IN THE DISTRICT COURT OF TULSA COUNTY
STATE OF OKLAHOMA
RESTORATION KINGS LLC;
Plaintiff.
-vs-
RIVERPARK BEST LIVING LLC; WESTLAKE HARDWARE INC; ALERT PLUMBING & DRAIN LLC; YSA INVESTMENTS 1 LLC; ACCENT RESTORATION LLC; and TULSA COUNTY TREASURER'S OFFICE;
Defendants.
PETITION – FORECLOSURE OF MECHANIC’S LIEN
COMES NOW, the Plaintiff Restoration Kings LLC, by and through its Counsel of Record, Stephen P. Gray, and for its Cause of Action against the Defendant Riverpark Best Living LLC, and the additional Defendants named herein, alleges and states as follows:
PARTIES AND JURISDICTION
1. The Plaintiff is an Oklahoma corporation registered with the Oklahoma Secretary of State.
2. The Defendant Riverpark Best Living LLC has at all times relevant hereto been incorporated under the laws of the State of Oklahoma and continues to operate within the State of Oklahoma.
3. The real property at issue in this matter [hereinafter the “Subject Property”] is located in Tulsa County, Oklahoma and the lien that is the subject of this Action [hereinafter the “Lien”] was filed in Tulsa County, Oklahoma on August 7th, 2025.
4. Upon information and belief, the following persons or entities may claim some right, title, lien, or mortgage interest in and to the Subject Property by virtue of instruments recorded in the office of the Tulsa County Clerk. Said Parties are hereby joined as Defendants so that their respective rights, priorities, and interests, if any, may be adjudicated and foreclosed herein:
a. Westlake Hardware Inc., c/o Christopher W. Cotner of Mee Hawkins Greenhaw & Cotner PLLP, 1900 Northwest Expressway, Suite 1400, Oklahoma City, Oklahoma 73118, which recorded a lien on March 7th, 2025, in the approximate amount of $25,067.37;
b. Alert Plumbing & Drain LLC, 3975 South Sheridan Road, Tulsa, Oklahoma 74145, which recorded a lien on June 16th, 2025, in the approximate amount of $10,200.00, inclusive of filing fees and administrative costs;
c. YSA Investments 1 LLC, 8 The Green #23817, Dover, Delaware 19901, which recorded a mortgage on October 31st, 2025, in the approximate principal amount of $2,000,000, the validity and present enforceability of which is presently unknown;
d. Accent Restoration LLC, 6972 East 38th Street, Suite 200, Tulsa, Oklahoma 74145, which recorded a lien on November 26th, 2025, in the approximate amount of $2,557.50.
5. The relative priority of the foregoing liens and mortgage interests is alleged according to their respective recording dates; however, the Plaintiff expressly reserves the right to assert statutory priority and relation-back rights as provided under Oklahoma lien law, including but not limited to Title 42 O.S. § 141, and requests that the Court determine the nature, extent, validity, and priority of all claimed interests in the Subject Property.
1ST CAUSE OF ACTION: LIEN FORECLOSURE
6. For its First Cause of Action, the Plaintiff incorporates ¶1-5 above as though fully set forth herein and further alleges:
7. The Plaintiff performed construction work with the knowledge and consent of Defendant Riverpark Best Living LLC at the Subject Property with a street address of: 7803 South Wheeling Avenue, Tulsa, Oklahoma 74136 and with a legal description of:
Lot One (1), Block Seventeen (17), KENSINGTON BLOCKS 15 & 17, of the Planned Unit Development 128-B, an Addition in Tulsa County, State of Oklahoma, according to the Plat thereof recorded as Plat No. 4319 on March 23rd, 1983.
8. The Plaintiff supplied construction services in the form of labor and materials at the Subject Property. The final work was performed within ninety (90) days preceding the filing of the Lien.
9. Defendant Riverpark Best Living LLC has failed to pay the Plaintiff for the labor and materials that were incorporated into the Subject Property.
10. To secure payment of the outstanding balance, the Plaintiff filed a Mechanic’s Lien [attached hereto as Exhibit 1] with the Tulsa County Clerk’s Office on August 7th, 2025, in the amount of $25,000.
11. The Lien was timely filed and is valid and enforceable under Oklahoma law.
12. Defendant Riverpark Best Living LLC is the record owner of the Subject Property and should appear and establish its interest in this litigation.
13. The Plaintiff is entitled to judgment in rem against the Subject Property in the amount of $25,000, together with attorney fees, court costs, and interest accrued and accruing.
14. The Plaintiff further requests that the Court determine the respective rights and priorities of all Defendants named herein and enter an order foreclosing all interests that are junior and inferior to Plaintiff’s Lien.
2ND CAUSE OF ACTION: BREACH OF CONTRACT
15. For its Second Cause of Action, the Plaintiff incorporates ¶1-14 above as though fully set forth herein and further alleges:
16. Defendant Riverpark Best Living LLC entered into a written contract with the Plaintiff in order to induce the Plaintiff to perform construction services at the Subject Property and thereby personally obligated itself for all amounts owed to the Plaintiff.
17. Defendant Riverpark Best Living LLC has failed and refused to pay the Plaintiff the sum of $25,000 and has further failed and refused to pay attorney fees, costs, and interest accruing on the unpaid balance from the dates the invoices became due at the contractual interest rate of eighteen percent per annum.
PRAYER FOR RELIEF
WHEREFORE, the Plaintiff Restoration Kings LLC, hereby respectfully requests:
1. Judgment in personam against Defendant Riverpark Best Living LLC in the principal sum of $25,000, together with attorney fees, costs, and contractual interest at 18% per annum;
2. Judgment in rem against the Subject Property;
3. A judicial determination of the validity, nature, extent, and priority of all liens and mortgage interests claimed by the other Defendants;
4. An order foreclosing all interests adjudged to be junior and inferior to the Plaintiff’s Lien;
5. Sale of the Subject Property according to law, with proceeds distributed according to the Court’s determination of priority; and
6. Such other and further relief as the Court deems just, equitable, and proper.
Respectfully submitted,
[signed] Stephen P. Gray, OBA #3556
STEPHEN P. GRAY, PC
2400 West Detroit Street
Broken Arrow, Oklahoma 74012
[email protected]
P: (918) 994-7051
Attorney for Plaintiff
VERIFICATION
STATE OF OKLAHOMA
COUNTY OF TULSA } ss.
I, CODY EGGER, being of lawful age, being first duly sworn, upon oath, hereby depose and state: I have read the foregoing document and understand its contents. I hereby state that the facts set forth in it are true and correct to the best of my knowledge and belief.
[Signature]
CODY EGGER
for Restoration Kings LLC
[Seal]
Given under my Hand and Seal on this 4th day of February, 2026.
CERTIFICATE OF MAILING
I hereby certify that within 3 business days of the filing of this document, a true and correct copy of the above and foregoing was mailed, with sufficient postage fully prepaid thereon, to the following:
Riverpark Best Living LLC
c/o Universal Registered Agents, Inc.
10300 Greenbriar Place
Oklahoma City, Oklahoma 73159
Defendant
Alert Plumbing & Drain LLC
3975 South Sheridan Road
Tulsa, Oklahoma 74145
Defendant
Accent Restoration LLC
6972 East 38th Street, Suite 200
Tulsa, Oklahoma 74145
Defendant
Westlake Hardware Inc.
c/o Christopher W. Cotner, OBA #18927
MEE HAWKINS GREENHAW & COTNER PLLP
1900 Northwest Expressway, Suite 1400
Oklahoma City, Oklahoma 73118
Defendant
YSA Investments 1 LLC
8 The Green #23817
Dover, Delaware 19901
Defendant
Tulsa County Treasurer's Office
218 West 6th Street, 8th Floor
Tulsa, Oklahoma 74119-1004
Defendant
Mechanic's Or Materialman's Lien Statement
State of Oklahoma )
) ss.
County of Tulsa )
(1) Restoration Kings LLC
whose address is 8449 South College Ave Tulsa, OK 74137
has a claim against Riverpark Apartments at Kensington
whose address is 7803 S Wheeling Ave. Tulsa, OK 74136
for the sum of Twenty Five Thousand Dollars
($25,000.00) due to claimant.
and that the claim is made for and on account of (2) work and labor
and that such (2) work and labor was last (3) performed
by Restoration Kings LLC
on the 27 day of March, 2025, according to an itemized statement thereof hereunto attached as "Exhibit A", and made a part of this statement; that such (2) work and labor
was (5) performed upon ____________________________ in pursuance
of Contractor Agreement with Property Manager and Corporate Office
and was (5) performed upon ____________________________ the premises owned
by Vesta Realty LLC
whose address is 6911 South 66th East Ave Tulsa, OK 74133
and described as follows to wit:
Lot One (1), Block Seventeen (17), KENSINGTON BLOCKS 15 AND 17, of the Planned Unit Development 128-B, an Addition in Tulsa County, State of Oklahoma, according to the Plat thereof recorded as Plat No. 4319 on March 23, 1983
Property Address: ____________________________ 7803 South Wheeling Ave Tulsa, OK ____________________________
in said County and State; that the said sum is just, due and unpaid, and the claimant has and claims a lien upon said property and upon the said premises on which the same is situated, to the amount of $______________________25,000.00______________________ as above set forth, according to the laws of the State of Oklahoma.
Dated this ___7___ day of ___August______, 20 ___25___
J. Cody Egger
J. Cody Egger
Owner / Operator
(Please Sign in the presence of a Notary Public)
State of Oklahoma )
) ss.
County of Tulsa )
J. Cody Egger — , of lawful age, being first duly sworn, upon oath says:
That he or she is (6) Owner mentioned in the foregoing statement of (7) Mechanics lien: that he or she has read this statement and knows the contents thereof; that the name of the owner, the name of the contractor, the name of the claimant, the description of the property upon which the lien is claimed, and the items of the account as therein set forth, are just, true, correct and unpaid.
J. Cody Egger
Owner Operator
(Please Sign in the presence of a Notary Public)
Subscribed and sworn to before me this 7 day of August ,2025
My Commission expires:
My Commission Number:
Kaleigh Cox
NOTARY PUBLIC
Notary Public
State of Oklahoma
KALEIGH COX
TULSA COUNTY
COMMISSION #23013460
Comm. Exp. 10-04-2027
1. "X, a corporation doing business in," or "AB and CD, partners doing business under the firm name and style of X Company in," or "a carpenter of," as the case may be.
2. "Work and labor," or "material," or "Labor and material," as the case may be.
3. "Performed" or "Furnished" as the case may be.
4. "A contract with Y, the owner," or "a contract with Y, the contractor," or "employment by the owner, Y," "contractor Y" or "sub-contractor Y," as the case may be.
5. "Performed upon" or "furnished for and used on" as the case may be.
6. "The claimant or President of said claimant corporation" or "one of the partners of said claimant partnership" as the case may be.
7. "Mechanic's" or "Materialman's"
8. In case of corporation sign verification "John doe, President of X corporation."
Restoration Kings
8449 College Ave
Tulsa, OK 74137 USA
+19165842275
[email protected]
Wendi McClanahan
Services New Set of 10 Apartment make Readies Total $25,000 1 0.00 0.00
Services First Installment Payment 1 8,333.33 8,333.33
Services Unit 28-28I -Painted Walls, Ceiling, Trim, Doors, Cabinets and replaced all light switch / Outlet Covers and Installed Blinds on all Blinds 1 0.00 0.00
Services Unit 30-30G -Painted Walls, Ceiling, Trim, Doors, Cabinets and replaced all light switch / Outlet Covers and Installed Blinds on all Blinds 1 0.00 0.00
Services Unit 31-31C -Painted Walls, Ceiling, Trim, Doors, Cabinets and replaced all light switch / Outlet Covers and Installed Blinds on all Blinds 1 0.00 0.00
Services Unit 50-50F -Painted Walls, Ceiling, Trim, Doors, Cabinets and replaced all light switch / Outlet Covers and Installed Blinds on all Blinds 1 0.00 0.00
Services Unit 29-29M - Never Started 1 0.00 0.00
Services Unit 44-44F - Never Started 1 0.00 0.00
Services Unit 42-42B - Never Started 1 0.00 0.00
Services Unit 34-34F - Never Started 1 0.00 0.00
Services Unit 47-47C - Never Started 1 0.00 0.00
Services Unit 47-47F - Never Started 1 0.00 0.00
$8,333.33
Restoration Kings
8449 College Ave
Tulsa, OK 74137 USA
+19186642275
[email protected]
Wendi McClenahan
<table>
<tr>
<th>Services</th>
<th>Description</th>
<th>Qty</th>
<th>Amount</th>
<th>Subtotal</th>
</tr>
<tr>
<td>Services</td>
<td>Make Readies - Last of Three Installment Payments</td>
<td>1</td>
<td>16,666.67</td>
<td>16,666.67</td>
</tr>
<tr>
<td>Services</td>
<td>Total Agreed Amount $50,000 for entire project</td>
<td>1</td>
<td>0.00</td>
<td>0.00</td>
</tr>
<tr>
<td>Services</td>
<td>Unit 41-41B -Painted Walls, Ceiling, Trim, Doors, Cabinets and replaced all light switch / Outlet Covers and Installed Blinds on all Blinds</td>
<td>1</td>
<td>0.00</td>
<td>0.00</td>
</tr>
<tr>
<td>Services</td>
<td>Unit 40-40J-Painted Walls, Ceiling, Trim, Doors, Cabinets and replaced all light switch / Outlet Covers and Installed Blinds on all Blinds</td>
<td>1</td>
<td>0.00</td>
<td>0.00</td>
</tr>
<tr>
<td>Services</td>
<td>Unit 43-43P-Painted Walls, Ceiling, Trim, Doors, Cabinets and replaced all light switch / Outlet Covers and Installed Blinds on all Blinds</td>
<td>1</td>
<td>0.00</td>
<td>0.00</td>
</tr>
<tr>
<td>Services</td>
<td>Unit 51-51E-Painted Walls, Ceiling, Trim, Doors, Cabinets and replaced all light switch / Outlet Covers and Installed Blinds on all Blinds</td>
<td>1</td>
<td>0.00</td>
<td>0.00</td>
</tr>
<tr>
<td>Services</td>
<td>Unit 34-34D-Painted Walls, Ceiling, Trim, Doors, Cabinets and replaced all light switch / Outlet Covers and Installed Blinds on all Blinds</td>
<td>1</td>
<td>0.00</td>
<td>0.00</td>
</tr>
<tr>
<td>Services</td>
<td>Unit 48-48E-Painted Walls, Ceiling, Trim, Doors, Cabinets and replaced all light switch / Outlet Covers and Installed Blinds on all Blinds</td>
<td>1</td>
<td>0.00</td>
<td>0.00</td>
</tr>
<tr>
<td>Services</td>
<td>Unit 47-47E-Painted Walls, Ceiling, Trim, Doors, Cabinets and replaced all light switch / Outlet Covers and Installed Blinds on all Blinds</td>
<td>1</td>
<td>0.00</td>
<td>0.00</td>
</tr>
<tr>
<td>Services</td>
<td>Unit 50-50B-Painted Walls, Ceiling, Trim, Doors, Cabinets and replaced all light switch / Outlet Covers and Installed Blinds on all Blinds</td>
<td>1</td>
<td>0.00</td>
<td>0.00</td>
</tr>
<tr>
<td>Services</td>
<td>Unit 51-51E-Painted Walls, Ceiling, Trim, Doors, Cabinets and replaced all light switch / Outlet Covers and Installed Blinds on all Blinds</td>
<td>1</td>
<td>0.00</td>
<td>0.00</td>
</tr>
<tr>
<td>Services</td>
<td>Unit 43-43J-Painted Walls, Ceiling, Trim, Doors, Cabinets and replaced all light switch / Outlet Covers and Installed Blinds on all Blinds</td>
<td>1</td>
<td>0.00</td>
<td>0.00</td>
</tr>
<tr>
<td>Services</td>
<td>Unit 30-30N-Painted Walls, Ceiling, Trim, Doors, Cabinets and replaced all light switch / Outlet Covers and Installed Blinds on all Blinds</td>
<td>1</td>
<td>0.00</td>
<td>0.00</td>
</tr>
</table>
Services Unit 41-41J -Painted Walls, Ceiling, Trim, Doors, Cabinets and replaced all light switch / Outlet Covers and Installed Blinds on all Blinds 1 0.00 0.00
Services Unit 42-42F -Painted Walls, Ceiling, Trim, Doors, Cabinets and replaced all light switch / Outlet Covers and Installed Blinds on all Blinds 1 0.00 0.00
Services Unit 40-40F -Painted Walls, Ceiling, Trim, Doors, Cabinets and replaced all light switch / Outlet Covers and Installed Blinds on all Blinds 1 0.00 0.00
Services Unit 48-48J - Painted Walls, Ceiling, Trim, Doors, Cabinets and replaced all light switch / Outlet Covers and Installed Blinds on all Blinds 1 0.00 0.00
Services Unit 52-52D - Painted Walls, Ceiling, Trim, Doors, Cabinets and replaced all light switch / Outlet Covers and Installed Blinds on all Blinds 1 0.00 0.00
Services Unit 39-39L - Painted Walls, Ceiling, Trim, Doors, Cabinets and replaced all light switch / Outlet Covers and Installed Blinds on all Blinds 1 0.00 0.00
Services Unit 51-51M - Painted Walls, Ceiling, Trim, Doors, Cabinets and replaced all light switch / Outlet Covers and Installed Blinds on all Blinds 1 0.00 0.00
Services Unit 39-39M - Painted Walls, Ceiling, Trim, Doors, Cabinets and replaced all light switch / Outlet Covers and Installed Blinds on all Blinds 1 0.00 0.00
Services Unit 39-39A - Painted Walls, Ceiling, Trim, Doors, Cabinetts and replaced all light switch / Outlet Covers and Installed Blinds on all Blinds 1 0.00 0.00
$16,666.67
