Communication Federal Credit Union v. Rebekah Mann a/k/a Rebekah Marie Mann and Kendra Mann a/k/a Kendra Nicole Mann

IN THE DISTRICT COURT OF OKLAHOMA COUNTY STATE OF OKLAHOMA COMMUNICATION FEDERAL CREDIT UNION, Plaintiff, vs. REBEKAH MANN A/K/A REBEKAH MARIE MANN and KENDRA MANN A/K/A KENDRA NICOLE MANN, Defendants. PETITION IN REPLEVIN FIRST CAUSE OF ACTION - REPLEVIN COMES NOW Plaintiff, Communication Federal Credit Union (hereafter “Plaintiff”), by and through counsel of record Joshua C. Greenhaw, Cara J. Bisel, and Breanne Stewart of Mee Hawkins Greenhaw & Cotner PLLP, and for its claims against Rebekah Mann a/k/a Rebekah Marie Mann and Kendra Mann a/k/a Kendra Nicole Mann, (hereafter referred to as “Defendants”), alleges and states: 1. On or about October 18, 2023, Defendants, for good and valuable consideration, executed and delivered to Fowler Dodge, a Retail Installment Sale Contract and Security Agreement (hereafter the “Contract”), in the amount of $53,811.00. 2. As part of Contract, and to secure the payment of the amounts owed pursuant to said Contract, Defendants granted to Fowler Dodge, a security interest in a 2021 Ram 1500 (VIN: 1C6SRFJT7MN810316) (hereafter the “Vehicle”). A true and correct copy of the Contract is attached hereto as Exhibit “A”. 3. Said Contract was subsequently assigned to Plaintiff and Plaintiff is the current owner and holder thereof and is the current creditor. 4. Under the terms of said Contract, Defendants agreed to make payments to Plaintiff as set out therein. 5. Defendants did not pay said Contract in accordance with the terms thereof and are in default. 6. Due to Defendants’ default, Plaintiff has declared the entire balance due under the terms of Contract in the principal amount of $50,509.66, together with interest in the amount of $2,138.94, plus interest continuing to accrue from and after November 18, 2025, at the contractual rate of 15.99% per annum, until paid, fees/charges in the amount of $93.00, costs of the action, and a reasonable attorneys’ fee, all as provided by the Contract. 7. Under the terms of Contract and under the Uniform Commercial Code, Plaintiff has a special interest in the Vehicle and the right to the immediate and permanent possession of said Vehicle. 8. Defendants may claim an interest in the Vehicle, but Plaintiff alleges that any interest claimed by Defendants is subject to and inferior to the interest of the Plaintiff in the Vehicle. 9. Upon information and belief, Defendants are in actual possession of said Vehicle, which Plaintiff believes is located in Oklahoma County, Oklahoma. Defendants have not permitted Plaintiff to take possession thereof. 10. The actual value of said Vehicle is unknown to this Plaintiff, but Plaintiff believes the approximate value of said Vehicle to be $32,450.00. 11. The aforementioned Vehicle was not taken in execution on any order or judgment against said Plaintiff, or for the payment of any tax, fine or amercement assessed against it, or by virtue of an Order of Delivery issued, or any other mesne or final process issued against said Plaintiff. WHEREFORE, Plaintiff requests that the Court grant judgment for an Order of Delivery (Writ of Replevin) for the Plaintiff against the Defendants for the permanent possession of the Vehicle pursuant to 12 O.S. § 1583. Plaintiff further requests judgment decreeing that Plaintiff’s interest in said Vehicle is senior and prior to the interest of the Defendants in said property, for costs of the action, and a reasonable attorneys’ fee. Plaintiff further requests judgment pursuant to 12 O.S. § 1582 that, should the Defendants refuse to grant possession of the Vehicle to Plaintiff, the Sheriff of Oklahoma County, or any other county in Oklahoma where the Vehicle may be found, shall be authorized to break open any property or enclosure in which the Vehicle is concealed after first demanding entry thereto. SECOND CAUSE OF ACTION – MONEY JUDGMENT For its second cause of action, Plaintiff alleges and adopts all statements made in its first cause of action, and in addition thereto, alleges and states: 12. Due to Defendants’ default, Plaintiff has declared the entire balance due under the terms of Contract in the principal amount of $50,509.66, together with interest in the amount of $2,138.94, plus interest continuing to accrue from and after November 18, 2025, at the contractual rate of 15.99% *per annum*, until paid, fees/charges in the amount of $93.00, costs of the action, and a reasonable attorneys’ fee, all as provided by the Contract. WHEREFORE, Plaintiff requests that the Court grant judgment pursuant to its second cause of action as follows: A money judgment for Plaintiff, against the Defendants, jointly and severally, in the sum of $50,509.66, together with interest in the amount of $2,138.94, plus interest continuing to accrue from and after November 18, 2025, at the contractual rate of 15.99% per annum, until paid, fees/charges in the amount of $93.00, costs of the action, and a reasonable attorneys’ fee, all as provided by the Contract. Plaintiff further requests that any judgment herein be deemed a final judgment pursuant to 12 O.S. § 994 (OSCN 2026), and for any other relief to which it is entitled. Respectfully submitted, ______________________________ BREANNE STEWART, OBA #35747 [email protected] CARA J. BISEL, OBA #31390 [email protected] JOSHUA C. GREENHAW, OBA #19111 [email protected] MEE HAWKINS GREENHAW & COTNER PLLP PO Box 1375 Oklahoma City, OK 73101 Telephone: (405) 848-9100 Facsimile: (405) 848-9101 ATTORNEYS FOR PLAINTIFF THIS IS A COMMUNICATION FROM A DEBT COLLECTOR. VERIFICATION STATE OF OKLAHOMA ) COUNTY OF OKLAHOMA ) ss. I, Breanne Stewart, of lawful age, being first duly sworn, on this 25 day of February 2026, depose and say: That I am the attorney of the Plaintiff in the above-referenced cause; that I have read the above and foregoing Petition and have personal knowledge thereof; that I know the contents thereof and that the statements therein made are true and correct to the best of my knowledge and belief. I state under penalty of perjury under the laws of Oklahoma that the foregoing is true and correct. ______________________________ BREANNE STEWART LAW 553-OK-ARB-eps 8/23 RETAIL INSTALLMENT SALE CONTRACT – SIMPLE FINANCE CHARGE (WITH ARBITRATION PROVISION) Buyer Name and Address (Including County and Zip Code) REEBEKAH MANN Co-Buyer Name and Address (Including County and Zip Code) KENDRA MANN Seller-Creditor (Name and Address) FOWLER DODGE 55 West | 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>2021</td> <td>RAM 1500</td> <td>58,008</td> <td>1C6SRFJT7MN810316</td> <td>Personal: family or household unless otherwise indicated below<br>☐ business<br>☐ agricultural ☐ 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 $4,208.00 is $94,559.24</th> </tr> <tr> <td>15.99 %</td> <td>$36,540.24</td> <td>$53,811.00</td> <td>$90,351.24</td> <td>$94,559.24</td> </tr> </table> Your Payment Schedule Will Be: (8) 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>$1,075.61</td> <td>MONTHLY beginning 12/02/2023</td> </tr> <tr> <td>N/A</td> <td>N/A</td> <td>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 $31.00 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 Guide. 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. WARRANTIES SELLER DISCLAIMS Unless the Seller makes a written warranty, or enters into a service contract 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 of fitness for a particular purpose. This provision does not affect any warranties covering the vehicle that the vehicle manufacturer may provide. 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. Agreement to Arbitrate: By signing below, you agree that, pursuant to the Arbitration Provision on page 5 of this contract, you or we may elect to resolve any dispute by neutral, binding arbitration and not by a court action. See the Arbitration Provision for additional information concerning the agreement to arbitrate. Buyer Signs X ___________________________ Co-Buyer Signs X ___________________________ EXHIBIT A ITEMIZATION OF AMOUNT FINANCED 1 Cash Price (including $________ sales/excise tax) $44,463.00 (1) 2 Total Downpayment: Trade-in 2019 RAM 1500 (Year) ________ (Make) ________ (Model) ________ Gross Trade-In Allowance $31,358.00 Less Pay Off Made By Seller to N/A $28,150.00 Equals Not Trade In $3,208.00 - Cash $1,000.00 - Other N/A $________ + Other N/A $________ - Other N/A $________ If total downpayment is negative, enter "0" and see 4I below) $4,208.00 (2) 3 Unpaid Balance of Cash Price (1 minus 2) $40,255.00 (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 $3,500.00 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 $10.00 LICENSE AND/OR REGISTRATION FEES 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 DOCUMENT FEE $549.00 to PROTECTIVE for SERVICE CONTRACT $9,497.00 to N/A for N/A $ N/A to N/A for N/A $ N/A to for $ N/A to for $ N/A to for $ N/A to for $ N/A to for $ N/A to for $ N/A to for $ N/A to for $ N/A Total Other Charges and Amounts Paid to Others on Your Behalf $13,556.00 (4) 5 Amount Financed (3 + 4) $53,811.00 (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. NATIONAL AUTO CARE CORP I want to buy a gap contract. Buyer Signs X Returned Check Charge: You agree to pay a charge of $25.00 if any check you give us is dishonored. Buyer Signs X Co-Buyer Signs X 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 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 ☐ Cn-Buyer ☐ Both ☐ Credit Disability ☐ Buyer ☐ Co-Buyer ☐ Both Premium: Credit Life S ________ N/A Credit Disability S N/A Insurance Company Name N/A Home Office Address 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 Premium S ________ N/A Insurance Company Name N/A Home Office Address N/A ☐ Type of Insurance N/A ☐ Term N/A Premium S ________ 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. 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 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. 4. 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 purposes. You agree that we may use this information to contact you in writing, by e-mail, or using prerecorded/artificial voice messages, text messages, and automatic telephone dialing systems, as the law allows. You also agree that 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 a cell phone number or the contact results in a charge to you. You agree to allow our agents and service providers to contact you as agreed above. You agree that you will, within a reasonable time, notify us of any change in your contact information. 5. APPLICABLE LAW Federal law and the law of the state of Oklahoma apply to this contract. 6. 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. 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. 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 TRIAL. 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 RIGHTS THAT YOU AND WE WOULD HAVE IN COURT MAY NOT BE AVAILABLE IN ARBITRATION. This Arbitration Provision covers any dispute that arises between you and us including the interpretation and scope of this Arbitration Provision, any claim of breach of express or implied warranty (except for the implied warranty of merchantability or fitness for a particular purpose) or non-conformance, breach of contract, or breach of the terms or condition of this Vehicle. This contract or any resulting transactions or arrangements and any such requirement to arbitrate are severable. The right to compel arbitration shall be open to our election, so resolved by written binding agreement and not by agreement. If Federal law gives us a right to compel arbitration, we will have such a right and the Arbitration Provision must apply to such claim or dispute. Any claims arising under it may be made subject to collective bargaining and may also be brought in a collective or representative action on behalf of a class or as a class representative. If a class representative action is filed, then the arbitrator shall select class representatives who act as representatives of all class members. The arbitrator shall select class representatives who act as representatives of all class members. The arbitrator shall select class representatives who act as representatives of all class members. The arbitrator shall select class representatives who act as representatives of all class members. The arbitrator shall select class representatives who act as representatives of all class members. The arbitrator shall select class representatives who act as representatives of all class members. The arbitrator shall select class representatives who act as representatives of all class members. The arbitrator shall select class representatives who act as representatives of all class members. The arbitrator shall select class representatives who act as representatives of all class members. The arbitrator shall select class representatives who act as representatives of all class members. The arbitrator shall select class representatives who act as representatives of all class members. The arbitrator shall select class representatives who act as representatives of all class members. The arbitrator shall select class representatives who act as representatives of all class members. The arbitrator shall select class representatives who act as representatives of all class members. This Arbitration Provision covers all transactions between the Seller and Buyer involving the sale of this Vehicle, and related transactions. It includes all insurance and financing agreements, and any other agreements between the Seller and Buyer relating to the sale, delivery, and use of this Vehicle. If any provision of this Arbitration Provision is found to be invalid or unenforceable, the remaining provisions will continue to be valid and enforceable. The Seller and Buyer agree that this Arbitration Provision is intended to be a complete and exclusive statement of the terms by which all issues and matters arising out of or relating to the sale of this Vehicle and its financing will be resolved. The Seller and Buyer agree that this Arbitration Provision supersedes all prior agreements between them regarding the sale of this Vehicle and its financing. The Seller and Buyer agree that any dispute between them regarding the sale of this Vehicle and its financing will be resolved by arbitration and not in court or by jury trial. Such dispute will be resolved by arbitration in accordance with the rules of the American Arbitration Association and the Federal Arbitration Act, 9 U.S.C. §§1-16. The arbitration will be conducted in the state where this Vehicle was delivered. If the transaction originated outside the United States, the arbitration will be conducted in the country where the transaction originated. If the arbitration is conducted in the United States, it will be conducted in the state where this Vehicle was delivered. If the transaction originated outside the United States, the arbitration will be conducted in the country where the transaction originated. If the arbitration is conducted in the United States, it will be conducted in the state where this Vehicle was delivered. The arbitration will be conducted in accordance with the rules of the American Arbitration Association. The amount of any award or compensation to be paid by either party shall not exceed $50,000, unless otherwise agreed in writing by both parties. Any final award or compensation to be paid by either party shall be paid within 30 days after the date of the arbitration hearing. The arbitration hearing shall be conducted in the federal district in which you reside unless the Seller chooses to assert a counterclaim. If there is no counterclaim, the arbitration will be held in the federal district where the transaction originated. We will pay the filing, administration, and arbitration fees set forth in the rules of the American Arbitration Association unless the rules permit us to recover some or all of these fees. If we do not prevail, we will pay all such fees except for any fees that you are required to pay pursuant to applicable law. If you prevail, you will be entitled to reasonable attorney's fees, costs, and expenses incurred in connection with the arbitration if the amount of your award or compensation exceeds $50,000. If the arbitration results in a final award or compensation of at least $50,000, the arbitration will be conducted in accordance with the Federal Arbitration Act, 9 U.S.C. §§1-16. If you prevail, you will be entitled to reasonable attorney's fees, costs, and expenses incurred in connection with the arbitration if the amount of your award or compensation exceeds $50,000. If the arbitration results in a final award or compensation of at least $50,000, the arbitration will be conducted in accordance with the Federal Arbitration Act, 9 U.S.C. §§1-16. If you prevail, you will be entitled to reasonable attorney's fees, costs, and expenses incurred in connection with the arbitration if the amount of your award or compensation exceeds $50,000. After the arbitration hearing, the arbitrator will issue a written decision. You may file a copy of the decision with the Clerk of the District Court of the United States for the District in which the transaction originated. You may also appeal the decision to the District Court of the United States for the District in which the transaction originated. If you do not prevail in your appeal, you may have an opportunity to appeal to the Circuit Court of Appeals for the Circuit in which the District Court is located. If you do not prevail in your appeal, you may have an opportunity to appeal to the Circuit Court of Appeals for the Circuit in which the District Court is located. THE SELLER SHALL NOT BE LIABLE FOR ANY LIABILITY, WHETHER BASED ON NEGLIGENCE OR ANY OTHER THEORY OF LIABILITY, FOR ANY INDIRECT, CONSEQUENTIAL, INCIDENTAL, OR SPECIAL DAMAGES ARISING OUT OF OR IN CONNECTION WITH THIS ARBITRATION PROVISION. If you do not sign this Arbitration Provision, you consent to arbitration but do not consent to any other aspect of this contract. If you do not sign this Arbitration Provision, you consent to arbitration but do not consent to any other aspect of this contract. 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 terms agreed to between you and the Seller. Any change to these terms must be made in writing signed by both you and the Seller. Buyer Signs X Co-Buyer Signs X 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 acknowledge that you have read all pages of this contract, including the arbitration provision above, before signing below. You confirm that you received a completely filled-in copy when you signed it. Buyer Signs X Date 10/18/2023 Co-Buyer Signs X Date 10/18/2023 Buyer Printed Name REBEKAH MANN Co-Buyer Printed Name KENDRA MANN Fowler Dodge Inc. - A member of Franchised Dodge Chrysler Jeep Ram Retailers, LLC. All rights reserved. All offers and prices are subject to change without notice. Offer expires 10/31/2023 unless otherwise noted. Fowler Dodge Inc. - A member of Franchised Dodge Chrysler Jeep Ram Retailers, LLC. All rights reserved. All offers and prices are subject to change without notice. Offer expires 10/31/2023 unless otherwise noted.