Date: 07-03-2013

Case Style: Jeremy George v. Gerald Catterline Irrevocable Trust

Case Number: CJ-2012-497

Judge: Linda G. Morrissey

Court: District Court, Tulsa County, Oklahoma

Plaintiff's Attorney: N. Blaine Frierson

Defendant's Attorney: James David Bryant and Charles R. Graham

Description: Jeremy George sued the Gerald Catterline Irrevocable Trust, Charlene Catterline, Trustee, and Ben Catterline claiming:

1. Plaintiff entered into a written lease agreement with Ben Catterlin who purported to have agency to enter into said lease, and said lease had not expired at the time ai4 date of the circumstances described below; and [7

2. Said agreement was entered in Tulsa County, Oklahoma, and both Parties are residents in good faith of Tulsa County and jurisdiction and venue are appropiate in the District Courts in and for Tulsa County, Oklahoma.

3. The agreement was reduced to writing and executed 23w” day of March, 2010 and had not expired; and

4. Plaintiffs were to pay $900.00 per month in rent and have exclusive tenant’s rights to the real property located at 5126 East 89th Street, Tulsa, Oklahoma 74137; and

5. The legal description of said real property is LotS, Block 5 of the Fox Pointe Addition, an addition to the City of Tulsa, according to the recorded plat thereof; and

6. According to the Tulsa County Clerk the record oer of said property is the Gerald Catterlin Irrevocable Trust by and through Trustee, Charlene Catterlin, although, neither Charlene nor anyone listed as an agent of the trust executed the written lease with Plaintiffs; and

7. The Residential Lease is attached hereto as “Exhibit A”; and

8. Defendant Ben Catterlin was fully aware that the Plaintiff, Jeremy George travelled as apart of his job responsibilities.

9. Despite this knowledge which Plaintiff can prove and, without notice to the tenant, Defendants without leave of court, and afler filing no Forcible Entry and Detainer illegally evicted tenants under Tit. 12 U.S. 1148.10 et.seq., and Tit. 41 0.S. 123 on or about November 14, 2011.

10. Landlord used self-help without leave of court to illegally evict the tenant, and took it upon himself to move tenant’s personal property from the house.

11. Tenant and Landlord made an agreement for Tenant to retrieve his personal property on or about November 18,2011, but, when tenant appeared to pick up his belongings, despite demand from tenant’s attorney, Defendants Ben Catterlin and Charlene Catterlin refused to deliver all the personal property of approximately $9,000.00 in value.

12. Tenant should be allowed pursuant to Tit. 41 U.S. 123 to recover twice his actual damages due to the illegal eviction.

WHEREFORE, PREMISES CONSIDERED, YOUR PLAINTIFF would respectfully request this honorable Court grant him damages in excess of $10,000.00 due to the illegal eviction, and attorney’s fees and court costs against the Defendants.

Second Cause ofAction

COMES NOW, your Plaintiff, Jeremy George, by and through his attorney of
record, N. Blame Frierson, OBA No. 13979, and would reallege and restate each and every allegation made hereinabove in the Plaintiff’s First Cause of Action in paragraphs 1-12
above, and would further allege and state as follows:

13. Due to the fact that Plaintiff has the means to prove Defendants illegally took his
personal property, the court should deem this as conversion, and Plaintiff should be awarded damages as allowed under common law and statutes for conversion under the laws of the State of Oklahoma; and

14. Your Plaintiff is entitled to a judgment for conversion of his personal property by Defendants in excess of $10,000.00.

WHEREFORE, PREMISES CONSIDERED, your Plaintiff is entitled to ajudgment for a written agreement for expectation damages and in the same amount for the Defendants wrongful eviction pursuant to the Residential Lease attached hereto as Exhibit “A”, and for conversion pursuant to Oklahoma case and statutory authority in an amount in excess of Ten Thousand and no! 100 Dollars ($1 0,000. 00) for either one or both actions, with court costs and attorney’s fees being due on the written contract, and pursuant to wrongfhl eviction and conversion and all other relief the Court deems just and equitable.

Outcome: Settled and dismissed with prejudice.

Plaintiff's Experts:

Defendant's Experts:

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