Jessica Cox, Trustee of the Cox Revocable Trust v. Skipper A. Davidson and Catrina Davidson

CIVIL COVER SHEET DISTRICT COURT OF OKLAHOMA COUNTY STATE OF OKLAHOMA Case No.: 2026-1034 Plaintiff: Jessica Cox, Trustee of the Cox Revocable Trust Defendant(s): Skipper A. Davidson Catrina Davidson County of Filing: Oklahoma County Case Type (check one): ☒ Contract – Promissory Note / Debt Collection ☐ Tort ☐ Real Property ☐ Domestic Relations ☐ Probate ☐ Other: ________________ Jury Trial Requested: ☐ Yes ☒ No Amount in Controversy: ☒ Over $10,000 ☐ Under $10,000 Related Cases: ☐ Yes ☒ No Attorney Information: Plaintiff is appearing pro se. Certification: I certify that the above information is true and correct to the best of my knowledge. Jessica Cox, Trustee Cox Revocable Trust Date: _____________ IN THE DISTRICT COURT OF OKLAHOMA COUNTY STATE OF OKLAHOMA JESSICA COX, Trustee of the Cox Revocable Trust, Plaintiff, v. Case No.: _______ SKIPPER A. DAVIDSON and CATRINA DAVIDSON, Defendants. PETITION FOR BREACH OF PROMISSORY NOTE AND ACCELERATION OF DEBT COMES NOW Plaintiff, Jessica Cox, Trustee of the Cox Revocable Trust ("Plaintiff"), and for her cause of action against Defendants, Skipper A. Davidson and Catrina Davidson ("Defendants"), alleges and states as follows: 1. Plaintiff is the Trustee of the Cox Revocable Trust and is the holder and obligee of a Promissory Note dated November 7, 2024. 2. Defendants are residents of Oklahoma County, Oklahoma, and venue and jurisdiction are proper in this Court. 3. On or about November 7, 2024, Defendants executed a Promissory Note in favor of Plaintiff in the original principal amount of Ninety Thousand Dollars ($90,000.00), bearing interest at the rate of four percent (4.00%) per annum. 4. Pursuant to the Promissory Note, Defendants were required to make monthly payments of $2,032.11 commencing December 15, 2024, and continuing on the fifteenth (15th) day of each month thereafter. 5. Defendants failed to make payments as required under the Promissory Note and have ceased making payments altogether, thereby constituting an Event of Default under the terms of the Note. 6. Plaintiff provided Defendants with written notice of default and elected to accelerate the Promissory Note pursuant to Sections 6.1, 6.2, and 6.4 thereof. 7. As a result of Defendants’ default, the entire unpaid principal balance, together with all accrued interest, is immediately due and owing. 8. As of the filing of this Petition, Defendants owe Plaintiff no less than Eighty-Six Thousand Six Hundred Fifty Dollars ($86,650.00), plus continuing interest accruing at the contractual rate, attorney’s fees, court costs, and all other amounts recoverable under the Promissory Note. 9. Defendants have failed and refused to pay the accelerated balance despite demand. WHEREFORE, Plaintiff prays for judgment against Defendants, jointly and severally, as follows: A. For the accelerated unpaid principal balance, together with accrued and continuing interest; B. For reasonable attorney’s fees and costs of collection as provided in the Promissory Note; C. For court costs; D. For such other and further relief as the Court deems just and proper. Respectfully submitted, Jessica Cox, Trustee Cox Revocable Trust 2417 Ryder Drive Yukon, Oklahoma 73099 EXHIBIT A Promissory Note dated November 7, 2024 PROMISSORY NOTE THIS PROMISSORY NOTE (hereinafter called "Promissory Note") made and entered into on Seventh day of November, 2024 by and between Skipper A. Davidson and Catrina Davidson (hereinafter called the "Obligor" or "Obligors"), and Jessica Cox, Trustee of the Cox Revocable Trust, dated June 26, 2023, (hereinafter called "Obligee"), each of which are individually hereinafter referred to as a "Party" and collectively as "Parties." Witnesseth: WHEREAS, Obligors is desirous to obtain financing from Obligee for purposes of obtaining a certain business interest (hereinafter called the "Assets"); and WHEREAS, Obligee is desirous to finance the sale and purchase of the Assets as will be paid by Obligors. NOW, THEREFORE, in consideration of their mutual covenants herein contained and for other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, the parties agree as follows: 1 Loan Amount and Period 1.1 Obligee shall sell the Land to Obligors, and Obligors shall purchase the Assets and pay the Obligee the sum of One Hundred Thousand and Dollars and No Cents ($100,000.00). Obligors shall pay to Obligee an initial payment of Ten Thousand Dollars and no Cents ($10,000.00) at Closing (as that term is defined in the Contract for Sale as made and entered into by the Parties) on the Seventh day of November, 2024. Obligors shall pay the remaining balance, as provided herein, of Ninety Thousand Dollars and no Cents ($90,000.00), (hereinafter called the "Principal") at an interest rate of Four percent (4.00%) per annum for the loan. 1.2 Obligors may direct that Obligee make disbursements of the Principal and interest to Obligors, or to Obligors's agent, in one or more payments and in such amounts as the Obligors may direct. 1.3 Obligors shall pay to Obligee the Principal and Interest in the amount of Two Thousand Thirty-Two and 11/100 Dollars ($2,032.11) each month, beginning December 1, 2024 and following installments shall be due and payable on the fifteenth day of each month thereafter for a period of forty-eight (48) months, inclusive. 1.4 Payments shall be due on the fifteenth day of each month and payments and other costs or expenses, then due not paid, in full, on or before 5:00 pm Central Time on the twentieth day of each month shall be subject to a late charge of Five percent (5%) of said payment, and other costs or expenses, in total. 2 Obligors as Parties. Each of Skipper A. Davidson and Catrina Davidson, as an Obligors under the terms of this Agreement shall be deemed to be jointly and severally liable thereto. The Obligee, at the Obligee’s sole discretion, may enforce this Agreement against one or both of them. Communication, negotiations, and Notice, as provided in Section 7, to one of them, as an individual, shall be deemed to have been adequately communicated to the other, and to be sufficient notice to the other of them. 3 Consideration and Security Interest 3.1 This Promissory Note shall be secured by a lien (the "Lien") on all other assets of the Company, including, but not limited to the Land, all improvements, fixtures, income therefrom, proceeds from any of the preceding assets, including all of those Assets (as that term is defined in that certain Contract for Sale and Purchase of Gram's Sweet Treats, LLC, as made and entered into by and between Obligors and Obligee, therein identified as Buyers and as Seller, respectively) and any and all appreciation and increase in value of said real property (collectively, the "Collateral"). 3.2 Obligors shall perform all means necessary to effectuate the immediate and complete perfection of the Lien on the Collateral and cooperate with Obligee to create, enter, and record the Lien, specifically by facilitating the recordation of a lien in the appropriate agency under the Uniform Commercial Code. 3.3 Obligors does hereby irrevocably give to Obligee (including any agent of the Obligee, such as a successor Trustee), a limited durable power of attorney to prepare, file, enter, modify, and amend the Lien with the appropriate recording agency. This power of attorney shall not be affected by subsequent disability or incapacity of the Obligee as principal, or lapse of time, except as otherwise provided herein, but shall be deemed to be a durable power of attorney under the Oklahoma Uniform Durable Power of Attorney Act, 58 O.S. §1071 et seq. This power of attorney shall be in immediate force and effect, and shall not be deemed to be a springing power. This power of attorney shall terminate and shall be revoked without further notice to either party, upon Termination (as defined hereinafter), and upon the complete satisfaction of all terms and conditions of this Promissory Note. 4 Forbearance 4.1 At anytime and from time-to-time during the Term of this Promissory Note, the Obligors may temporarily forbear and refrain (called "Forbearance Period") from submitting installment payments to Obligee. During such period Forbearance Periods, the Obligors will halt all collection measures for the balance of this Promissory Note and shall discontinue enforcement of any provisions of this Promissory Note related to Installment Payments of the balance of the principal, any accrued interest, and all other costs and penalties. 4.2 The Forbearance Period shall be for no greater than thirty (30) days and shall terminate at the end of that time. Thereupon, Obligors shall pay, in full an amount sufficient to bring current the Promissory Note payments, including any then- owing costs or penalties. The Obligors may not exercise the option to forbear payments more than one calendar month, i.e., one installment payment, in a row. 4.3 Obligors shall have the right to forbear the payment of the obligation under this Promissory note by submitting a written notice (by letter or email delivery) at least thirty (30) days prior to the due date of the first monthly installment for which Obligors wishes to invoke the Forbearance Period. Said notice shall include the beginning date and the ending date of the Forbearance Period. Obligors shall thereafter continue submitting the Monthly Installments to Obligee, beginning on the due-date of the Monthly Installment after the expiration of the Forbearance Period. 4.4 Nothing herein shall be deemed to halt or modify the accrual of interest on the Principle during any Forbearance Period, nor shall it alter the Obligors' responsibility to pay any and all costs and penalties then owing. 4.5 Obligors may exercise their right to forbearance of this Promissory Note no more than six (6) instances, during the term of this Agreement. 4.6 Obligee may at anytime, and from time-to-time, extend any additional term or terms of forbearance periods, beyond those allocated to the Obligors as provided in this Section of this Promissory Note. Any such voluntary extensions by the Obligee of additional forbearance periods, shall extend the Term of the Promissory Note, but shall not otherwise modify or alter any other rights or duties of the Obligors. 5 Termination 5.1 This Promissory Note shall terminate upon the occurrence of the following events: (i) the full payment of the Principal to the Obligee and full satisfaction of the Second Note, or (ii) Obligors defaults on payments or terms as provided herein. This Promissory Note shall not be deemed terminated unless adequate notice of termination is made to all parties to this Promissory Note as provided in Section 5. Upon termination of this Promissory Note the full Principal, as defined in Section 1 and Section 2 respectively shall become immediately due and payable to Obligee. 5.2 Obligors may pay the balance of this Promissory Note, including any late charges, at anytime prior the final payment date without penalty. 5.3 Upon the Obligors' satisfaction of all of the terms and conditions of this Promissory Note, including payment in-full of the Principal, Late Fees, and all other costs and expenses owing to the Obligee, then the Obligee shall as soon as practicable, release the Lien with respect to all real and personal property of the Obligors. 6 Default 6.1 The Obligors shall be deemed to be in default upon failure to make any payment due hereunder or for breach of any condition stated herein or upon the filing of an assignment for the benefit of creditors, bankruptcy, or for relief under any provisions of the Bankruptcy Code; or by suffering an involuntary petition in bankruptcy or receivership not vacated within thirty days. In the event this Promissory Note shall be in default, and placed with an attorney for collection, then the Obligors agrees to pay all reasonable attorney fees and costs of collection. 6.2 In the event of default of any payment required under this Note which is not cured within sixty (60) days from the date such payment is due or in the event of any other default under this Note, the Obligee, or any subsequent note holder, may exercise its option to accelerate the entire principal amount outstanding and accrued interest thereon regardless of any prior forbearance, and seek all other remedies and redress permissible under the terms of this Agreement and allowed by law. 6.3 Obligee agrees to notify Obligors of any default in any required payment under this Promissory Note by mailing such notice within fourteen (14) days from the date such payment was due by certified mail addressed to the Obligors at the address stated in Section 5 of this Promissory Note. 6.4 In case of default in any of the terms or conditions of this Promissory Note, Obligors confers upon the Obligee the option of declaring the unpaid balance of the Promissory Note and penalties accrued thereon, together with all sums advanced hereunder, immediately due and payable without notice. 6.5 In case of default in any of the terms or conditions of this Promissory Note, the Obligee may seize, regain control of, and repossess the Assets and any and all of the Collateral, and Obligors shall surrender same to Obligee without further notice. 7 Notice to Parties. All notices, requests, demands, payments, and other communications required or permitted to be given pursuant to this Promissory Note shall be valid if in writing and if delivered personally, or sent by first class mail, postage prepaid and addressed as follows: To Obligors: Skipper A. Davidson and Catrina Davidson 18417 Mesa Road Edmond, Oklahoma 73012 To Obligee: Jessica Cox, Trustee 2417 Ryder Drive Yukon, Oklahoma 73099 8 Severability. If any provision of this Promissory Note shall be held or deemed to be or shall, in fact, be inoperative or unenforceable as applied in any particular case in any jurisdiction or jurisdictions or in all jurisdictions, or in all cases because it conflicts with any other provision or provision hereto for any constitution, or statute or rule of public policy, or for any other reason, such circumstances shall not have the effect of rendering the provision in question inoperative or unenforceable in any other case or circumstance, or of rendering any other provision or provisions herein contained invalid, inoperative, or unenforceable to any extent whatever. 9 Amendments. This Promissory Note may not be modified except in a written instrument signed by the parties. 10 Enforceability. This Promissory Note shall bind and inure to the benefit of the parties hereto and their respective successors, executors, personal representatives and assigns. No party to this Promissory Note may assign its rights or interest hereunder without the prior written consent of each of the other parties. 11 Counterparts. This Promissory Note may be executed simultaneously in two or more counterparts, each of which shall be deemed an original, but all of which taken together shall constitute one and the same document. 12 Construction. This Promissory Note shall be carried out, governed by, and construed in accordance with, the laws of the State of Oklahoma, and the laws of the United States of America. Venue for all actions resulting from default or otherwise arising from the material terms of this Promissory Note shall be the District Court of Oklahoma County, State of Oklahoma. 13 Limitation of Rights. With exception of the rights herein expressly conferred, nothing expressed in this Promissory Note is intended or shall be construed to give to any person or entity other than the parties hereto any legal or equitable right, remedy or claim under or in respect to the Promissory Note or any covenants, Promissory Notes, conditions and provisions herein contained. This Promissory Note and all of the covenants, terms, provisions, conditions, and provisions hereto being intended to be and being the sole exclusive benefit of the Parties hereto. MADE AND ENTERED INTO this Seventh day of November, 2024, Obligors and Obligee have each caused this Promissory Note to be executed, sealed and delivered as of the day and year first above written. OBLIGORS: SKIPPER A. DAVIDSON CATRINA DAVIDSON OBLIGEE: COX REVOCABLE TRUST, DATED JUNE 26, 2023 JESSICA COX, TRUSTEE AMORTIZATION SCHEDULE Principal: $90,000.00 Interest Rate: 4.00% Monthly Payment: $2,032.11 Total Interest Paid: $7,542.00 Total Paid: $97,542.00 <table> <tr> <th>Date</th> <th>Interest</th> <th>Principal</th> <th>Balance</th> </tr> <tr><td>Dec, 2024</td><td>$300</td><td>$1,732</td><td>$88,268</td></tr> <tr><td>2024</td><td>$300</td><td>$1,732</td><td>$88,268</td></tr> <tr><td>Jan, 2025</td><td>$294</td><td>$1,738</td><td>$86,530</td></tr> <tr><td>Feb, 2025</td><td>$288</td><td>$1,744</td><td>$84,786</td></tr> <tr><td>Mar, 2025</td><td>$283</td><td>$1,749</td><td>$83,037</td></tr> <tr><td>Apr, 2025</td><td>$277</td><td>$1,755</td><td>$81,281</td></tr> <tr><td>May, 2025</td><td>$271</td><td>$1,761</td><td>$79,520</td></tr> <tr><td>Jun, 2025</td><td>$265</td><td>$1,767</td><td>$77,753</td></tr> <tr><td>Jul, 2025</td><td>$259</td><td>$1,773</td><td>$75,980</td></tr> <tr><td>Aug, 2025</td><td>$253</td><td>$1,779</td><td>$74,201</td></tr> <tr><td>Sep, 2025</td><td>$247</td><td>$1,785</td><td>$72,417</td></tr> <tr><td>Oct, 2025</td><td>$241</td><td>$1,791</td><td>$70,626</td></tr> <tr><td>Nov, 2025</td><td>$235</td><td>$1,797</td><td>$68,829</td></tr> <tr><td>Dec, 2025</td><td>$229</td><td>$1,803</td><td>$67,027</td></tr> <tr><td>2025</td><td>$3,144</td><td>$21,241</td><td>$67,027</td></tr> <tr><td>Jan, 2026</td><td>$223</td><td>$1,809</td><td>$65,218</td></tr> <tr><td>Feb, 2026</td><td>$217</td><td>$1,815</td><td>$63,403</td></tr> <tr><td>Mar, 2026</td><td>$211</td><td>$1,821</td><td>$61,582</td></tr> <tr><td>Apr, 2026</td><td>$205</td><td>$1,827</td><td>$59,756</td></tr> <tr><td>May, 2026</td><td>$199</td><td>$1,833</td><td>$57,923</td></tr> <tr><td>Jun, 2026</td><td>$193</td><td>$1,839</td><td>$56,084</td></tr> <tr><td>Jul, 2026</td><td>$187</td><td>$1,845</td><td>$54,238</td></tr> <tr><td>Aug, 2026</td><td>$181</td><td>$1,851</td><td>$52,387</td></tr> <tr><td>Sep, 2026</td><td>$175</td><td>$1,857</td><td>$50,530</td></tr> <tr><td>Oct, 2026</td><td>$168</td><td>$1,864</td><td>$48,666</td></tr> <tr><td>Nov, 2026</td><td>$162</td><td>$1,870</td><td>$46,796</td></tr> <tr><td>Dec, 2026</td><td>$156</td><td>$1,876</td><td>$44,920</td></tr> <tr><td>2026</td><td>$2,279</td><td>$22,107</td><td>$44,920</td></tr> <tr><td>Jan, 2027</td><td>$150</td><td>$1,882</td><td>$43,038</td></tr> <tr><td>Feb, 2027</td><td>$143</td><td>$1,889</td><td>$41,149</td></tr> <tr><td>Mar, 2027</td><td>$137</td><td>$1,895</td><td>$39,254</td></tr> <tr><td>Apr, 2027</td><td>$131</td><td>$1,901</td><td>$37,353</td></tr> <tr><td>May, 2027</td><td>$125</td><td>$1,908</td><td>$35,445</td></tr> </table> Date Interest Principal Balance Jun, 2027 $118 $1,914 $33,531 Jul, 2027 $112 $1,920 $31,611 Aug, 2027 $105 $1,927 $29,684 Sep, 2027 $99 $1,933 $27,751 Oct, 2027 $93 $1,940 $25,811 Nov, 2027 $86 $1,946 $23,865 Dec, 2027 $80 $1,953 $21,913 2027 $1,378 $23,007 $21,913 Jan, 2028 $73 $1,959 $19,954 Feb, 2028 $67 $1,966 $17,988 Mar, 2028 $60 $1,972 $16,016 Apr, 2028 $53 $1,979 $14,037 May, 2028 $47 $1,985 $12,052 Jun, 2028 $40 $1,992 $10,060 Jul, 2028 $34 $1,999 $8,061 Aug, 2028 $27 $2,005 $6,056 Sep, 2028 $20 $2,012 $4,044 Oct, 2028 $13 $2,019 $2,025 Nov, 2028 $7 $2,025 $0 2028 $441 $21,913 $0 EXHIBIT B Notice of Default and Acceleration of Promissory Note and Proof of Mailing Final Demand Letter Skipper A. Davidson Catrina Davidson 18417 Mesa Road Edmond, Oklahoma 73012 Date: January 28th, 2026 Re: Promissory Note dated November 7, 2024 – Notice of Default, Acceleration, and Demand for Payment Dear Mr. and Mrs. Davidson: This correspondence is sent on behalf of Jessica Cox, Trustee of the Cox Revocable Trust (the “Obligee”), regarding your obligations under that certain Promissory Note dated November 7, 2024 (the “Note”). As you are aware, pursuant to the Note, you were obligated to remit monthly payments in the amount of $2,032.11, commencing December 15, 2024, and continuing on the fifteenth (15th) day of each month thereafter. You have failed to make the required payments in full and in accordance with the terms of the Note and have ceased making payments altogether. While limited and sporadic partial payments totaling $6,500.00 were received during calendar year 2025, such payments were insufficient to satisfy your contractual obligations and did not cure your continuing default. Pursuant to Section 6.1 of the Note, your failure to make payments when due constitutes an Event of Default. Further, under Sections 6.2 and 6.4 of the Note, upon the occurrence of an Event of Default, the Obligee is entitled to declare the entire unpaid principal balance, together with all accrued interest and other amounts due, immediately due and payable. Accordingly, please be advised that the Obligee has elected to accelerate the Promissory Note, and the entire remaining balance is hereby declared immediately due and payable. As of the date of this letter, the total amount due and owing under the Note, inclusive of unpaid principal and accrued interest, is no less than Eighty-Six Thousand Six Hundred Fifty Dollars ($86,650.00). Interest continues to accrue at the contractual rate of four percent (4.00%) per annum, and the total payoff amount increases daily until paid in full. Demand is hereby made that you remit payment in full of all amounts due under the Promissory Note within ten (10) days of your receipt of this letter. In the event payment in full is not timely received, the Obligee will pursue all available legal remedies without further notice, including the initiation of litigation for breach of the Promissory Note, recovery of the accelerated balance, accrued interest, attorney's fees, court costs, and all other relief permitted under the Note and applicable law. Nothing contained herein shall be construed as a waiver of any rights or remedies, all of which are expressly reserved. This communication is made in an effort to resolve this matter prior to the commencement of litigation. Sincerely, Jessica Cox Trustee, Cox Revocable Trust 2417 Ryder Drive Yukon, Oklahoma 73099 U.S. Postal Service™ CERTIFIED MAIL® RECEIPT Domestic Mail Only For delivery information, visit our website at www.usps.com® Certified Mail Fee $__________________________ Extra Services & Fees (check box, add fee as appropriate) ☐ Return Receipt (hardcopy) $__________________________ ☐ Return Receipt (electronic) $__________________________ ☐ Certified Mail Restricted Delivery $_____________________ ☐ Adult Signature Required $__________________________ ☐ Adult Signature Restricted Delivery $_____________________ Postage $__________________________ total Postage and Fees $__________________________ Sent To ____________________________________________________________ Street and Apt. No., or P.O. Box No. ________________________________ City: State, ZIP+4 ________________________________________________ P.S. Form 3800, January 2023 PSN 2510-02-0006047 See Reverse for Instructions UNITED STATES POSTAL SERVICE. YUKON 900 GARTH BROOKS BLVD YUKON, OK 73099-9996 www.usps.com 01/28/2026 02:16 PM TRACKING NUMBERS 9589 0710 5270 3474 4707 65 TRACK STATUS OF ITEMS WITH THIS CODE (up to 25 items) TRACK STATUS BY TEXT MESSAGE Send tracking number to 28777 (USPS) Standard message and data rates may apply TRACK STATUS ONLINE Visit https://www.usps.com/tracking Text and e-mail alerts available PURCHASE DETAILS <table> <tr> <th>Product</th> <th>Oty</th> <th>Unit Price</th> <th>Price</th> </tr> <tr> <td>First Class Mail®Letter Edmond, OK 73012<br>Weight: 0 ib 0.40 oz<br>Estimated Delivery Date<br>Fri 01/30/2026</td> <td>1</td> <td>$0.78</td> <td>$0.78</td> </tr> <tr> <td>Certified Mail®<br>Tracking #: 9589 0710 5270 3474 4707 65<br>Return Receipt<br>Tracking #: 9A90 9401 9739 5199 5-117 98</td> <td></td> <td>$0.40</td> <td>$0.40</td> </tr> <tr> <td><b>Total</b></td> <td></td> <td></td> <td><b>$10.48</b></td> </tr> </table> Grand Total: $10.48 Debit Card Permit $10.48 Card Name: VISA Account #: XXXXXXXXXX/XXXXX9c Approval #: 105215 Transaction #: 256 Receipt #: 066019 Debit Card Purchase: $10.48 ATD: AUO00000980840 Conelitives AL: US DEBIT