Oklahoma Federal Credit Union v. JACKIE DESHAUN WASHINGTON

IN THE DISTRICT COURT OF OKLAHOMA COUNTY STATE OF OKLAHOMA OKLAHOMA FEDERAL CREDIT UNION Plaintiff, vs. JACKIE DESHAUN WASHINGTON, Defendant. PETITION Plaintiff, Oklahoma Federal Credit Union ("PLAINTIFF"), for its cause of action against the Defendant, Jackie Deshaun Washington ("Defendant"), alleges and states as follows: 1. On or about June 28, 2022, Defendant executed a Promissory Note (hereinafter referred to as the "Contract") and became obligated to pay PLAINTIFF the principal amount of $52,039.89, plus interest at 14.8900% per annum, according to the terms of the Contract. A copy of the Contract is attached hereto as Exhibit "A". 2. As part of the Contract and to secure the performance of Defendant, Defendant executed a Security Agreement and granted PLAINTIFF a security interest in a 2019 Ram 1500 VIN: 1C6SRFKT6KN840550 (hereinafter referred as the "Collateral"). PLAINTIFF properly perfected its security interest in accordance with Oklahoma law. A copy of the Lien Entry is attached hereto as Exhibit "B". 3. Defendant failed to pay pursuant to the terms of the Contract, despite demand by PLAINTIFF, and are therefore in default under the Contract and Security Agreement. 4. As of December 15, 2026, the balance due on the Contract was $57,256.26. 5. PLAINTIFF is entitled to reasonable attorney's fees and its reasonable costs of collection under the terms of the Contract and Security Agreement and under 12 O.S. §936. 6. Because of Defendant’s default under the Contract and Security Agreement, PLAINTIFF has a special ownership or interest in the Collateral and is entitled to immediate possession of the Collateral. 7. The actual value of the Collateral is estimated at $31,000.00. 8. The Collateral has not been taken in execution on any order or judgment against PLAINTIFF, or for the payment of any tax, fine or amercement assessed against PLAINTIFF, or by virtue of an order of delivery issued under Chapter 31 of Title 12 of the Oklahoma Statutes, or for any other mesne or final process issued against PLAINTIFF. 9. PLAINTIFF believes that Defendant is in actual or constructive possession of the Collateral, and that Defendant’s possession is subject to the rights of PLAINTIFF. Although PLAINTIFF has demanded possession of the Collateral, Defendant failed to deliver or relinquish possession of the Collateral to PLAINTIFF. Defendant is, therefore, wrongfully detaining the Collateral. 10. PLAINTIFF believes that Defendant may attempt to conceal, damage or destroy the Collateral or a part thereof, or to remove the Collateral for the State or County, and PLAINTIFF will thereby suffer irreparable harm. PLAINTIFF is without adequate remedy at law to prevent such harm and injury. As such, PLAINTIFF respectfully requests this Court to enter an Order requiring Defendant to appear and disclose the location of the Collateral. 11. Pursuant to the Servicemember’s Civil Relief Act of 2003, PLAINTIFF has reviewed the Department of Defense website and determined Defendant is not in the military. See the Affidavit attached hereto as Exhibit “C”. 12. PLAINTIFF requests an Order authorizing it to issue subpoenas immediately pursuant to 12 O.S. §2004.1 related to the location of the Collateral and Defendant’s cell phone records and data. 13. Pursuant to 40 O.S. §4-508(D), PLAINTIFF requests an Order that at any time or times subsequent to the filing of this order, the Oklahoma Employment Security Commission shall produce, within thirty (30) days of receipt of this order, employment information of the Defendant. WHEREFORE, Oklahoma Federal Credit Union prays: (a) that the clerk of this Court issue the above-described notice to Defendant, and further that the notice inform Defendant, that pursuant to 12 O.S. §1571.1, any person who willfully or knowingly damages property in which there exists a valid right to issuance of an order of delivery, or on which such order shall be sought under the provisions of 12 O.S. §1571, or who conceals it, with intent to interfere with the enforcement of the order, or who removes it from the jurisdiction of this Court with the intention of defeating the enforcement of an order of delivery, or who willfully refuses to disclose its location to an officer charged with execution an order for its delivery, or who, when in possession of such property, willfully interferes with the officers charged with execution such writ, shall be guilty of a misdemeanor, and in addition to such criminal penalties as are provided by law, shall be liable to PLAINTIFF for double the amount of damages done to the property, together with a reasonable attorney's fees to be fixed by the Court; (b) that this Court enter money judgment for PLAINTIFF and against Defendant, in the amount of $57,256.26, plus interest since December 15, 2026, at a rate of 14.8900% until paid, plus PLAINTIFF's court costs and a reasonable attorney's fee; (c) that this Court issue an order for immediate delivery of the Collateral to PLAINTIFF; (d) that this Court issue an Order requiring Defendant to appear and disclose the location of the Collateral; (e) PLAINTIFF requests an Order authorizing it to issue subpoenas immediately pursuant to 12 O.S. §2004.1 to nonparties for the production of documentary evidence related to the location of the Collateral and Defendant’s cell phone records and data, (f) that this Court render judgment in favor of PLAINTIFF and against the Defendant for possession of the Collateral, decreeing that PLAINTIFF's interest in the Collateral is senior and prior to the interest of Defendant in the Collateral, and authorizing the foreclosure of PLAINTIFF's security interest in the Collateral, and (g) award all contractual charges as set forth in the Contract and all other relief this Court deems just. Respectfully submitted, Jeffery S. Ludlam, OBA #17822 HALL & LUDLAM, PLLC 210 Park Ave, Suite 3001 Oklahoma City, OK 73102 (405) 600-9500 Telephone (405) 871-5403 Facsimile [email protected] VERIFICATION STATE OF OKLAHOMA ) ) ss. COUNTY OF OKLAHOMA ) I, Robyn Bell, of lawful age, being first duly sworn upon oath, state: That I am an agent for the plaintiff, Oklahoma Federal Credit Union, the above-named; that I have read the above and foregoing Petition: that the matters, facts and things therein stated are true and correct to the best of my belief and knowledge. Subscribed and sworn to before me this 5TH day of January, 2026. Notary Public My Commission Expires: 1-24-26 LAW 553-OK-eps 7/21 RETAIL INSTALLMENT SALE CONTRACT SIMPLE FINANCE CHARGE Buyer Name and Address (Including County and Zip Code) JACKIE DESHAUN WASHINGTON 3500 SCHRODER LANE FOREST PARK, OK 73121 US Co-Buyer Name and Address (Including County and Zip Code) N/A Seller-Creditor (Name and Address) FOWLER DODGE 55 West I 240 Service Rd Oklahoma City, OK 73139 You, the Buyer (and Co-Buyer, if any), may buy the vehicle below for cash or on credit. By signing this contract, you choose to buy the vehicle on credit under the agreements in this contract. You agree to pay the Seller - Creditor (sometimes “we” or “us” in this contract) the Amount Financed and Finance Charge in U.S. funds according to the payment schedule below. We will figure your finance charge on a daily basis. The Truth-In-Lending Disclosures below are part of this contract. <table> <tr> <th>New/Used</th> <th>Year</th> <th>Make and Model</th> <th>Odometer</th> <th>Vehicle Identification Number</th> <th>Primary Use For Which Purchased</th> </tr> <tr> <td>USED</td> <td>2019</td> <td>RAM 1500</td> <td>54,259</td> <td>1C6SRFKT6KN840550</td> <td>Personal, family, or household unless otherwise indicated below<br>[ ] business<br>[ ] agricultural<br>[ ] N/A</td> </tr> </table> FEDERAL TRUTH-IN-LENDING DISCLOSURES <table> <tr> <th>ANNUAL PERCENTAGE RATE<br>The cost of your credit as a yearly rate.</th> <th>FINANCE CHARGE<br>The dollar amount the credit will cost you.</th> <th>Amount Financed<br>The amount of credit provided to you or on your behalf.</th> <th>Total of Payments<br>The amount you will have paid after you have made all payments as scheduled.</th> <th>Total Sale Price<br>The total cost of your purchase on credit, including your down payment of $830.54</th> </tr> <tr> <td>14.89 %</td> <td>$ 32,043.27</td> <td>$ 52,039.89</td> <td>$ 84,083.16</td> <td>$ 84,913.70</td> </tr> </table> Your Payment Schedule Will Be: (e) means an estimate <table> <tr> <th>Number of Payments</th> <th>Amount of Payments</th> <th>When Payments Are Due</th> </tr> <tr> <td>84</td> <td>$ 1,000.99</td> <td>MONTHLY beginning 07/28/2022</td> </tr> <tr> <td>N/A</td> <td>$ N/A</td> <td>N/A</td> </tr> <tr> <td colspan="3">N/A</td> </tr> </table> Late Charge. If payment is not received in full within 10 days after it is due, you will pay a late charge of $____27.00______ or ____5___% of the part of the payment that is late, whichever is greater. Prepayment. If you pay early, you will not have to pay a penalty. Security Interest. You are giving a security interest in the vehicle being purchased. Additional Information: See this contract for more information including information about nonpayment, default, any required repayment in full before the scheduled date and security interest. Used Car Buyers Guilde. The information you see on the window form for this vehicle is part of this contract. Information on the window form overrides any contrary provisions in the contract of sale. Spanish Translation: Guía para compradores de vehículos usados. La información que ve en el formulario de la ventana para este vehículo forma parte del presente contrato. La información del formulario de la ventana deja sin efecto toda disposición en contrario contenida en el contrato de venta. NO COOLING OFF PERIOD State law does not provide for a "cooling off" or cancellation period for this sale. After you sign this contract, you may only cancel it if the seller agrees or for legal cause. You cannot cancel this contract simply because you change your mind. This notice does not apply to home solicitation sales. ☐ VENDOR'S SINGLE INTEREST INSURANCE (VSI insurance): If the preceding box is checked, the Creditor requires VSI insurance for the initial term of the contract to protect the Creditor for loss or damage to the vehicle (collision, fire, theft, concealment, skip). VSI insurance is for the Creditor's sole protection. This insurance does not protect your interest in the vehicle. You may choose the insurance company through which the VSI Insurance is obtained. If you elect to purchase VSI insurance through the Creditor, the cost of this Insurance is $_________N/A_________ and is also shown in Item 4B of the Itemization of Amount Financed. The coverage is for the initial term of the contract. NOTICE: ANY HOLDER OF THIS CONSUMER CREDIT CONTRACT IS SUBJECT TO ALL CLAIMS AND DEFENSES WHICH THE DEBTOR COULD ASSERT AGAINST THE SELLER OF GOODS OR SERVICES OBTAINED PURSUANT HERETO OR WITH THE PROCEEDS HEREOF. RECOVERY HEREUNDER BY THE DEBTOR SHALL NOT EXCEED AMOUNTS PAID BY THE DEBTOR HEREUNDER. The preceding NOTICE applies only to goods or services obtained primarily for personal, family, or household use. In all other cases, Buyer will not assert against any subsequent holder or assignee of this contract any claims or defenses the Buyer (debtor) may have against the Seller, or against the manufacturer of the vehicle or equipment obtained under this contract. Buyer Signs X ________ Co-Buyer Signs X ________ N/A ___________ Original ITEMIZATION OF AMOUNT FINANCED 1 Cash Price (including S N/A sales/excise tax) $ 49,781.43 (1) 2 Total Downpayment = Trade-in 2010 DODGE CHALLENGER (Year) (Make) (Model) Gross Trade-In Allowance $ 14,000.00 Less Pay Off Made By Seller to N/A $ 13,169.48 Equals Net Trade In $ 830.54 +Cash $ N/A +Other N/A $ N/A +Other N/A $ N/A +Other N/A $ N/A If total downpayment is negative, enter "0" and see 4I below) $ 830.54 (2) 3 Unpaid Balance of Cash Price (1 minus 2) $ 48,950.88 (3) 4 Other Charges Including Amounts Paid to Others on Your Behalf (Seller may keep part of these amounts): A Cost of Optional Credit Insurance Paid to Insurance Company or Companies. Life $ N/A Disability $ N/A B Vendor's Single Interest Insurance Paid to Insurance Company $ N/A C Other Optional Insurance Paid to Insurance Company or Companies $ N/A D Optional Gap Contract $ 340.00 E Official Fees Paid to Government Agencies to N/A for N/A $ N/A to N/A for N/A $ N/A to N/A for N/A $ N/A F Government Taxes Not Included in Cash Price $ N/A G Government License and/or Registration Fees N/A LICENSE AND/OR REG FEES $ 2,340.00 H Government Certificate of Title Fees $ N/A I Other Charges (Seller must identify who is paid and describe purpose.) to N/A for Prior Credit or Lease Balance $ N/A to FOWLER DODGE for DOC FEE $ 399.00 to N/A for N/A $ N/A to N/A for N/A $ N/A to N/A for N/A $ N/A to N/A for N/A $ N/A to N/A for N/A $ N/A to N/A for N/A $ N/A to N/A for N/A $ N/A to N/A for N/A $ N/A to N/A for N/A $ N/A to N/A for N/A $ N/A Total Other Charges and Amounts Paid to Others on Your Behalf $ 3,079.00 (4) 5 Amount Financed (3 + 4) $ 52,039.89 (5) OPTION: □ You pay no finance charge if the Amount Financed, item 5, is paid in full on or before N/A , Year N/A . SELLER'S INITIALS N/A OPTIONAL GAP CONTRACT. A gap contract (debt cancellation contract) is not required to obtain credit and will not be provided unless you sign below and agree to pay the extra charge. If you choose to buy a gap contract, the charge is shown in Item 4D of the Itemization of Amount Financed. See your gap contract for details on the terms and conditions it provides. It is a part of this contract. Term 84 Mos. CARCO Name of Gap Contract I want to buy a gap contract. Buyer Signs X Signature Returned Check Charge: You agree to pay a charge of $ 25.00 if any check you give us is dishonored! Buyer Signs X Signature Co-Buyer Signs X N/A Insurance. You may buy the physical damage insurance this contract requires from anyone you choose who is acceptable to us. You may also provide the physical damage insurance through an existing policy owned or controlled by you that is acceptable to us. You are not required to buy any other insurance to obtain credit unless the box indicating Vendor's Single Interest Insurance is required is checked on page 1 of this contract. If any insurance is checked below, policies or certificates from the named insurance companies will describe the terms and conditions. Check the insurance you want and sign below: Optional Credit Insurance □ Credit Life: □ Buyer □ Co-Buyer □ Both □ Credit Disability: □ Buyer □ Co-Buyer □ Both Premium: Credit Life S N/A Credit Disability $ N/A Insurance Company Name N/A N/A Home Office Address N/A N/A Credit life insurance and credit disability insurance are not required to obtain credit. Your decision to buy or not buy credit life insurance and credit disability insurance will not be a factor in the credit approval process. They will not be provided unless you sign and agree to pay the extra cost. If you choose this insurance, the cost is shown in Item 4A of the Itemization of Amount Financed. Credit life insurance is based on your original payment schedule. This insurance may not pay all you owe on this contract if you make late payments. Credit disability insurance does not cover any increase in your payment or in the number of payments. Coverage for credit life insurance and credit disability insurance ends on the original due date for the last payment unless a different term for the insurance is shown below. Other Optional Insurance □ Type of Insurance N/A Term N/A Insurance Company Name N/A Home Office Address N/A □ Type of Insurance N/A Term N/A Insurance Company Name N/A Home Office Address N/A Other optional insurance is not required to obtain credit. Your decision to buy or not buy other optional insurance will not be a factor in the credit approval process. It will not be provided unless you sign and agree to pay the extra cost. I want the insurance checked above. X N/A N/A Buyer Signature Date X N/A N/A Co-Buyer Signature Date THIS INSURANCE DOES NOT INCLUDE INSURANCE ON YOUR LIABILITY FOR BODILY INJURY OR PROPERTY DAMAGE CAUSED TO OTHERS. WITHOUT SUCH INSURANCE YOU MAY NOT OPERATE THIS VEHICLE ON PUBLIC HIGHWAYS. LAW 553-OK-eps 7/21 v1 Page 2 of 4 OTHER IMPORTANT AGREEMENTS 1. FINANCE CHARGE AND PAYMENTS a. How we will figure Finance Charge. We will figure the Finance Charge on a daily basis at the Annual Percentage Rate on the unpaid part of the Amount Financed. b. How we will apply payments. We may apply each payment to the earned and unpaid part of the Finance Charge, to the unpaid part of the Amount Financed and to other amounts you owe under this contract in any order we choose as the law allows. c. How late payments or early payments change what you must pay. We based the Finance Charge, Total of Payments, and Total Sale Price shown on page 1 of this contract on the assumption that you will make every payment on the day it is due. Your Finance Charge, Total of Payments, and Total Sale Price will be more if you pay late and less if you pay early. Changes may take the form of a larger or smaller final payment or, at our option, more or fewer payments of the same amount as your scheduled payment with a smaller final payment. We will send you a notice telling you about these changes before the final scheduled payment is due. d. You may prepay. You may prepay all or part of the unpaid part of the Amount Financed at any time without penalty. If you do so, you must pay the earned and unpaid part of the Finance Charge and all other amounts due up to the date of your payment. e. Your right to refinance a balloon payment. A balloon payment is a scheduled payment that is more than twice as large as the average of your earlier scheduled payments. If you are buying the vehicle primarily for personal, family or household use, you have the right to refinance the balloon payment when due without penalty. The terms of the refinancing will be no less favorable to you than the terms of this contract. This provision does not apply if we adjusted your payment schedule to your seasonal or irregular income. 2. YOUR OTHER PROMISES TO US a. If the vehicle is damaged, destroyed, or missing. You agree to pay us all you owe under this contract even if the vehicle is damaged, destroyed, or missing. b. Using the vehicle. You agree not to remove the vehicle from the U.S. or Canada, or to sell, rent, lease, or transfer any interest in the vehicle or this contract without our written permission. You agree not to expose the vehicle to misuse, seizure, confiscation, or involuntary transfer. If we pay any repair bills, storage bills, taxes, fines, or charges on the vehicle, you agree to repay the amount when we ask for it. c. Security Interest. You give us a security interest in: • The vehicle and all parts or goods put on it; • All money or goods received (proceeds) for the vehicle; • All insurance, maintenance, service, or other contracts we finance for you; and • All proceeds from insurance, maintenance, service, or other contracts we finance for you. This includes any refunds of premiums or charges from the contracts. This secures payment of all you owe on this contract. It also secures your other agreements in this contract. You will make sure the title shows our security interest (lien) in the vehicle. You will not allow any other security interest to be placed on the title without our written permission. d. Insurance you must have on the vehicle. You agree to have physical damage insurance covering loss of or damage to the vehicle for the term of this contract. The insurance must cover our interest in the vehicle. You agree to name us on your insurance policy as an additional insured and as loss payee. If you do not have this insurance, we may, if we choose, buy physical damage insurance. If we decide to buy physical damage insurance, we may either buy insurance that covers your interest and our interest in the vehicle, or buy insurance that covers only our interest. If we buy either type of insurance, we will tell you which type and the charge you must pay. The charge will be the premium for the insurance and a finance charge computed at the Annual Percentage Rate shown on page 1 of this contract. If the vehicle is lost or damaged, you agree that we may use any insurance settlement to reduce what you owe or repair the vehicle. e. What happens to returned insurance, maintenance, service, or other contract charges. If we get a refund of insurance, maintenance, service, or other contract charges, you agree that we may subtract the refund from what you owe. 3. IF YOU PAY LATE OR BREAK YOUR OTHER PROMISES a. You may owe late charges. You will pay a late charge on each late payment as shown on page 1 of this contract. Acceptance of a late payment does not excuse your late payment or mean that you may keep making late payments. If you pay late, we may also take the steps described below. b. You may have to pay all you owe at once. If you break your promises (default), we may demand that you pay all you owe on this contract at once. Default means: • You do not pay any payment on time; • You give false, incomplete, or misleading information during credit application; • You start a proceeding in bankruptcy or one is started against you or your property; or • You break any agreements in this contract. The amount you will owe will be the unpaid part of the Amount Financed plus the earned and unpaid part of the Finance Charge, any late charges, and any amounts due because you defaulted. c. You may have to pay collection costs. If we hire an attorney who is not our salaried employee to collect what you owe, you will pay the attorney's fee and court costs the law permits. The maximum attorney's fee you will pay will be 15% of the amount you owe, unless a court awards an additional amount. d. We may take the vehicle from you. If you default, we may take (repossess) the vehicle from you if we do so peacefully and if the law allows it. If your vehicle has an electronic tracking device (such as GPS), you agree that we may use the device to find the vehicle. If we take the vehicle, any accessories, equipment, and replacement parts will stay with the vehicle. If any personal items are in the vehicle, we may store them for you. If you do not ask for these items back, we may dispose of them as the law allows. e. How you can get the vehicle back if we take it. If we repossess the vehicle, you may pay to get it back (redeem). We will tell you how much to pay to redeem. Your right to redeem ends when we sell the vehicle. f. We will sell the vehicle if you do not get it back. If you do not redeem, we will sell the vehicle. We will send you a written notice of sale before selling the vehicle. We will apply the money from the sale, less allowed expenses, to the amount you owe. Allowed expenses are expenses we pay as a direct result of taking the vehicle, holding it, preparing it for sale, and selling it. Attorney fees and court costs, if the law permits, are also allowed expenses. If any money is left (surplus), we will pay it to you unless the law requires us to pay it to someone else. If money from the sale is not enough to pay the amount you owe, you must pay the rest to us unless the law provides otherwise. If you do not pay this amount when we ask, we may charge you interest at a rate not exceeding the highest lawful rate until you pay. g. What we may do about optional insurance, maintenance, service, or other contracts. This contract may contain charges for optional insurance, maintenance, service, or other contracts. If we demand that you pay all you owe at once or we repossess the vehicle, you agree that we may claim benefits under these contracts and cancel them to obtain refunds of unearned charges to reduce what you owe or repair the vehicle. If the vehicle is a total loss because it is confiscated, damaged, or stolen, we may claim benefits under these contracts and cancel them to obtain refunds of unearned charges to reduce what you owe. The Annual Percentage Rate may be negotiable with the Seller. The Seller may assign this contract and retain its right to receive a part of the Finance Charge. HOW THIS CONTRACT CAN BE CHANGED. This contract contains the entire agreement between you and us relating to this contract. Any change to this contract must be in writing and we must sign it. No oral changes are binding. Buyer Signs X 9/28/2022 Co-Buyer Signs X N/A If any part of this contract is not valid, all other parts stay valid. We may delay or refrain from enforcing any of our rights under this contract without losing them. For example, we may extend the time for making some payments without extending the time for making others. See the rest of this contract for other important agreements. NOTICE TO RETAIL BUYER: Do not sign this contract in blank. You are entitled to a copy of the contract at the time you sign. Keep it to protect your legal rights. You agree to the terms of this contract. You confirm that before you signed this contract, we gave it to you, and you were free to take it and review it. You confirm that you received a completely filled-in copy when you signed it. Buyer Sign X 9/28/2022 Date 06/28/2022 Co-Buyer Sign X N/A Date N/A Buyer Printed Name JACKIE DESHAUN WASHINGTON Co-Buyer Printed Name N/A If the "business" use box is checked in "Primary Use for Which Purchased": Print Name N/A Co-Buyers and Other Owners — A co-buyer is a person who is responsible for paying the entire debt. An other owner is a person whose name is on the title to the vehicle but does not have to pay the debt. The other owner agrees to the security interest in the vehicle given to us in this contract. Other owner signs here X N/A Address N/A N/A Seller signs FOWLER DODGE Date 06/28/2022 By X Title Seller assigns its interest in this contract to OKLAHOMA FEDERAL CREDIT UNION (Assignee) under the terms of Seller's agreement(s) with Assignee. ☐ Assigned with recourse ☒ Assigned without recourse ☐ Assigned with limited recourse Seller FOWLER DODGE By X Title OKLAHOMA TAX COMMISSION LIEN HOLDERS RELEASE FORMS VIN: 1C6SRFKT6KN840550 VEHYR: 2019 MAKE: RAM MODEL: 1500 BODY: PK AGNT #: M1422 LIEN DATE: 06/28/2022 LIEN DEBTOR: WASHINGTON JACKIE DESHAUN WASHINGTON JACKIE DESHAUN 3500 SCHROEDER LN FOREST PARK OK 73121-4034 LIEN HOLDER: OKLAHOMA FEDERAL CREDIT UNION OKLAHOMA FEDERAL CREDIT UNION PO BOX 18483 OKLAHOMA CITY OK 73154-0483 TO: OKLAHOMA TAX COMMISSION MOTOR VEHICLE DIVISION P.O. BOX 269061 OKLAHOMA CITY OK 73126 REF#: L0212871368 TO WHOM IT MAY CONCERN: WE HAVE RELEASED OUR SECURITY INTEREST IN THE MOTOR VEHICLE DESCRIBED ABOVE, EFFECTIVE ON THE DATE WHICH APPEARS BY MY SIGNATURE. PLEASE REVISE YOUR RECORDS TO REFLECT THIS RELEASE. SIGNATURE OF REPRESENTATIVE OF SECURED PARTY X ________________________________ DATE __________________ LENDER: TO ENSURE PROPER PROCESSING OF YOUR COMPLETED LIEN RELEASE, PLEASE NOTE THE FOLLOWING. DO NOT ALTER THIS DOCUMENT NO STAPLES NO TAPE NO FOREIGN FIXTURES OR ATTACHMENTS NO WRITING OR MARKING (OTHER THAN SIGNATURE AND DATE FOR RELEASE) DO NOT ALTER THE SIZE OF THIS DOCUMENT IN THE DISTRICT COURT OF OKLAHOMA COUNTY STATE OF OKLAHOMA OKLAHOMA FEDERAL CREDIT ) UNION ) ) Plaintiff, ) Case No. vs. ) JACKIE DESHAUN WASHINGTON, ) Defendant. ) SCRA AFFIDAVIT State of Oklahoma ) County of Oklahoma ) I, Lisa J. Ludlam, state that I am an attorney for Hall & Ludlam, PLLC, authorized to make this affidavit on its behalf in this case. As of the current date, the Defendant, JACKIE DESHAUN WASHINGTON, is not in military service according to the SCRA website. I have used the Servicemembers Civil Relief Act Website (https://scra.dmdc.osd.mil/) to determine the Defendant’s military status as attached hereto. Pursuant to 28 U.S.C. § 1746 and 12 O.S. § 426, I state under penalty of perjury that the foregoing is true and correct. Executed on February 13, 2026. Lisa J. Ludlam, OBA 18267 HALL & LUDLAM, PLLC 210 Park Ave., Ste. 3001 Oklahoma City, OK 73102 P: 405-600-9500 | E: [email protected] [email protected] Attorneys for Oklahoma Federal Credit Union Status Report Pursuant to Servicemembers Civil Relief Act SSN: XXX-XX-8800 Birth Date: Feb-XX-1980 Last Name: WASHINGTON First Name: JACKIE Middle Name: DESHAUN Status As Of: Feb-13-2026 Certificate ID: N5ZY0W772KBPBD7 <table> <tr> <th colspan="4">On Active Duty On Active Duty Status Date</th> </tr> <tr> <th>Active Duty Start Date</th> <th>Active Duty End Date</th> <th>Status</th> <th>Service Component</th> </tr> <tr> <td>NA</td> <td>NA</td> <td>No</td> <td>NA</td> </tr> <tr> <td colspan="4">This response reflects the individuals' active duty status based on the Active Duty Status Date</td> </tr> </table> <table> <tr> <th colspan="4">Left Active Duty Within 367 Days of Active Duty Status Date</th> </tr> <tr> <th>Active Duty Start Date</th> <th>Active Duty End Date</th> <th>Status</th> <th>Service Component</th> </tr> <tr> <td>NA</td> <td>NA</td> <td>No</td> <td>NA</td> </tr> <tr> <td colspan="4">This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date</td> </tr> </table> <table> <tr> <th colspan="4">The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date</th> </tr> <tr> <th>Order Notification Start Date</th> <th>Order Notification End Date</th> <th>Status</th> <th>Service Component</th> </tr> <tr> <td>NA</td> <td>NA</td> <td>No</td> <td>NA</td> </tr> <tr> <td colspan="4">This response reflects whether the individual or his/her unit has received early notification to report for active duty</td> </tr> </table> Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, Space Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 3901 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service. Service contact information can be found on the SCRA website's FAQ page (Q35) via this URL: https://scra.dmdc.osd.mil/scra/#/faqs. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 3921(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided.