CREDIT ACCEPTANCE CORPORATION v. PAULA J. PENA

IN THE DISTRICT COURT OF BRYAN COUNTY STATE OF OKLAHOMA CREDIT ACCEPTANCE CORPORATION, Plaintiff, v. PAULA J. PENA, Defendant. Case No. CJ-260-80 PETITION COMES NOW the Plaintiff, Credit Acceptance Corporation, and for its cause of action against the Defendant alleges and states as follows: 1. Plaintiff is authorized by law to bring this action in this County. The Defendant can be properly served with process. 2. The Defendant is indebted to the Plaintiff in the sum of $18,427.53 for balance due on contract. Said sum is due and owing after application of all credits. 3. Plaintiff is entitled to receive a reasonable attorney's fee. WHEREFORE, Plaintiff prays for judgment against the Defendant for the principal sum of $18,427.53, plus interest from the date of Judgment, until paid, a reasonable attorney’s fee, costs and such other relief as this Court deems just and proper. Respectfully submitted, ______________________________ Greg A. Metzer, OBA No. 11432 METZER & AUSTIN, P.L.L.C. 1 South Broadway, Suite 100 Edmond, OK 73034 (405) 330-2226 (405) 330-2234 (FAX) [email protected] ATTORNEY FOR PLAINTIFF