Oklahoma Federal Credit Union v. Sue Vicki Thomas

IN THE DISTRICT COURT OF KAY COUNTY STATE OF OKLAHOMA OKLAHOMA FEDERAL CREDIT UNION Plaintiff, vs. SUE VICKI THOMAS, Defendant. PETITION Plaintiff, Oklahoma Federal Credit Union ("Plaintiff"), for its cause of action against the Defendant, Sue Vicki Thomas ("Defendant"), alleges and states as follows: 1. On or about January 16, 2024, Defendant executed a Promissory Note (hereinafter referred to as the "Contract") and became obligated to pay Plaintiff the principal amount of $16,299.00, plus interest at 15.9900% 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 2017 Fiat Spider VIN: JC1NFAEK6H0102089 (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, 2025, the balance due on the Contract was $23,400.79. 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 $7,450.00. 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. WHEREOFRE, 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 $23,400.79, plus interest since December 15, 2025, at a rate of 15.9900% 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. [Signature] Executive Vice President Subscribed and sworn to before me this 5TH day of January, 2026. [Signature] Notary Public My Commission Expires: 1-24-26 RETAIL INSTALLMENT SALE CONTRACT – SIMPLE FINANCE CHARGE (WITH ARBITRATION PROVISION) Buyer Name and Address (including County and Zip Code) Over-Buyer Name and Address (including County and Zip Code) Seller/Creditor (name and address) You, the Buyer (and Co-Buyer, if any), may buy this vehicle by means of a credit. By signing this contract, you choose to buy this vehicle on credit under the agreement on the front and back of this contract. You agree to pay the Seller - Creditor (sometimes “we” or “us”) of 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. Truth-in-Lending Disclosures below are part of this contract. New Vehicle Year Make and Model Odometer Vehicle Identification Number Primary Use for Which Purchased: Person, family, or household unless otherwise noted: Business Agricultural FEDERAL TRUTH-IN-LENDING DISCLOSURES ANNUAL PERCENTAGE RATE The cost of your credit as a yearly rate FINANCE CHARGE The amount the credit will cost you Amount Financed The amount of credit extended to you or on your behalf Total of Payments The amount you must return to us when you have made all required payments of principal and interest. Total Sale Price The cost of the vehicle plus the amount of credit, including the finance charge. (See note below.) $__________ $__________ $__________ Your Payment Schedule Will Be: Number of Payments Amount of Payments When Payments Are Due (a) means an estimate $__________ $__________ $__________ beginning ____________ Late Charge: If payment is not received in full within 10 days after it is due, you will pay a late charge of $. ________ or $. ________, whichever is less. Prepayment: If you pay early, you will not have to pay a penalty. Secured Interest: You are giving us security interest in the vehicle being purchased. Additional Disclosure: See this contract for more information including information about repayment default and repossession if full payment is not made prior to the last scheduled date and security interest. ITEMIZATION OF AMOUNT FINANCED 1. Cash Prior Purchase _______ Amt Appraised _______ Amt Brokered _______ 2. Total Downpayment = _______ 3. Usual Balance of Credit Prior To This Sale _______ 4. Other Charges Including Amounts Paid to Others on Your Retail _______ 5. Other Charges Including Amounts Paid to Others on Your Retail Seller may keep cash or these amounts: Cash $__________ Check $__________ Other $__________ 6. Optional Credit Insurance Paid to Insurance Company or Company Representing Insurance Company _______ 7. Vendor's Single Interest Insurance Paid to Insurance Company _______ 8. Other Optional Insurance Paid to Insurance Company or Company Representing Insurance Company _______ 9. Optional Auto Contract _______ 10. Off-Lease Fees Paid to Government Authorities _______ 11. Government Sales Tax Included in Cash Price _______ 12. Government Loaner and/or Pledge/Lease Fees _______ 13. Government Rebates _______ 14. Other Charges (Identify and identify who is paid and reason for purpose) _______ Total Other Charges and Amounts Paid to Others on Your Retail _______ Total Amount Financed (Items 1 + 2 + 3 + 4 + 5 + 6 + 7 + 8 + 9 + 10 + 11 + 12 + 13 + 14) _______ Insurance we may pay the physical damage insurance you may like but if from anyone you choose (who supplies it is not required to be a producer and/or agency authorized by us). The full amount of the insurance will be charged through us to you and/or your estate or to the holder of the note and/or any secured party. The balance of the insurance will be deducted from the amount financed if and when paid in accordance with the terms of this contract or as required by law. The insurance is not required to be sold as part of the contract. See the Arbitration Provision for additional information concerning the agreement to arbitrate. If you wish to be excluded from these optional arrangements, check here: _______ Other Optional Insurance _______ Type of Insurance _______ Premium $__________ Insurer's Company Name _______ Home Office Address _______ Other optional insurance is not required to obtain credit; however, your decision to buy one or any other optional insurance will not affect your right to receive credit. If you elect to purchase optional insurance, a record of its sale will be maintained for specified periods. If any optional insurance does not provide a benefit to you, you may cancel it at any time during the term of such optional insurance coverage by notifying the seller who is providing the optional insurance. If not offered or not promptly delivered, this contract and note may be returned or rescinded. OPTIONAL CAB CONTRACT: If you contract (Cab cancellable contract) is required to obtain credit and will not be provided unless you sign below and agree to pay the extra charge. If you choose to fix a cab contract, the charge is shown on Item 10 of the statement of Amount Financed. See your cab contract for details on charges and conditions if provided in a part of this contract. Term _______ Max. _______ Name of Cab Contract _______ Agreement to Arbitrate: By signing, you agree that pursuant to the Arbitration Provision on the reverse side of this contract, you or we may seek to resolve any dispute by means of binding arbitration. For additional information concerning the agreement to arbitrate see the Arbitration Provision. 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: The contract generally binds an agreement between you and us relating to the contact. Any change to this contract must be in writing and we must sign it. No oral changes are binding. Any part of the contract not in effect at other parts day. We may delay or change the effective date of our rights under the contract without losing them. For example, we may extend the time within which some purchasers withdraw their notice of revocation of consent. 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 acknowledge that you have read both sides of this contract, including the arbitration provision on the reverse side, before signing below. You confirm that you received a completely filled-in copy when you signed it. Co-Buyer Signed X Co-Buyer Printed Name _________________ Date ______________ Other owner signs here X _________________ Address _________________ Other owner signs here X _________________ Address _________________ Sellerv Signature(s) __________________________ Date __________________________ Assignee(s): ________________________________ Date _________________________ EXHIBIT A 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 will apply each payment to the unpaid part of the Finance Charge and to other amounts you owe under this contract in any order we choose except as otherwise required by law. c. How late payments or early payments change what you must pay. We will tell you your Charges, Total Sales Price, and Payment Plan and the Total Sales Price shown on the front of this contract may be higher than the Total Sales Price if we allow you to pay late and less if you pay early. Charges may take the form of a larger or smaller initial payment or, at our option, a larger or smaller amount of each scheduled payment with a smaller final payment. We will send you a notice telling you about these changes before they become effective. d. Your right to 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 remaining finance charge, if any, plus the 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 behind on your payments, you have the right to request a balloon payment plan. If you are behind on your payments and the balloon payment is due within 30 days after the balloon payment becomes due, you have the right to refinance the balloon payment when due without penalty. The terms of the refinance agreement cannot be more favorable than those 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 your 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 for hire. You may not remove the vehicle from the U.S. or Canada, or to sell, lease, or transfer any interest in the vehicle or this contract without our written permission. You may not use the vehicle for resale, sale, lease, confiscation, or involuntary transfer. If we pay any repair bills, storage bills, taxes, fines, or charges on the vehicle, we may apply the amount when we ask for it. c. Security Interest. You give us a security interest in: • All parts, accessories, and tools installed on the vehicle; • All money or goods received (proceeds) for the vehicle; • All insurance, maintenance, service, or other contracts related to the vehicle; • All proceeds from insurance, maintenance, service, or other contracts we finance for you. This includes any refunds or other charges made on these contracts. This security payment is all you owe on this contract. It also secures your other agreements in this contract. You will not assign or sell your rights to proceeds from the vehicle. You will not allow any other security interest to be placed on the title without our written permission. d. Insurance. You agree to maintain the vehicle with insurance covering loss or damage to the vehicle for the term of this contract. This insurance must cover all we finance in this contract. You agree to name us on your insurance policy as loss payee. If you do not have this insurance, we may, if we choose, buy physical damage insurance and add it to the vehicle's physical damage insurance, we may either buy insurance that covers your interest and our interest in the vehicle, or buy separate insurance that covers your interests. If we buy another type of insurance, we will tell you which type and the charge you must pay. The charge will be the per capita rate or the annual percentage rate charge computed by the Annual Percentage Rate shown on the front of this contract. If the vehicle is lost or damaged, you agree to pay us all you owe unless we agree to accept an insurance settlement to reduce what you owe or repair the vehicle. e. What happens to returned insurance, maintenance, service, or other charges. If we get a refund of insurance, maintenance, service, or other 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 will pay extra late charges. You will pay a late charge on each late payment as shown on the front. Acceptance of a late payment does not excuse your late payment or mean that you are entitled to a grace period. 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 promise or pay late, you may have to pay all you owe on this contract at once. Default charges: • You do not pay any payment on time; • You do not provide true, accurate, or complete information during credit application; • You start a proceeding in bankruptcy or one is started against you; • You break any agreements in this contract. The amount you will owe will be the unpaid part of the Amount Financed, $0.01, if any, plus the unpaid part of the Finance Charge, any late charges, and any amounts due because you defaulted. 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 ITS PROCEEDS HEREOF; RECOVERY HEREBYUNDER 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. 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 fees and costs the attorney incurs. The amount attorney’s fees you will pay will be 15% of the amount you owe, unless a court awards an additional amount. d. We can take possession of your vehicle from you. If you default, we may take (repossession) the vehicle from you if we do so pursuant to the law and if the law allows it. If we take possession of the vehicle, we may sell the vehicle or we may keep the vehicle. If we take the vehicle, we may sell it as is, even if there are things wrong with it. If there are items in the vehicle, we may store them for you. If you do not ask for these items back, we may dispose of them at the sale price. If we take it, we may repossess the vehicle, you may pay it back (redeem). We will tell you how much it will cost to redeem, your right to redeem, and your right to keep the vehicle. e. 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 statement before we sell the vehicle. We will apply the money from the sale, less allowed expenses, to the amount you owe. Allowed expenses are selling expenses such as advertising, holding the vehicle, holding it preparing for it sale, and selling it. Attorney fees and court costs, if the law permits, are not considered expenses but we will apply them if we will pay to you unless the law requires us to pay it to someone else. If the money from the sale is not enough to pay the amount you owe, we may charge you other expenses or fees, or provide otherwise. If you do not pay this amount when we ask, we may change your interest at a rate not exceeding the highest legally permitted. g. What we may do about optional insurance, maintenance, service, or other contracts. The Seller may continue optional contracts, 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 cancel the optional contracts and cancel them to obtain refunds of unused charges to reduce what you owe or repair the vehicle. If the vehicle is a total loss because of a collision or other damage, we may cancel claim benefits under these contracts and cancel them to obtain refunds of unused charges to reduce what you owe. 4. WARRANTIES SELLER DISCLAIMS Unless the Seller provides written warranty, or enters into a written agreement within 90 days from the date of this contract, the Seller makes no warranties, express or implied, on the vehicle, and there will be no implied warranties of merchantability or fitness for a particular purpose. This provision does not affect any warranties covering the vehicle that the vehicle manufacturer may provide. 5. USED CAR BUYERS GUIDE. The information you see on the window form of 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 se muestra en el formulario de la ventana del vehículo forma parte del presente contrato. La información del formulario de la ventana debe sobrepasar cualquier disposición en contrato contenida en el contrato de venta. 6. SERVICING AND COLLECTION CONTACTS In consideration of our extension of credit to you, you agree to provide us your contact information for our servicing and collection activities. You understand that we have the consent to contact you in writing, by e-mail, or using prerecorded/artificial voice messages, text messages, and automatic telephone dialing system. If we try to collect what you owe, we may try to contact you in these and other ways at any address or telephone number you provide us, even if the telephone number is listed as unlisted, exclusive, or restricted. If you move, you agree to allow our agents and service providers to contact you as agreed above. If you want to notify us of any change in your contact information, notify us of any such change in your contact information. 7. APPLICABLE LAW Federal law and the law of the state of Oklahoma apply to this contract. 8. NEGATIVE CREDIT REPORT NOTICE 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. ARBITRATION PROVISION PLEASE REVIEW - IMPORTANT - AFFECTS YOUR LEGAL RIGHTS 1. EITHER YOU OR WE MAY CHOOSE TO HAVE ANY DISPUTE BETWEEN YOU AND US DECIDED BY ARBITRATION AND NOT IN COURT OR BY JURY. 2. IF A DISPUTE IS ARBITRATED, YOU WILL GIVE UP YOUR RIGHT TO PARTICIPATE AS A CLASS REPRESENTATIVE OR CLASS MEMBER ON ANY CLASS CLAIM YOU MAY HAVE AGAINST US INCLUDING ANY RIGHT TO CLASS ARBITRATION OR ANY CONSOLIDATION OF INDIVIDUAL ARBITRATIONS. 3. DISCOVERY AND RIGHTS TO APPEAL IN ARBITRATION ARE GENERALLY MORE LIMITED THAN IN A LAWSUIT, AND OTHER IMPORTANT RIGHTS MAY NOT BE AVAILABLE IN ARBITRATION. Any claim or dispute, whether in contract, tort, statute or otherwise (including the interpretation or scope of this Arbitration Provision), any allegation of waiver of rights under this Arbitration Provision, and the arbitrability of the claim or dispute, between you and us or our employees, agents, successors or assigns, which arises out of or relates to your credit application, purchase or contract of the vehicle, this contract or any resulting transaction or relationship (including, but not limited to, the purchase, sale, financing, leasing, or rental of the vehicle), including, but not limited by, breach, default, nonperformance, or any type of dispute, including, but not limited to, a breach of contract or a breach of warranty, regardless of whether the claim or dispute arises under federal, state, local, or foreign law, and whether or not it could have been filed in court. You agree that any claim or dispute to be arbitrated by a single arbitrator only on an individual basis and not as a plaintiff in a collective or representative action, or a class representative or member of a class on any class claim. The arbitrator may not preside over a consolidated, representative, class, collective, injunctive, or private attorney general action. You or we may choose the American Arbitration Association (www.adr.org) or National Arbitration and Mediation (www.namadc.com) as the arbitration organization to conduct the arbitration. You and we agree, you or we may choose a different arbitration organization, but you will not be required to join or associate. We will always be allowed to select an arbitrator. An arbitrator shall apply governing substantive law and the applicable statute of limitations. The arbitration hearing shall be conducted in the federal district in which this transaction was originated. We will pay the filing, administration, service, or case management fees for the arbitration hearing fee up to a maximum of $5,000, unless the law or the rules of the chosen arbitration organization provide otherwise. You will pay the filing, service, or case management fees for the arbitration hearing if the hearing fee over $5,000 in accordance with the rules and procedures of the chosen arbitration organization. The amount we pay may be reimbursed in whole or in part by decision of the arbitrator if the arbitrator finds that any of your claims is invalid under applicable law. Each party shall be responsible for its own attorney fees unless a court determines otherwise. If the Alberta Arbitration Act (the "Act") provides that the Act shall apply to this Arbitration Provision, then the provisions of the Act shall govern this Arbitration Provision and any such arbitration under this Arbitration Provision shall be subject to the Federal Arbitration Act (9 U.S.C. § 1 et seq.) and not by any state law concerning arbitration. Any award by the arbitrator shall be in writing and will be final and binding on all parties, subject to any limited right to appeal under the Federal Arbitration Act. You and we retain the right to seek remedies in small claims court for disputes or claims if that court’s jurisdiction, unless such action is transferred, removed or remanded to another court. Whether or not you elect to go to arbitration, you may raise or assert claims by filing any action in small claims court, or by using self-help remedies, such as repossession, or by filing an action to recover the vehicle, to recover a deficiency balance, or for individual or statutory public injunctive relief. Any court having jurisdiction may enter judgment on the arbitrator’s award. This Arbitration Provision shall survive any termination, partial or transfer of this contract, any part of this Arbitration Provision, other than the waiver of claims, if deemed or found to be unreasonable. For information, you should read the small print at the end of this contract. If you and we agree to arbitrate, this arbitration agreement will be enforced on a class basis in court or in arbitration. If a court or arbitrator finds that this class arbitration waiver is unenforceable for any reason with respect to a claim or dispute in which class allegations have been made, the rest of this Arbitration Provision shall also be unenforceable. SERVICE OKLAHOMA LIEN HOLDERS RELEASE FORMS VIN: JC1NFAEK6H0102089 VEHYR: 2017 MAKE: FIAT MODEL: 124 SPIDER BODY: CV AGNT #: M5738 LIEN DATE: 01/16/2024 LIEN DEBTOR: THOMAS VICKI THOMAS VICKI 734 MARLAND DR PONCA CITY OK 74601-5915 LIEN HOLDER: OKFCU LIEN HOLDER ID: LH010296 OKFCU 517 NE 36TH ST OKLAHOMA CITY OK 73105-2511 TO: SERVICE OKLAHOMA MOTOR VEHICLE DIVISION P.O. BOX 269061 OKLAHOMA CITY OK 73126-9061 REF#: L2020413672 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 KAY COUNTY STATE OF OKLAHOMA OKLAHOMA FEDERAL CREDIT ) UNION ) ) Plaintiff, ) Case No. vs. ) SUE VICKI THOMAS, ) 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, SUE VICKI THOMAS, 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 Department of Defense Manpower Data Center Results as of: Feb-13-2026 01:36:11 PM EST SCRA 5.28 Status Report Pursuant to Servicemembers Civil Relief Act SSN: XXX-XX-9301 Birth Date: Apr-XX-1970 Last Name: THOMAS First Name: SUE Middle Name: VICKI Status As Of: Feb-13-2026 Certificate ID: J983VT7GXTXSSRM On Active Duty On Active Duty Status Date <table> <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> </table> This response reflects the individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date <table> <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> </table> This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date <table> <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> </table> This response reflects whether the individual or his/her unit has received early notification to report for active duty. 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.