed: Feb 25, 2026
Type: CJ
View Official Docket ↗

What's This Case About?

Let’s be real: you don’t expect your homeowners association to go full Scarface on a $2,364.56 bill. But that’s exactly what’s happening in Broken Arrow, Oklahoma, where the Union Station South Homeowners Association, Inc. has pulled out the legal big guns—not just to collect a few months of dues, but to foreclose on a house over what amounts to less than the cost of a decent used car. That’s right—this isn’t a lawsuit for damages, or a demand for yard cleanup. This is a full-blown attempt to take someone’s home because they didn’t pay their HOA fees. And if you think that’s dramatic, just wait—because the defendant, Warren S. Clarke, might not even be alive. Or married. Or reachable. But that’s not stopping the HOA one bit.

So who are these people? On one side, we’ve got the Union Station South Homeowners Association, Inc.—a not-for-profit corporation that, like every HOA since the dawn of suburbia, exists to enforce rules about trash cans, lawn lengths, and, apparently, aggressively pursue debt collection. Their job is to maintain the neighborhood’s curb appeal and common areas, funded by monthly or quarterly assessments from residents. On the other side is Warren S. Clarke, the alleged owner of 512 S. Redwood Avenue, a modest home in a quiet Broken Arrow subdivision. That’s about all we know. The filing is so cautious about Clarke’s status that it lists him as “if living, or the unknown heirs, beneficiaries, successors, executors, administrators, devisees, and assigns, if deceased.” Which, let’s be honest, sounds less like a legal document and more like a Choose Your Own Adventure book written by a paralegal. His spouse? “If any.” The occupants of the house? Just “Occupants.” It’s like the HOA is suing a ghost—or a whole haunted house full of legal phantoms.

Now, here’s how we got here. At some point, Warren S. Clarke (or whoever was responsible for the property) stopped paying the HOA dues. According to the claim, as of February 18, 2026, the total past-due balance was $2,364.56. That number includes $804 in unpaid assessments, $30.36 in interest, $85 in “other charges,” and—wait for it—$800 in attorney fees and collection costs. Yes, you read that right: the legal bill to collect under $920 in actual assessments and interest is nearly double the original debt. And while late fees are listed at $0.00 (bless their hearts), the HOA tacks on future assessments, more interest, and even more attorney fees that will keep piling up “during the pendency of this action.” So, the longer this drags on, the more Clarke allegedly owes—even if he’s already moved out, passed away, or never knew about the lawsuit in the first place.

The legal move here is a petition for foreclosure of an owner’s association lien. In plain English? The HOA is saying, “You didn’t pay your dues, so we put a lien on your house. Now, since you still haven’t paid, we want the court to force a sale of the property to cover what you owe.” It’s not uncommon—HOAs in many states have the legal right to place liens and even foreclose over unpaid fees. But here’s the kicker: in Oklahoma, HOA liens are generally junior to mortgage liens. That means if the house is sold, the mortgage lender (in this case, Associated Mortgage Corporation, represented by MERS—the mysterious Mortgage Electronic Registration Systems, Inc.) gets paid first. Only whatever’s left goes to the HOA. Given that houses in this part of Broken Arrow are worth well over $150,000, it’s unlikely the HOA will get stiffed entirely—but they’re not just after the money. They want the court to wipe out all competing claims to the property, including from the mortgage holder, the spouse (if there is one), and literally anyone else living there. They’re not just chasing a debt—they’re trying to legally erase everyone’s rights to this house, just in case someone shows up later saying, “Uh, that’s my house?”

And what do they want? $2,364.56—plus more. They’re asking for a personal judgment against Clarke (or his estate), meaning he could be on the hook for the debt even if the house sells for nothing. They also want the property sold at auction, the proceeds applied to the judgment, and any leftover cash held by the court (because, of course, they can’t just hand it back to the homeowner—no, it must abide). They want attorney fees, court costs, interest, and a formal declaration that their lien is valid and superior. All of this over a sum that, in the grand scheme of real estate, is basically pocket lint. For context: the average HOA fee in the U.S. is around $300 a month. This debt represents about eight months of dues. Eight months. Not eight years. Not a decade of defiance. Eight months of non-payment, and we’re at foreclosure.

Now, here’s our take: the most absurd part of this case isn’t even the amount. It’s the theater of it all. The HOA filed a lawsuit listing five defendants, including “the spouse of Warren S. Clarke, if any,” and “the occupants of the premises,” who could be tenants, relatives, or a family of raccoons for all we know. They’re dragging Mortgage Electronic Registration Systems, Inc.—a notorious, often criticized nominee entity used in mortgage servicing—into a fight over lawn maintenance fees. They sent a debt collection notice citing the Fair Debt Collection Practices Act… in a lawsuit. It’s like they’re trying to scare everyone away with legal fireworks, hoping someone will just pay up to make it stop.

And let’s talk about that $800 attorney fee. For a standard foreclosure petition? That’s… aggressive. It suggests the HOA isn’t just trying to recover costs—it’s using legal pressure as a tool. Maybe they’re hoping Clarke (or his heirs) will see this nuclear option and say, “Fine, here’s $2,400, just leave us alone.” And honestly? That’s probably what will happen. Because going to trial over this would cost everyone more than the debt itself.

Do we think the HOA is wrong to collect what’s owed? Not necessarily. Dues keep the lights on, the grass mowed, the playground safe. But when the cure is worse than the disease—when you’re threatening to take a home over a debt smaller than a security deposit—we have to ask: who’s really being served here? The community? Or just the lawyers?

We’re rooting for common sense. For a phone call instead of a foreclosure. For an HOA that remembers it’s supposed to be a homeowners association, not a debt collection cartel. But hey—this is civil court. And in the world of petty disputes, sometimes the smallest debts come with the biggest drama.

Case Overview

$2,365 Demand Petition
Jurisdiction
District Court of Tulsa County, Oklahoma
Filing Attorney
Timothy D. Geary
Relief Sought
Injunctive Relief
Plaintiffs
Defendants
Claims
# Cause of Action Description
1 petition for foreclosure of owner's association lien plaintiff seeks to foreclose on defendant's property due to unpaid assessments and fees

Petition Text

2,078 words
IN THE DISTRICT COURT OF TULSA COUNTY STATE OF OKLAHOMA UNION STATION SOUTH HOMEOWNERS ASSOCIATION, INC., an Oklahoma Not for Profit Corporation; Plaintiff, vs. WARREN S. CLARKE, if living, or the unknown heirs, beneficiaries, successors, executors, administrators, devisees, and assigns, if deceased; SPOUSE OF WARREN S. CLARKE, if any, if living, or the unknown heirs, beneficiaries, successors, executors, administrators, devisees, and assigns, if deceased; MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., as Nominee for Associated Mortgage Corporation; ASSOCIATED MORTGAGE CORPORATION; OCCUPANTS OF THE PREMISES AT 512 S REDWOOD AVE., BROKEN ARROW, OK 74012; Defendants. PETITION FOR FORECLOSURE OF OWNERS ASSOCIATION LIEN Plaintiff, UNION STATION SOUTH HOMEOWNERS ASSOCIATION, INC., an Oklahoma Not for Profit Corporation, alleges and states as follows: 1. That the Plaintiff is an Oklahoma not for profit corporation with its principal place of business in Tulsa County, Oklahoma. 2. That Plaintiff did timely file the Deed of Dedication and Restrictive Covenants of Union Station South with the County Clerk for Tulsa County, Oklahoma on December 3, 1992, as Instrument Number 4914 and Document Number 92108391; the same is hereby incorporated by reference and made a part hereof as if fully set forth hereafter (hereinafter "Governing Documents"). 3. That Defendant WARREN S. CLARKE, if living, or the unknown heirs, beneficiaries, successors, executors, administrators, devisees, and assigns, if deceased, is the record owner of the Property (the “Property”) that is the subject matter of this action, the same being legally described in Exhibit “A”. 4. That pursuant to the terms of the Governing Documents, Defendant WARREN S. CLARKE, if living, or the unknown heirs, beneficiaries, successors, executors, administrators, devisees, and assigns, if deceased, did become indebted to Plaintiff for assessments for common expenses incurred by Plaintiff pursuant to the Governing Documents. 5. That Defendant WARREN S. CLARKE, if living, or the unknown heirs, beneficiaries, successors, executors, administrators, devisees, and assigns, if deceased, has failed to pay the assessments and other charges levied against the Property as they came due. As of February 18, 2026, Defendant owes a past-due balance of $2,364.56, together with all additional assessments, late fees, interest, attorney fees, special assessments, and other charges that continue to accrue under the Governing Documents during the pendency of this action and other charges commencing to be due and owing the aforementioned dates. 6. That pursuant to Title 60 O.S.A. §851, et seq, and the Governing Documents, Plaintiff filed its assessment lien against the Subject Property for past due assessments chargeable against Defendant WARREN S. CLARKE, if living, or the unknown heirs, beneficiaries, successors, executors, administrators, devisees, and assigns, if deceased, and said lien being recorded with the County Clerk for Tulsa County, on September 19, 2025, as Document Number 2025083397, a copy of said lien is attached hereto as Exhibit “B”, and made a part hereof by reference. 7. That pursuant to Title 60 O.S.A. §851, et seq, the Governing Documents, and other applicable Oklahoma law, Plaintiff has the right to bring this action for foreclosure to recoup all unpaid dues, assessments, interest, and other charges owed by Defendant WARREN S. CLARKE, if living, or the unknown heirs, beneficiaries, successors, executors, administrators, devisees, and assigns, if deceased, including reasonable attorney fees and costs. 8. That Defendant WARREN S. CLARKE, if living, or the unknown heirs, beneficiaries, successors, executors, administrators, devisees, and assigns, if deceased, may claim some right, title, or interest in and to the Property. Plaintiff states, however, that any such right, title, or interest claimed by Defendant is subordinate and inferior to the lien of Plaintiff, and Plaintiff petitions the Court that Defendant be summoned in this case and be required to set up in this suit any right, title, or interest said Defendant may have, or claim to have, in and to the Property, or be forever barred from claiming any such right, title, or interest in and to the Property. 9. That Defendant SPOUSE OF WARREN S. CLARKE, if any, if living, or the unknown heirs, beneficiaries, successors, executors, administrators, devisees, and assigns, if deceased, may claim some right, title, or interest in and to the Property. Plaintiff states, however, that any such right, title, or interest claimed by Defendant is subordinate and inferior to the lien of Plaintiff, and Plaintiff petitions the Court that Defendant be summoned in this case and be required to set up in this suit any right, title, or interest said Defendant may have, or claim to have, in and to the Property, or be forever barred from claiming any such right, title, or interest in and to the Property. 10. That Defendant MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., as Nominee for Associated Mortgage Corporation, may have a prior and superior lien to the lien of Union Station South Homeowners Association, Inc. upon the Property, which was recorded on November 23, 2022, with the County Clerk of Tulsa County, Oklahoma, as Document Number 2022118777, and has not subsequently been released. 11. That the Defendant ASSOCIATED MORTGAGE CORPORATION, may have a prior and superior lien to the lien of Union Station South Homeowners Association, Inc. upon the Property, which was recorded on November 23, 2022, with the County Clerk of Tulsa County, Oklahoma, as Document Number 2022118777, and has not subsequently been released. 12. That Defendant OCCUPANTS OF THE PREMISES AT 512 S REDWOOD AVE., BROKEN ARROW, OK 74012, may claim some right, title, or interest in and to the Property. Plaintiff states, however, that any such right, title, or interest claimed by Defendant is subordinate and inferior to the lien of Plaintiff, and Plaintiff petitions the Court that Defendant be summoned in this case and be required to set up in this suit any right, title, or interest said Defendant may have, or claim to have, in and to the Property, or be forever barred from claiming any such right, title, or interest in and to the Property. 13. That after allowing all just credits, there is due and owing to Plaintiff Union Station South Homeowners Association on the recorded lien, the sum of $2,364.56 as of February 18, 2026. Defendant owes a past-due balance of $2,364.56, representing past-due payments, accrued interest, and other charges, together with ongoing dues, late fees, and interest that will continue to accrue through the date of final disbursement of proceeds in this action. 14. That unless expressly stated otherwise herein, any right, title, or interest claimed by all named Defendants are subordinate and inferior to the lien claimed by Union Station South Homeowners Association, Inc. 15. That Plaintiff has performed all condition precedent to the filing of this Petition including mailing of required notices pursuant to applicable Oklahoma Law and the Governing Documents and is entitled to the relief requested herein. 16. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. In accordance with the Fair Debt Collection Practices Act, Title 15 U.S.C.A. Sec. 1692 (FDCPA), unless the person or entity responsible for the payment of the above debt, within (30) days after service of this pleading, disputes the validity of the debt, or any portion thereof, the debt will be assumed valid. If such person or entity notifies the undersigned attorney for the creditor in writing within said thirty (30) day period that the debt, or any portion thereof, is disputed, said attorney will obtain verification of the debt and a copy of such verification will be mailed to said person or entity by the undersigned attorney for the creditor; and upon written request by you within the thirty (30) day period, the undersigned attorney for the creditor will provide the name and address of the original creditor, if different from the current creditor. WHEREFORE, premises considered, Plaintiff petitions for judgment in personam of and from Defendant, WARREN S. CLARKE, if living, or the unknown heirs, beneficiaries, successors, executors, administrators, devisees, and assigns, if deceased, in the present amount of $2,364.56 as of February 18, 2026, said amount representing the total amount due on the Property for past due assessments, and other charges owing to Plaintiff by Defendant, and for further judgment in personam for such additional amounts representing future assessments, that come due and owing and remain unpaid from and after the dates of each outstanding balance, during the pendency of this action, together with late fees, finance charges, and Plaintiff's reasonable attorney fees and court costs incurred in the prosecution of this action, with interest on all thereof as allowed by law until said judgement is paid in full, for judgement *in rem* of and from all Defendants, and each of them, adjudging the liens of Plaintiff asserted herein to be a valid and subsisting lien against the Property in the amounts petitioned hereunder, and ordering that the liens be foreclosed and the Property be sold, with appraisement, according to law, and the proceeds of said sale to be applied to the payment of the judgement of Plaintiff entered herein, and the balance of said proceeds, if any, to be paid into the Court to abide by the further order of the Court. Plaintiff further prays that upon confirmation of the sale of the Property, the Defendants herein, and each of them, be forever barred, foreclosed, and enjoined from asserting or claiming any right, title, interest, estate, or equity or redemption in and to the Property, and for such other and further relief as this Court may deem equitable and necessary in the premises. Respectfully Submitted: [signature] Timothy D. Geary, OBA No. 36121 *Jones Property Law, PLLC* 517 Liberty Lane, STE 100 Edmond, OK 73034 P: 405-888-2744 E: [email protected] Attorney for Plaintiff EXHIBIT "A" LOT ELEVEN (11), BLOCK SIX (6), UNION STATION SOUTH, AN ADDITION TO THE CITY OF BROKEN ARROW, TULSA COUNTY, STATE OF OKLAHOMA, ACCORDING TO THE RECORDED PLAT THEREOF. 512 S REDWOOD AVE., BROKEN ARROW, OK 74012 EXHIBIT B RECORD AND RETURN TO: Schwartz Vays 7215 NE 4th Ave, #101 Miami, FL 33138 CLAIM OF LIEN BEFORE ME, the undersigned notary public, personally appeared, Antonio Martin, who was duly sworn and says that he/she is the authorized agent of the Lienor. Union Station South Homeowners Association, a Oklahoma not for profit corporation (the “Association”), whose address is 901 N. Forest Ridge Blvd Broken Arrow, OK 74014 and that in accordance with Oklahoma Statutes and the Association’s Declaration, together with all subsequent supplements and amendments thereto (collectively, the “Covenants”), and the articles of incorporation and bylaws of the Association, said Association is owed the following amounts for shares of the common expenses: <table> <tr> <th>Assessments:</th> <td>$804.00</td> </tr> <tr> <th>Interest:</th> <td>$30.36</td> </tr> <tr> <th>Late Fees:</th> <td>$0.00</td> </tr> <tr> <th>Collection Cost and Attorneys fees:</th> <td>$800.00</td> </tr> <tr> <th>Other Charges</th> <td>$85.00</td> </tr> <tr> <th>TOTAL:</th> <th>$1,719.36</th> </tr> </table> plus, interest at the rate of 6 % per annum from the date due until paid. This claim of Lien shall also secure all unpaid assessments, interest, late fees, collection costs and attorney’s fees subsequent to the date of this Claim of Lien and before entry of a certificate of title. The Lienor claims this lien on the following described property Tulsa County, Oklahoma: Property Description: 512 S Redwood Ave Broken Arrow, OK 74012 Folio # 83908-84-08-16430. The record owner(s) of the Subject Property is/are WARREN CLARKE. The amount due to the Lienor remains outstanding as of 9/18/2025.Union Station South Homeowners Association Witness 1: Nellie Maceo Print Name: Nellie Maceo Witness 2: Camila Mora Print Name: Camila Mora By: Antonio Martin Antonio Martin, Authorized Agent of Union Station South Homeowners Association State of Florida County of Miami-Dade The foregoing instrument was acknowledged before me on this 18 day of September, 2025 by Antonio Martin, Authorized Agent of Union Station South Homeowners Association, who [ ] produced ____________________________ as identification or [X] is personally known to me and who did take an oath that the matters contained herein are true and correct. Griffin Thayer Jordan Notary Public, State of Florida at Large LEGAL DESCRIPTION: ALL OF THE FOLLOWING DESCRIBED REAL ESTATE, SITUATED IN THE COUNTY OF TULSA, STATE OF OKLAHOMA, TO-WIT: LOT ELEVEN (11), BLOCK SIX (6), UNION STATION SOUTH, AN ADDITION TO THE CITY OF BROKEN ARROW, TULSA COUNTY, STATE OF OKLAHOMA, ACCORDING TO THE RECORDED PLAT THEREOF. Affidavit of Custodian of Electronic Claim of Lien I, Antonio Martin, do hereby make oath that I am the custodian of the original version of the electronic document tendered for registration herewith, and that this electronic document is a true and exact copy of the original document executed and authenticated according to law on 18 day of September, 2025. Antonio Martin Authorized Agent of Union Station South Homeowners Association 9/18/2025 STATE OF FLORIDA COUNTY OF MIAMI-DADE Sworn to and subscribed before me this 18 day of September, 2025 by Antonio Martin. Griffin Thayer Jordan Notary's Signature My Commission Expires: 8/22/2026
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