JEFFERSON CAPITAL SYSTEMS LLC v. SARA MURPHY

IN THE DISTRICT COURT OF TULSA COUNTY STATE OF OKLAHOMA JEFFERSON CAPITAL SYSTEMS LLC, Plaintiff, vs. SARA MURPHY Defendant(s). Case No. PETITION COMES NOW the Plaintiff, by and through counsel, Nelson and Kennard, LLP, and herewith alleges the following and seeks redress as hereafter delineated. 1. Plaintiff is a national debt collection agency, which transacts business within the State of Oklahoma. 2. Venue is proper in this County, as the Defendant(s) reside(s) in this County at the commencement of this action, or the contract which is the subject matter of this action was made, executed, and delivered in this County. 3. The last four (4) digits of the Defendant’s account number, used by the original creditor as of the date of default are XXXXXXXXXXXXX6721. 4. Plaintiff’s claim arises when the Defendant(s) opened a credit account and failed to make the required monthly payments as agreed. The credit account charged off for non-payment on 3/08/24, the balance due at time of default is as follows $4,283.18. A true and accurate copy of the last periodic statement provided to the Defendant(s) prior to charge-off is attached hereto as Exhibit 1. A true and accurate copy of the ownership of the credit card account is attached hereto as Exhibit 2. 5. The Defendant(s) breached the Contract by failing to make the required periodic payments. 6. As a direct and proximate result of the Defendant(s) default, the total amount of debt claimed is $4,283.18. 7. The date of the last payment made by the Defendant(s) is August 9, 2023. 8. Plaintiff seeks court costs, and for such further relief as the Court may deem proper in the premises. WHEREFORE, Plaintiff, JEFFERSON CAPITAL SYSTEMS LLC prays for judgment against the Defendant(s), SARA MURPHY in the amount of $4,283.18, plus all costs herein expended, including but not limited to, court costs, sheriff’s fees, and special process server fees, attorney fees; and for such other and further relief as the Court may deem proper in the premises. Dated this January 8, 2026 Nelson and Kennard, LLP By: ____________________________ Ashton Dewayne Sears, OBA # 35737 12596 W. Bayaud Ave., Ste. 120 Lakewood, CO 80228 Phone: 866-920-2295 [email protected] Attorney for the Plaintiff EXHIBIT 1 PayPal CREDIT Statement Closing Date: 03/08/24 Days in Billing Period: 30 Account Number: [redacted] 6721 Customer Name: SARA MURPHY ACCOUNT SUMMARY Previous Balance $4,242.18 - Payments & Credits $4,283.18 + Purchases & Adjustments $0.00 + Fees $41.00 + INTEREST CHARGES $0.00 = New Balance $0.00 Credit Limit $3,400.00 Available Credit $0.00 PAYMENT INFORMATION New Balance $0.00 Minimum Payment Due $922.00 Payment Due Date 03/10/24 Amount to avoid Standard and Deferred Interest on your next statement: $4,283.18 See Reverse Late Payment Warning: If we do not receive your minimum payment by 03/10/24, you may have to pay a late fee of up to $41.00. CURRENT ACTIVITY PAYMENTS & CREDITS <table> <tr> <th>Tran Date</th> <th>Posting Date</th> <th>Reference Number</th> <th>Description</th> <th>Amount</th> </tr> <tr> <td>03/08/24</td> <td>03/08/24</td> <td>F928300EL00999990</td> <td>Charge Off Account-Principals</td> <td>-$3,350.37</td> </tr> <tr> <td>03/08/24</td> <td>03/08/24</td> <td>F928300EL00999990</td> <td>Charge Off Account-Interest Charge</td> <td>-$615.81</td> </tr> <tr> <td>03/08/24</td> <td>03/08/24</td> <td>F928300EL00999990</td> <td>Charge Off Account - Fee</td> <td>-$317.00</td> </tr> <tr> <td colspan="5">Total Payments & Credits -$4,283.18</td> </tr> </table> FEES <table> <tr> <th>Tran Date</th> <th>Posting Date</th> <th>Description</th> <th>Amount</th> </tr> <tr> <td>03/02/24</td> <td>03/02/24</td> <td>Late Fee</td> <td>$41.00</td> </tr> <tr> <td colspan="3">Total Fees</td> <td>$41.00</td> </tr> </table> 2024 Totals Year-To-Date Total Fees Charged in 2024: $123.00 Total Interest Charged in 2024: $472.69 INTEREST DETAILS INTEREST CHARGE CALCULATION <table> <tr> <th>Balance Type</th> <th>Annual Percentage Rate (APR)</th> <th>Balance Subject to Interest Rate</th> <th>Interest Charged</th> <th>Current Balance</th> </tr> <tr> <td>Standard Purchases</td> <td>29.24% (v)</td> <td>$0.00</td> <td>$0.00</td> <td>-$68.42</td> </tr> <tr> <td>PayPal Send Money Cash Advances</td> <td>29.24% (v)</td> <td>$0.00</td> <td>$0.00</td> <td>$0.00</td> </tr> </table> DEFERRED INTEREST CALCULATION <table> <tr> <th>Promotion Type</th> <th>Posting Date</th> <th>Annual Percentage Rate(APR)</th> <th>Expiration Date</th> <th>Monthly Accrued Deferred Interest</th> <th>Total Accrued Deferred Interest</th> <th>Deferred Interest Balance</th> </tr> <tr> <td>No Interest If Paid In Full</td> <td>08/05/23</td> <td>29.24%(v)</td> <td>03/10/24*</td> <td>$0.00</td> <td>$0.00</td> <td>$52.13*</td> </tr> <tr> <td>No Interest If Paid In Full</td> <td>08/05/23</td> <td>29.24%(v)</td> <td>03/10/24*</td> <td>$0.00</td> <td>$0.00</td> <td>$16.29*</td> </tr> </table> (v)=Variable Rate *You must pay your deferred interest balance in full by the expiration date above to avoid paying accrued deferred interest charges NOTICE: We may convert your payment into an electronic debit. See reverse for details, Billing Rights Information and other Important Information Customer Service: For account information, call the number on the front of this statement. For Hearing or Speech disabilities, use a TRS. Unless your name is listed on this statement, your access to information on the account may be limited. You may also mail questions (but not payments) to: P.O. Box 71726, Philadelphia, PA 19176-1726. Please include your account number on any correspondence you send to us. Payments: Send payments to the address listed on the remit portion of this statement or pay online at www.paypal.com. Notice: See below for your Billing Rights and other important information. Purchases, returns, and payments made just prior to billing date may not appear until next month's statement. When you provide a check as payment, you authorize us either to use information from your check to make a one-time electronic fund transfer from your account or to process the payment as a check transaction. When we use information from your check to make an electronic fund transfer, funds may be withdrawn from your account as soon as the same day we receive your payment, and you will not receive your check back from your financial institution. You may choose not to have your payment collected electronically by sending your payment (with the payment stub), in your own envelope – not the enclosed window envelope, addressed to: P.O. Box 669826, Dallas, TX 75266-0783 and not the Payment Address. What To Do If You Think You Find A Mistake On Your Statement If you think there is an error on your statement, write to us at: Synchrony Bank, P.O. Box 71725, Philadelphia, PA 19176-1725. Or call customer service at 1-844-373-4961. If you write to us, in your letter, give us the following information: • Account Information: Your name and account number. • Dollar Amount: The dollar amount of the suspected error. • Description Of Problem: If you think there is an error on your bill, describe what you believe is wrong and why you believe it is a mistake. You must contact us within 60 days after the error appeared on your statement. You must notify us of any potential errors in writing or by calling customer service at 1-844-373-4961. While we investigate whether or not there has been an error, the following are true: • We cannot try to collect the amount in question, or report you as delinquent on that amount. • The charge in question may remain on your statement, and we may continue to charge you interest on that amount. But, if we determine that we made a mistake, you will not have to pay the amount in question or any interest or other fees related to that amount. • While you do not have to pay the amount in question, you are responsible for any other remaining charges on your account. Your Rights If You Are Dissatisfied With Your Credit Card Purchases If you are dissatisfied with the goods or services that you have purchased with your credit card, and you have tried in good faith to correct the problem with the merchant, you may have the right not to pay the remaining amount due on the purchase. To use this right, all of the following must be true: 1. The purchase must have been made in your home state or within 100 miles of your current mailing address, and the total price must have been less than $50. (Note: Neither of these are necessary if your purchase was based on an advertisement we mailed to you, or if we own the company that sold you the goods or services.) 2. You must have used your credit card for the purchase. Purchases made with cash advances from an ATM, or with a check that accesses your credit card account do not qualify. 3. You must not yet have fully paid for the purchase. If all of the criteria above are met and you are still dissatisfied with the purchase, contact us in writing at: Synchrony Bank, P.O. Box 71725, Philadelphia, PA 19176-1725 Or call customer service at 1-844-373-4961 While we investigate, the same rules apply to the disputed amount as discussed above. After we finish our investigation, we will tell you our decision. At that point, if we think you owe an amount and you do not pay we may report you as delinquent. Information About Payments: You may at any time pay, in whole or in part, the total unpaid balance or any part of the total unpaid balance, before the payment is received by us; however, no payment will be credited as of the next day. Credit to your Account may be delayed up to five days if payment (a) is not received at the Payment Address, (b) is not made in U.S. dollars drawn on a U.S. financial institution located in the U.S., (c) is not accompanied by the remittance coupon attached to your statement, (d) contains more than one payment or remittance coupon, or (e) includes staples, paper clips, tape, a folded check, or correspondence of any type. Payments Made By Phone Or Online: If you make a payment by phone or online before 11:59 p.m. Eastern Time, we will credit it as of the date the payment is made. Consumer Protection: All written communications concerning disputed amounts, including any check or other payment instrument that: (i) indicates that the payment constitutes "payment in full" or is tendered in full satisfaction of a disputed amount; or (ii) is tendered with other conditions or limitations ("Disputed Payments"), must be mailed or delivered to us at P.O. Box 71725, Philadelphia, PA 19176-1725. Credits To Your Account: An amount shown in parentheses or preceded by a minus (-) sign is a credit or credit balance unless otherwise indicated. Credits will be applied to your previous balance immediately upon receipt, but will not satisfy any required payment that may be due. Credit Reports And Account Information: If you believe that we have reported inaccurate information about you to a consumer reporting agency, please contact us at P.O. Box 71727, Philadelphia, PA 19176-1727. In doing so, please identify the inaccurate information and tell us why you believe it is incorrect. If you have a copy of the credit report that includes the inaccurate information, please include a copy of that report. We may report information about your account to credit bureaus. Late payments, missed payments, or other defaults on your account may be reflected in your credit report. Payment Interest: We will not charge you any interest on non-promotional transactions if you pay your entire balance by the due date each month. Please refer to the due date shown on the front of your statement. We will begin charging interest on promotional purchases on the purchase date. How We Calculate Interest We calculate interest on your account for each billing cycle separately for each balance type. A separate average daily balance is calculated for the following balance types, as applicable: standard purchases, cash advances and promotional purchases. To get the average daily balance, we take the closing balance each day, including billed interest and billed fees, add the daily interest amount from the previous day and any credits and adjustments posted that day and subtract any payments or credits (treating any net credit balance as zero). This gives us the daily balance. Then, we add up all the daily balances for the billing cycle and divide the total by the number of days in the billing cycle. The result is the average daily balance. We multiply the average daily balance by the applicable daily rate to get the daily interest amount. Then we multiply the daily interest amount by the number of days in the billing cycle to determine the interest charges. Amount To Avoid Standard And Deferred Interest On Your Next Statement: This amount includes: Standard Purchases and Cash Advances Purchases without any promotional offer and Cash Advances. Promoted Incentives Not Expiring This Billing Cycle Purchases made with 'No Payments + No Interest if paid in full' and 'No Interest if paid in full' promotions that are about to expire. Easy Payments Purchases Monthly Plan Payments Although unrelated to avoiding Standard and Deferred Interest, we include Monthly Plan Payments to help you avoid late fees. If you have a Financed Easy Payments Purchase balance, you will continue to be assessed interest on the Easy Payments Purchase balance until it is paid in full. Your Account Is owned and serviced by Synchrony Bank. [WF64555521KA] O1HA6128 - 03/09/23 Bankruptcy Notice: If you file bankruptcy, you must send us notice, including account number and all information related to the proceeding to the following address: Synchrony Bank, Attn: Bankruptcy Dept., P.O. Box 71783, Philadelphia, PA 19176-1783. This is an attempt to collect a debt and any information obtained will be used for that purpose. *By providing a telephone number on your account, you consent to Synchrony Bank and any other owner or servicer of your account contacting you about your account, including using any contact information or cell phone numbers you provide, and you consent to the use of any automatic telephone dialing system and/or an artificial or prerecorded voice when contacting you, even if you are charged for the call under your phone plan. For changes of address, phone number and/or email, please check the box and print the changes below. These changes will be applied to PayPal Credit but not to your PayPal Account. Street Address City, State ZIP Phone # Email *Home Phone # *Business Phone # *Cell # or other phone # we can use to contact you **Email Address ** By providing your email address, you agree to receive email communications about your account and also give permission for us to share your email address with PayPal Credit. Statement Closing Date: 03/08/24 Days in Billing Period: 30 Account Number: 6044 1910 8521 6721 Customer Name: SARA MURPHY View your account online at paypal.com Or call 1-844-377-4138 AM ET to 11 PM ET Mon-Fri and 9 AM ET to 9 PM ET Sat-Sun ACCOUNTHOLDER NOTICES If you need to contact Synchrony about the loss of a Synchrony cardholder, you can submit a deceased notification form located at www.syf.com under the 'Contact Us' page. Statement not provided to customer. This is a duplicate courtesy copy of your most recent billing statement. You can still view and pay your electronic statement online. [No text present on this page] EXHIBIT 2 synchrony 965 Keller Rd Altamonte Springs, FL 32714 BILL of SALE Jefferson Capital (SFFLJPPS) – PLCC PayPal Fresh – April 2024 Transfer Date: 4/13/2024 For value received and in further consideration of the mutual covenants and conditions set forth in the Master Account Sale Agreement (the “Agreement”), dated as of this 10th day of July, 2023 by and between Synchrony Bank formerly known as GE Capital Retail Bank; RFS Holding, LLC, Synchrony Card Funding, LLC and Retail Finance Credit Services, LLC., (“Seller”) and Jefferson Capital Systems, LLC (“Buyer”), Seller hereby transfers, sells, conveys, grants, and delivers to Buyer, its successors and assigns, without recourse except as set forth in the Agreement, to the extent of its ownership, the Accounts as set forth in the Notification Files (as defined in the Agreement and Account Sale Addendum dated 08/01/2023), delivered by Seller to Buyer on or about 13th of April, 2024, and as further described in the Agreement. The aggregate Sale Balance of the accounts as of the Transfer Date was Synchrony Bank By: Lynne Fisher 4/29/2024 Lynne Fisher Title: SVP Recovery Operations RFS Holding LLC By: Lynne Fisher 4/29/2024 Lynne Fisher Title: Duly Authorized Signatory Synchrony Card Funding, LLC By: Lynne Fisher 4/29/2024 Lynne Fisher Title: Duly Authorized Signatory Retail Finance Credit Services, LLC By: Lynne Fisher 4/29/2024 Lynne Fisher Title: Vice President Name | Social Security Number | Account Number | Seller Account Number | Open Date [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] SARA MURPHY | XXX-XX-6795 | xxxxxxxxxxxxxxxx6721 | xxxxxxxxxxxxxx | 6/15/2023 [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] [Redacted] | [Redacted] | [Redacted] | [Redacted] | [Redacted] LEGEND: [Redacted] indicates that all data for these records is redacted to protect other Consumers who were included in the same sale file but not part of the current action. Social Security Number, Account Number, and Seller Account Number information is masked to prevent only the last four characters in order to protect Consumer information. <table> <tr> <th>Charge Off Date</th> <th>Charge Off Amount</th> <th>Purchased Balance</th> <th>Last Payment Date</th> <th>Last Payment Amount</th> </tr> <tr> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> </tr> <tr> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> </tr> <tr> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> </tr> <tr> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> </tr> <tr> <td><b>3/08/2024</b></td> <td>$4,283.18</td> <td>$4,283.18</td> <td><b>8/09/2023</b></td> <td>$30.00</td> </tr> <tr> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> </tr> <tr> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> </tr> <tr> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> </tr> <tr> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> </tr> <tr> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> </tr> <tr> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> </tr> <tr> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> </tr> <tr> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> </tr> <tr> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> </tr> <tr> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> </tr> <tr> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> </tr> <tr> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> </tr> <tr> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> </tr> <tr> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> </tr> <tr> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> </tr> <tr> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> <td>[Redacted]</td> </tr> </table> LEGEND: [Redacted] indicates that all data for these records is redacted to protect other Consumers who were included in the same sale file but not part of the current action. Social Security Number, Account Number, and Seller Account Number information is masked to present only the last four characters in order to protect Consumer information. [Co Borrower Name] [Original Creditor] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] SYNCHRONY BANK [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted] [Redacted]