CJ-2026-1555 - Carolyn Biby v. Jill Ann Jekel

What's This Case About?

Let’s be real: we’ve all been rear-ended at a stoplight. Maybe you cursed, maybe you cried, maybe you debated getting out and having words. But unless your spine collapsed like a house of cards, you probably didn’t walk away thinking, Yep, this is my $75,000 moment. But Carolyn Biby? Oh, she’s not just filing a claim—she’s dropping a legal bomb on her coworker and their employer, alleging that a routine lunchtime drive turned into a life-altering spinal disaster thanks to someone who apparently forgot how cars work.

So who are these people? On one side, we’ve got Carolyn Biby—a resident of Jones, Oklahoma, which, for the record, is not a fictional town from a Wes Anderson movie but a real place with real people who apparently do not take being hit from behind lightly. She’s the plaintiff, the one who says she was just minding her business, driving safely on a sunny November day in Edmond (Oklahoma’s version of suburban serenity), when her world got violently rearranged. On the other side? Jill Ann Jekel—her coworker, apparently—and the company they both allegedly work for, Hunton Oil & Gas LLC, a domestic limited liability company that, based on the name, probably deals in oil, gas, and now, unintentionally, personal injury drama. The relationship here isn’t spelled out in the filing, but the implication is clear: they’re coworkers, possibly even on the same work schedule, maybe even running errands for the company. That last part matters—more on that later.

Now, let’s set the scene. It’s November 2, 2024. The clock hits noon. The sun is shining, the roads are dry, and W Edmond Road—a four-lane highway with a 45 mph speed limit—is humming along like any other weekday. Carolyn is driving eastbound in the left lane. Traffic ahead slows. She does what any reasonable human with a driver’s license and a pulse would do: she stops. Completely. Safely. Legally. She’s not swerving, she’s not slamming brakes unnecessarily, she’s just… obeying traffic laws. Meanwhile, Jill Jekel is right behind her, also eastbound, also presumably aware that cars exist in front of other cars. But Jill does not stop. No, Jill plows directly into the back of Carolyn’s vehicle with such force that airbags deploy—yes, plural—and the impact allegedly causes not just car damage, but catastrophic bodily harm. The Edmond Police Department shows up, does their thing, and cites Jill for following too closely, which, in city code, is basically the legal equivalent of saying, “You were not paying attention, and also, you’re bad at driving.”

And here’s where it gets spicy. Carolyn didn’t just walk away with whiplash and a dent in her bumper. According to the petition, she suffered a closed wedge compression fracture of the T9 thoracic vertebra—which sounds like something out of a medical thriller—and a collapsed vertebra in the lumbar region. Let’s translate: her spine got crushed. She also allegedly sprained her ribs and thoracic spine, developed kyphosis (a permanent postural deformity that makes your upper back hunch), and now lives with chronic pain, emotional distress, and a drastically reduced quality of life. She was taken to Mercy Health Center, presumably in pain and shock, and has since endured ongoing medical treatment. The filing claims she was in good health before this. Now? She’s dealing with permanent injuries, disability, and a future filled with physical therapy, pain management, and the emotional toll of being that person—the one who got rear-ended into a new reality.

So why are we in court? Because Carolyn isn’t just mad—she’s lawyered up. And her legal team at Adler Markoff & Associates is making three distinct arguments, each more dramatic than the last. First: negligence. They’re saying Jill wasn’t just a little distracted—she was legally negligent. She failed to keep a safe distance, failed to pay attention, failed to stop, failed to control her vehicle, and possibly had defective brakes (though that last one feels like a stretch—no evidence is cited, it’s just alleged). But here’s the kicker: they’re also claiming negligence per se, which means Jill didn’t just mess up—she broke the law, and that law was specifically designed to prevent exactly this kind of crash. So her citation isn’t just a slap on the wrist—it’s a smoking gun in civil court.

Second: vicarious liability. This is where Hunton Oil & Gas gets dragged in. The argument? Jill wasn’t just out running personal errands—she was acting “within the scope of her employment” when she caused the crash. Maybe she was on a work call. Maybe she was driving a company vehicle. Maybe she was picking up lunch for the office. Whatever the case, if she was working for Hunton at the time, then Hunton is on the hook for her actions. That’s how respondeat superior works—Latin for “the boss pays when the employee screws up.”

Third: negligent entrustment. This one’s juicy. It means Hunton didn’t just employ Jill—they gave her the keys to a company vehicle, knowing—or should have known—that she was the kind of person who might drive like a maniac. Did Jill have a history of bad driving? Was she recently cited? Was she known for texting behind the wheel? The filing doesn’t say, but it implies that Hunton was reckless for letting her drive at all. That’s a big deal, because it shifts blame from “oops, accident” to “you enabled this disaster.”

Now, what does Carolyn want? A cool $75,000—plus interest, plus attorney’s fees, plus punitive damages, which are not about compensation but about punishment. That number might sound high for a fender bender, but let’s be clear: this wasn’t a fender bender. This was a crash so violent it deployed airbags and shattered vertebrae. In personal injury law, $75,000 is not crazy for long-term medical care, chronic pain, and permanent disability—especially when you factor in lost wages, emotional suffering, and future treatment. And punitive damages? Those are the legal equivalent of throwing shade. They’re saying, “Not only did you hurt her, but you did it in a way that was so careless, so preventable, that you deserve to feel it in your wallet.”

Our take? Look, car accidents are tragic, common, and often messy. But what makes this case a spectacle isn’t just the injuries—it’s the corporate entanglement. A coworker rear-ends you so hard it collapses your spine, and now you’re suing both her and your shared employer, alleging they negligently handed her the keys like it was no big deal. The most absurd part? That this probably wasn’t even a high-speed chase—just a moment of distraction at a stoplight. One second of not paying attention, and boom: spinal fracture, lawsuit, and a potential $75,000 bill for someone’s bad driving and worse judgment.

We’re not rooting for lawsuits. We’re not rooting for pain. But if there’s one thing we’re rooting for? Accountability. If Hunton really did hand a company car to someone they knew was a risk, that’s on them. If Jill was texting, daydreaming, or just not paying attention while driving a work vehicle, that’s on her. And if Carolyn is now living with permanent physical changes because of it? Then yeah, she deserves her day in court. This isn’t about revenge—it’s about the fact that when you get behind the wheel, you’re not just driving a car. You’re operating a weapon. And when you fail to treat it that way, people get hurt. Permanently.

So buckle up, Oklahoma County. This one’s going to be a bumpy ride.

Case Overview

$75,000 Demand Jury Trial Petition

Jurisdiction

District Court, Oklahoma

Filing Attorney

Daniel P. Markoff, OBA# 14886, Bria A. Hanlon, OBA # 32412, Andrew S. Hiller, OBA # 34356

Adler Markoff & Associates

Relief Sought

$75,000 Monetary

$1 Punitive

Plaintiffs

Carolyn Biby individual
Rep: Daniel P. Markoff, OBA# 14886, Bria A. Hanlon, OBA # 32412, Andrew S. Hiller, OBA # 34356

Defendants

Jill Ann Jekel individual
Hunton Oil & Gas LLC business

Claims

#	Cause of Action	Description
1	Negligence and Negligence Per Se	Defendant's negligence led to a motor vehicle collision resulting in serious injuries to the plaintiff.
2	Vicarious Liability - Defendant Hunton Oil & Gas LLC	Defendant Hunton Oil & Gas LLC is vicariously liable for the negligence of its employee/agent.
3	Negligent Entrustment - Defendant Hunton Oil and Gas LLC	Defendant Hunton Oil and Gas LLC entrusted a vehicle to an employee who was likely to operate it in a careless manner.

Petition Text

1,281 words

IN THE DISTRICT COURT OF OKLAHOMA COUNTY STATE OF OKLAHOMA CAROLYN BIBY, an individual, Plaintiff, v. JILL ANN JEKEL, an individual; and HUNTON OIL & GAS LLC, a Domestic Limited Liability Company Defendant. FILED IN DISTRICT COURT OKLAHOMA COUNTY Case No.: __________ MAR - 3 2026 RICK WARREN COURT CLERK 114 OJ - 2026 - 1555 PETITION I. PARTIES 1. Plaintiff Carolyn Biby is an individual and an Oklahoma resident residing in Jones, Oklahoma. 2. Defendant Jill Ann Jekel is an individual and resides in Oklahoma County, Oklahoma. She may be served at her residence: 3321 NW 158th Street, Oklahoma City, OK 73013. 3. Defendant Hunton Oil & Gas LLC is a Domestic Limited Liability Company with its place of business in Oklahoma County, Oklahoma. It can be served via its registered agent, Kevin Crowley, at 6416 N Santa Fe, Oklahoma City, OK 73116. II. JURISDICTION 3. This Court has personal jurisdiction over Defendant because Defendants reside in Oklahoma County and committed the tortious acts giving rise to this action in Oklahoma County. 4. Venue is proper in this Court pursuant to 12 O.S. §141 because Oklahoma County is the county where the collision occurred, the injuries were sustained, and Defendant resides. III. FACTS 5. On or about November 2, 2024, at approximately 12:00 PM, Plaintiff and Defendant were involved in a motor vehicle collision on W Edmond Road at S Trail Ridge Road in Edmond, Oklahoma. 6. At the time of the collision, the weather was clear, it was daylight, and the roadway was dry asphalt. 7. W Edmond Road is a four-lane roadway with a posted speed limit of 45 miles per hour. 8. Plaintiff was operating her vehicle eastbound in the left lane of W Edmond Road. 9. Traffic ahead of Plaintiff came to a stop, and Plaintiff brought her vehicle to a complete stop. 10. Defendant Jekel was operating her vehicle eastbound on W Edmond Road, traveling directly behind Plaintiff’s vehicle. 11. Defendant Jekel failed to bring her vehicle to a stop and struck the rear of Plaintiff’s vehicle. 12. Defendant Jekel was by the Edmond Police Department for a violation of Edmond Municipal Code 10.28.070 – following too closely. 13. The force of the impact was significant, causing serious damage to Plaintiff’s vehicle, causing the Plaintiff’s airbags to deploy, and resulting in serious injuries to the Plaintiff. 14. As a result of the collision, Plaintiff sustained injuries and required immediate medical attention. 15. Plaintiff was transported to Mercy Health Center for treatment of her injuries. 16. At all times relevant to the negligent acts complained of, Hunton Oil & Gas LLC (Hunton) was an employer of Defendant Jekel, and Jekel was an employee of Hunton. 17. At all times described herein, Defendant Jekel was acting within the scope of his employment and/or agency for Hunton. 18. Defendant Hunton Oil & Gas LLC authorized, permitted, allowed, or otherwise entrusted the use of their vehicle to Defendant Jekel. 19. Defendant Hunton Oil & Gas LLC is the registered owner of the vehicle operated by Defendant Jekel. 20. At all relevant times, Plaintiff was operating her vehicle in a safe and reasonable manner, and was in compliance with all applicable statutes, codes, and other regulations. FIRST CAUSE OF ACTION: NEGLIGENCE AND NEGLIGENCE PER SE Plaintiff adopts and incorporates the foregoing paragraphs and states: 21. Defendant owed a duty of care to Plaintiff to operate her motor vehicle in a safe and reasonable manner and in accordance with applicable laws and regulations. 22. Defendant breached that duty of care through her negligent or grossly negligent operation of a motor vehicle by operating the vehicle in a careless and wanton manner without regard for the safety of others. 23. Defendant's negligence includes, but is not limited to: A. Failing to maintain a safe following distance: (47 O.S. §11-310) B. Failing to keep a proper lookout for traffic ahead; (47 O.S. §11-901b) C. Failing to stop in time to avoid the collision; (47 O.S. §11-901b) D. Failing to maintain control of her vehicle; (47 O.S. §11-901b) E. Operating a vehicle with defective or improperly functioning brakes; (12 O.S. §12-301, 12 O.S. §12-302) F. Failing to devote full time and attention to driving; (47 O.S. §11-901b) and G. Operating her vehicle in a careless manner without regard for the safety of others. (47 O.S. §11-901) 24. The collision at issue was caused by Defendant's violation of these statutes. The subject collision and Plaintiff's resulting injuries were the very type of events and injuries that these statutes were designed to prevent, and Plaintiff is part of the class of people meant to be protected by the same. Accordingly, Defendant's violations of these statutes give rise to a negligence per se claim. 25. As a direct and proximate result of Defendant's negligence and negligence per se, Plaintiff sustained serious personal injuries, incurred medical expenses, and suffered pain and suffering and other damages, all in an amount in excess of $75,000.00 SECOND CAUSE OF ACTION: VICARIOUS LIABILITY – DEFENDANT HUNTON OIL & GAS LLC For her second cause of action, Plaintiff re-alleges and incorporates by reference all foregoing paragraphs and states: 26. At all times described herein, Defendant Jekel was acting within the scope of their employment and/or agency for Hunton. 27. Defendant Hunton is therefore vicariously liable for the negligence of its employee/agent, and other applicable damages under Respondeat Superior. 28. Defendant Hunton is vicariously liable for the gross negligence of its employee/agent, and punitive damages under Respondeat Superior. 29. As a direct and proximate result of the negligence and gross negligence of Defendant Jekel, for which Hunton is vicariously liable, Plaintiff Biby has sustained serious bodily injuries, medical expenses, out-of-pocket expenses, pain and suffering, and punitive damages, all in an amount in excess of $75,000.00. THIRD CAUSE OF ACTION: NEGLIGENT ENTRUSTMENT – DEFENDANT HUNTON OIL AND GAS LLC For her second cause of action, Plaintiff re-alleges and incorporates by reference all foregoing paragraphs and states: 30. Defendant Hunton was the owner of the vehicle operated by Defendant Jekel. 31. Defendant Hunton possessed the title to the vehicle operated by Defendant Jekel. 32. Defendant Hunton included the vehicle in their insurance coverage. 33. Defendant Hunton authorized, encouraged, provided for, contracted with, or otherwise permitted Defendant Jekel to operate a vehicle that was registered to themselves. 34. Defendant Hunton knew or should have known that Defendant Jekel was likely to operate the vehicle in a way that was careless, reckless, negligent, or with reckless disregard for the rights of others. DAMAGES 35. Prior to the collision, Plaintiff was in good health with a normal life expectancy, but as a direct and proximate result of Defendant's negligence, Plaintiff has sustained the following injuries and damages for which Plaintiff is entitled to recover: a. Past, present, and future physical pain and suffering; b. Permanent physical injuries, including a closed wedge compression fracture of the T9 thoracic vertebra, a collapsed vertebra in the lumbar region, sprain of the ribs, and sprain of the thoracic spine; c. Past, present, and future mental and emotional pain, suffering, and distress; d. Past, present, and future reasonable and necessary medical expenses in the care and treatment of Plaintiff's injuries; e. Permanent disfigurement, including kyphosis of the thoracic region resulting in postural changes; f. Loss of enjoyment of life; g. Physical impairment and disability; h. Inconvenience; and i. Such other general damages as may be recognized under Oklahoma law. PRAYER FOR RELIEF WHEREFORE, Plaintiff prays for judgment against Defendants in an amount in excess of $75,000.00 for compensatory damages, together with pre-judgment and post-judgment interest as allowed by law, costs of this action, attorneys' fees, and such other and further relief as the Court may deem just and proper. Respectfully submitted, Daniel P. Markoff, OBA# 14886 Bria A. Hanlon, OBA # 32412 Andrew S. Hiller, OBA # 34356 ADLER MARKOFF & ASSOCIATES 9211 Lake Hefner Pkwy., Suite104 Oklahoma City, Oklahoma, 73120 Telephone:(405) 607-8757 Facsimile: (405) 607-8749 Email: [email protected] [email protected] [email protected] ATTORNEY FOR PLAINTIFF ATTORNEY'S LIEN CLAIMED JURY TRIAL DEMANDED