CS-2026-669 - Bank of America, N.A. v. Mollie E. Pulley

What's This Case About?

Let’s cut straight to the drama: a bank is suing a woman in Oklahoma over $5,307 — less than you’d spend on a used car — and dragging it into public court like it’s some high-stakes financial thriller. This isn’t The Wolf of Wall Street. This is The Debt Collector of Canadian County, and honestly, it’s both absurd and oddly riveting.

Meet Mollie E. Pulley, a resident of Oklahoma City, living in an apartment complex on Pennsylvania Avenue that looks exactly like every other beige, slightly sun-bleached complex you’ve driven past on a road trip through the Midwest. She’s not a Wall Street titan. She’s not running a Ponzi scheme out of her laundry room. She’s just a regular person who, at some point, opened a Bank of America credit card — probably to cover an emergency, or maybe just to buy something nice during a rough month. And now, years later, that decision has landed her name on a legal petition filed by one of the largest financial institutions in the country. On the other side? Bank of America, N.A., a corporate behemoth with more money than most small countries, represented by a law firm that specializes in debt collection — Nelson and Kennard, LLP — which, let’s be real, sounds less like a law firm and more like a villainous duo from a 1980s cop show.

So what happened? Well, according to the filing, Mollie opened a credit account, used it, and then… stopped paying. That’s it. The spark notes version: she racked up a balance, made her last payment on November 30, 2023, and then went radio silent. The account officially “charged off” — banker-speak for “we’ve given up on getting paid” — on July 31, 2024, with a total balance of $5,307.27. That’s not chump change, sure, but it’s also not a life-altering sum. For context, that’s about what you’d pay for a single month of private college tuition, or two new iPhones, or one really fancy couch you immediately regret buying on credit. The statement attached to the lawsuit shows the full balance due — $5,307.27 — with zero payments, zero purchases, zero interest, zero fees. It’s a frozen moment in time: a debt snapshot of a card that’s been cut off, maxed out, and abandoned.

And why are we in court? Because Bank of America says Mollie broke the contract. That’s the legal claim — breach of contract, specifically for failing to make the required monthly payments. Now, before you gasp in horror, remember: this isn’t fraud. There’s no allegation she stole the card, lied on the application, or went on a shopping spree with ill-gotten gains. She just didn’t pay. And while that’s certainly a problem for the bank, it’s also a problem for millions of Americans every year. Credit card debt is like quicksand — easy to step into, hard to climb out of, especially when interest rates are over 29%. And speaking of that interest — here’s the wild part: the statement shows zero interest charged in this billing cycle. Why? Because the promotional 0% APR on purchases expired on July 10, 2024 — the same day this statement was issued. So technically, she dodged the bullet on interest… right before the account got nuked.

But make no mistake: that 29.24% variable rate was lurking like a debt gremlin, ready to pounce. And the statement itself includes a delightful little table that says if she’d kept making only the minimum payment, she’d be paying this off for 18 years and end up shelling out nearly $15,600 in total. Let that sink in: a $5,300 balance could have become triple that with time. So when the bank says she breached the contract, sure — legally, they’re correct. But morally? Emotionally? Economically? This is the kind of debt trap that’s baked into the system. She wasn’t reckless. She was normal. She was human.

Now, what does Bank of America want? $5,307.27. Plus court costs. Plus sheriff’s fees. Plus “special process server fees” — which sounds like something out of a medieval summons, but is probably just the guy who hand-delivered the lawsuit to Mollie’s door. Is $5,307 a lot? In the grand scheme of lawsuits, no. You could buy a decent used car, fix a roof, or pay off a year of rent with that. But for a single person in Oklahoma, where the median household income is around $60,000, it’s not nothing. It’s six months of groceries. It’s a year of car insurance. It’s the kind of number that can wreck your credit, haunt your credit report, and follow you around like a bad Yelp review.

And yet, here we are. A national bank, with assets in the trillions, has hired a Colorado-based law firm to sue an individual over a debt that, for them, is basically rounding error. They filed this petition on February 2, 2026 — yes, 2026 — and it was officially docketed in March of that year. That’s not a typo. This case is set in the future. Either we’ve accidentally time-traveled to 2026, or someone really needs to check their calendar settings. (Our money’s on the latter — probably a clerical error, but honestly, it adds to the surreal vibe.)

So what’s our take? The most absurd part isn’t that someone owes money. It’s that a bank this big feels the need to sue over this amount — not through arbitration, not through collections, but in public court, where anyone with Wi-Fi can read about Mollie’s credit misadventures. This isn’t justice. This is debt theater. This is the financial system flexing its muscles on someone who likely didn’t stand a chance from the start. We’re not rooting for Mollie because she’s innocent — she did agree to pay, after all — but because this feels like using a flamethrower to light a birthday candle. Where’s the compassion? The restructuring? The “hey, let’s work something out”? Instead, it’s cold, corporate, and impersonal: a form letter from a law firm in Colorado demanding payment, backed by the full force of the Canadian County District Court.

Look, we get it — banks aren’t charities. They lend money to make money. But when you’re suing an individual over five grand and attaching a 12-page credit statement full of financial jargon that reads like a spy novel, you’ve lost the moral high ground. This isn’t a cautionary tale about responsibility. It’s a cautionary tale about how the system grinds people down — one late payment, one missed minimum, one lawsuit at a time.

And honestly? If Bank of America really wanted to make a difference, they could’ve just sent a nicer letter. Or offered a payment plan. Or, hear us out, forgiven the debt and called it a PR win. But no. They chose the courtroom. And now, Mollie E. Pulley’s name is forever linked to Case No. CS-2026-669 — not because she committed a crime, but because she fell into the same credit card rabbit hole that’s swallowed millions before her.

We’re entertainers, not lawyers. But even we know this: sometimes, the real crime isn’t the debt. It’s the response.

Case Overview

$5,307 Demand Petition

Jurisdiction

District Court of Canadian County, Oklahoma

Filing Attorney

Ashton Dewayne Sears

Nelson and Kennard, LLP

Relief Sought

$5,307 Monetary

Plaintiffs

Bank of America, N.A. business
Rep: Nelson and Kennard, LLP

Defendants

Mollie E. Pulley individual

Claims

#	Cause of Action	Description
1	breach of contract	failure to make required monthly payments

Petition Text

2,324 words

IN THE DISTRICT COURT OF CANADIAN COUNTY STATE OF OKLAHOMA BANK OF AMERICA, N.A., Plaintiff, vs. MOLLIE E PULLEY Defendant(s). Case No. CS-2026-669 FILED HOLLY EATON COURT CLERK CANADIAN COUNTY, OKLAHOMA MAR 18 2026 BY DEPUTY PETITION COMES NOW the Plaintiff, by and through counsel, Nelson and Kennard, LLP, and herewith alleges the following and seeks redress as hereafter delineated. 1. Plaintiff is a national banking association, which transacts business within the State of Oklahoma. 2. Venue is proper in this County, as the Defendant(s) reside(s) in this County at the commencement of this action. 3. The last four (4) digits of the Defendant’s account number, used by the current creditor as of the date of default are XXXXXXXXXXXXXX5121. 4. Plaintiff’s claim arises when the Defendant(s) opened a credit account and failed to make the required monthly payments as agreed. The credit account charged off for non-payment on 7/31/24, the balance due at time of default was $5,307.27. A true and accurate copy of the last periodic statement provided to the Defendant(s) prior to charge-off is attached hereto as Exhibit 1. 5. The Defendant(s) breached the Contract by failing to make the required periodic payments. 6. As a direct and proximate result of the Defendant(s) default, the total amount of debt claimed is $5,307.27. 7. The date of the last payment made by the Defendant(s) is November 30, 2023. 8. Plaintiff seeks court costs, and for such further relief as the Court may deem proper in the premises. WHEREFORE, Plaintiff, BANK OF AMERICA, N.A. prays for judgment against the Defendant(s), MOLLIE E PULLEY in the amount of $5,307.27, plus all costs herein expended, including but not limited to, court costs, sheriff's fees, and special process server fees; and for such other and further relief as the Court may deem proper in the premises. Dated this February 2, 2026 Nelson and Kennard, LLP By: Ashton Dewayne Sears, OBA # 35737 12596 W. Bayaud Ave., Ste. 120 Lakewood, CO 80228 Phone: 866-920-2295 [email protected] Attorney for the Plaintiff EXHIBIT 1 BANK OF AMERICA P.O. BOX 15284 WILMINGTON, DE 19850 MOLLIE E PULLEY 14544 N PENNSYLVANIA AVE APT 303 OKLAHOMA CITY OK 73134-6138 Customer Service Information: www.bankofamerica.com 1.800.421.2110 Mail billing inquiries to: Bank of America P.O. Box 672050 Dallas TX 75267-2050 Mail payment to: Bank of America P.O. Box 851001 Dallas TX 75285-1001 BANK OF AMERICA P.O. BOX 851001 DALLAS TX 75285-1001 MOLLIE E PULLEY 14544 N PENNSYLVANIA AVE APT 303 OKLAHOMA CITY OK 73134-6138 Account Summary/Payment Information Previous Balance $5,307.27 Payments and Other Credits $0.00 Purchases and Adjustments $0.00 Fees Charged $0.00 Interest Charged $0.00 New Balance Total $5,307.27 Total Credit Line $5,200.00 Total Credit Available $0.00 Cash Credit Line $1,040.00 Portion of Credit Available for Cash $0.00 Statement Closing Date 07/10/2024 Days in Billing Cycle 30 New Balance Total $5,307.27 Current Payment Due $53.00 Past Due Amount $597.00 Total Minimum Payment Due $650.00 Payment Due Date 08/07/2024 Late Payment Warning: If we do not receive your Total Minimum Payment by the date listed above, you may have to pay a late fee of up to $40.00 and your APRs may be increased up to the Penalty APR of 29.99%. Total Minimum Payment Warning: If you make only the Total Minimum Payment each period, you will pay more in interest and it will take you longer to pay off your balance. For example: <table> <tr> <th>If you make no additional charges using this card and each month you pay</th> <th>You will payoff the balance shown on this statement in about</th> <th>And you will end up paying an estimated total of</th> </tr> <tr> <td>Only the Total Minimum Payment</td> <td>18 years</td> <td>$15,548.00</td> </tr> </table> If you would like information about credit counseling services, call 866.300.5238. Visa Signature® Account# [REDACTED] 5121 June 11 - July 10, 2024 BANK OF AMERICA P.O. BOX 851001 DALLAS TX 75285-1001 Account Number: [REDACTED] 5121 Payment Due Date 08/07/2024 New Balance Total $5,307.27 Total Minimum Payment Due $650.00 Enter payment amount $ For change of address/phone number, see reverse side. Make your payment online at www.bankofamerica.com or Mail this coupon along with your check payable to: Bank of America IMPORTANT INFORMATION ABOUT THIS ACCOUNT PAYING INTEREST - We will not charge Interest on Purchases on the next statement if you pay the New Balance Total in full by the Payment Due Date, and you had paid in full by the previous Payment Due Date. We will begin charging interest on Balance Transfers and Cash Advances on the transaction date. TOTAL INTEREST CHARGE COMPUTATION - Interest Charges accrue and are compounded on a daily basis. To determine the Interest Charges, we multiply each Balance Subject to Interest Rate by its applicable Daily Periodic Rate and that result is multiplied by the number of days in the billing cycle. To determine the total Interest Charge for the billing cycle, we add the Periodic Rate Interest Charges together. A Daily Periodic Rate is calculated by dividing an Annual Percentage Rate by 365. HOW WE ALLOCATE YOUR PAYMENTS - Payments are allocated to posted balances. If your account has balances with different APRs, we will allocate the amount of your payment equal to the Total Minimum Payment Due to the lowest APR balances first (including transactions made after this statement). Payment amounts in excess of your Total Minimum Payment Due will be applied to balances with higher APRs before balances with lower APRs. IMPORTANT INFORMATION ABOUT PAYMENTS BY PHONE - When using the optional Pay-by-Phone service, you authorize us to initiate an electronic payment from your account at the financial institution you designate. You must authorize the amount and timing of each payment. For your protection, we will ask for security information. To cancel, call us before the scheduled payment date. Same-day payments cannot be edited or canceled. YOUR CREDIT LINES - The Total Credit Line is the amount of credit available for the account; however, only a portion of that is available for Bank Cash Advances. The Cash Credit Line is that amount you have available for Bank Cash Advances. Generally, Bank Cash Advances consist of ATM Cash Advances, Over the Counter (OTC) Cash Advances, Same-Day Online Cash Advances, Overdraft Protection Cash Advances, Cash Equivalents, and applicable transaction fees. MISCELLANEOUS - Promotional Rate End Date: This date is based on a future statement closing date. If you change your payment due date, this date could change. The New Balance Total which appears on this statement is not a payoff amount and may be subject to additional interest charges when you pay in full after your statement closing date. Virtual cards are the digital form of your eligible physical credit cards stored within a digital wallet. CALCULATION OF BALANCES SUBJECT TO INTEREST RATE Average Daily Balance Method (including new Purchases): We calculate separate Balances Subject to an Interest Rate for Purchases and for each Introductory or Promotional Offer balance consisting of Purchases. We do this by: (1) calculating a daily balance for each day in the billing cycle; (2) adding all the daily balances together; and (3) dividing the sum of the daily balances by the number of days in the billing cycle. To calculate the daily balance for each day in this statement’s billing cycle, we: (1) take the beginning balance; (2) add an amount equal to the applicable Daily Periodic Rate multiplied by the previous day’s daily balance; (3) add new Purchases, new Account Fees, and new Transaction Fees; and (4) subtract applicable payments and credits. If any daily balance is less than zero we treat it as zero. Average Balance Method (including new Balance Transfers and new Cash Advances): We calculate separate Balances Subject to an Interest Rate for Balance Transfers, Cash Advances, and for each Introductory or Promotional Offer balance consisting of Balance Transfers or Cash Advances. We do this by: (1) calculating a daily balance for each day in this statement’s billing cycle; (2) calculating a daily balance for each day prior to this statement’s billing cycle that had a “Pre-Cycle balance” – a Pre-Cycle balance is a Balance Transfer or a Cash Advance with a transaction date prior to this statement’s billing cycle but with a posting date within this statement’s billing cycle; (3) adding all the daily balances together; and (4) dividing the sum of the daily balances by the number of days in this statement’s billing cycle. To calculate the daily balance for each day in this statement’s billing cycle, we: (1) take the beginning balance; (2) add an amount equal to the applicable Daily Periodic Rate multiplied by the previous day’s daily balance; (3) add new Balance Transfers, new Cash Advances and Transaction Fees; and (4) subtract applicable payments and credits. If any daily balance is less than zero we treat it as zero. To calculate a daily balance for each day prior to this statement’s billing cycle that had a Pre-Cycle balance: (1) we take the beginning balance attributable solely to Pre-Cycle balance (which will be zero on the transaction date of the first Pre-Cycle balance); (2) add an amount equal to the applicable Daily Periodic Rate multiplied by the previous day’s daily balance; (3) and add only the applicable Pre-Cycle balances and their related Transaction Fees. We exclude from this calculation all transactions posted in previous billing cycles. PAYMENTS - We credit mailed payments as of the date received, if the payment is: (1) received by 5 p.m. local time at the address shown on the remittance portion of your monthly statement; (2) paid with a check drawn in U.S. dollars on a U.S. financial institution or a U.S. dollar money order; and (3) sent in the return envelope with only the remittance portion of your statement accompanying it. Payments received by mail after 5 p.m. local time at the remittance address on any day including the Payment Due Date, but that otherwise meet the above requirements, will be credited as of the next day. Payments made online or by phone will be credited as of the date of receipt if made by 11:59 p.m. ET. Credit for any other payments may be delayed up to five days. Cash payments made with our tellers will only be accepted with a valid identification (ID). No payment shall operate as an accord and satisfaction without the prior written approval of one of our Senior Officers. We process most payment checks electronically by using the information found on your check. Each check authorizes us to create a one-time electronic funds transfer (or process it as a check or paper draft). Funds may be withdrawn from your account as soon as the same day we receive your payment. Checks are not returned to you. If you have authorized us to pay your bill automatically from your savings or checking account with us, you can stop the payment on any amount you think is wrong. To stop payment, your letter must reach us at least three business days before the automatic payment is scheduled to occur. For the complete terms and conditions of your account, consult your Credit Card Agreement. This account is issued and administered by Bank of America. Bank of America is a registered trademark of Bank of America Corporation. Transactions <table> <tr> <th>Transaction Date</th> <th>Posting Date</th> <th>Description</th> <th>Reference Number</th> <th>Account Number</th> <th>Amount</th> <th>Total</th> </tr> <tr> <td>07/10</td> <td>07/10</td> <td>Interest Charged<br>INTEREST CHARGED ON PURCHASES</td> <td></td> <td></td> <td>0.00</td> <td></td> </tr> <tr> <td>07/10</td> <td>07/10</td> <td>INTEREST CHARGED ON BALANCE TRANSFERS</td> <td></td> <td></td> <td>0.00</td> <td></td> </tr> <tr> <td>07/10</td> <td>07/10</td> <td>INTEREST CHARGED ON DIR DEP&CHK CASHADV</td> <td></td> <td></td> <td>0.00</td> <td></td> </tr> <tr> <td>07/10</td> <td>07/10</td> <td>INTEREST CHARGED ON BANK CASH ADVANCES</td> <td></td> <td></td> <td>0.00</td> <td></td> </tr> <tr> <td colspan="6">TOTAL INTEREST CHARGED FOR THIS PERIOD</td> <td>$0.00</td> </tr> </table> <table> <tr> <th>Total fees charged in 2024</th> <th>$240.00</th> </tr> <tr> <th>Total interest charged in 2024</th> <th>$0.00</th> </tr> </table> Interest Charge Calculation Your Annual Percentage Rate (APR) is the annual interest rate on your account. <table> <tr> <th>Type of Balance</th> <th>Annual Percentage Rate</th> <th>Promotional Transaction Type</th> <th>Promotional Offer ID</th> <th>Promotional Rate End Date</th> <th>Balance Subject to Interest Rate</th> <th>Interest Charges by Transaction Type</th> </tr> <tr> <td>Purchases</td> <td>29.24%V<br>Promotional APR 0.00%</td> <td>PUR, WT</td> <td>LL36-31004</td> <td>07/10/2024</td> <td>$5,305.36</td> <td>$0.00</td> </tr> <tr> <td>Balance Transfers</td> <td>29.24%V</td> <td></td> <td></td> <td></td> <td>$0.00</td> <td>$0.00</td> </tr> <tr> <td>Direct Deposit and Check Cash Advances</td> <td>29.99%V</td> <td></td> <td></td> <td></td> <td>$0.00</td> <td>$0.00</td> </tr> <tr> <td>Bank Cash Advances</td> <td>29.99%V</td> <td></td> <td></td> <td></td> <td>$1.93</td> <td>$0.00</td> </tr> </table> APR Type Definitions: Promotional Transaction Types: PUR = Purchase, WT = Non-Bank Wire Transfer; Daily Interest Rate Type: V= Variable Rate (rate may vary); APR Type: Promotional APR (APR for limited time on eligible transactions) Important Messages Your statement balance exceeds the Total Credit Line. To ensure uninterrupted use of your account, please make a payment to bring your balance under the Total Credit Line. There is no fee for being over your Total Credit Line. When this statement was created, the account’s Credit Line was in a restricted status and not available for use. You can request a copy of this statement in either Braille or Large Print by calling 800.432.1000 or going to bankofamerica.com and enter Visually Impaired Access from the home page. How are we doing? Your opinion is important to us. You're invited to join the Bank of America® Advisory Panel and share what you think we’re doing right — and what we need to do better. Enter code CACC at bankofamerica.com/AdvisoryPanel to learn more and join. When you use the QRC feature, certain information is collected from your mobile device for business purposes Inclusion on the Advisory Panel subject to qualifications.