IN THE DISTRICT COURT OF KINGFISHER COUNTY,
STATE OF OKLAHOMA
JEFFERSON CAPITAL SYSTEMS LLC
Plaintiff,
-vs-
DEBBIE COKER
Defendant(s).
Case No. CS·2020·53
PETITION FOR MONEY DUE FOR BREACH OF REVOLVING CREDIT CHARGE AGREEMENT
Count I—Breach of Contract
COMES NOW the Plaintiff and for its cause of action against the Defendant(s) states as follows:
1. That Plaintiff is a LIMITED LIABILITY COMPANY organized and existing under the laws of GEORGIA; the debt sued upon arose in and Plaintiff’s cause of action accrued in the State of Oklahoma.
2. That at least one of the Defendant(s) reside(s) in or may be found in KINGFISHER County, Oklahoma and within the venue of this court.
3. Plaintiff is the holder of the Revolving Credit Charge Agreement (“Agreement”) sued upon herein by virtue of the sale and assignment of said Agreement from THE BANK OF MISSOURI to various parties including and ultimately to Plaintiff.
4. That Defendant(s) was/were issued a credit account pursuant to the Defendant’s Agreement with THE BANK OF MISSOURI.
5. That Defendant either made written application to THE BANK OF MISSOURI for said credit card, or signed various credit charge slips, or both, thereby agreeing in writing to the terms and conditions of said Agreement.
6. That the Defendant(s) did utilize said credit or allow it to be used in the purchase of goods and services at various locations and thereby agreed to the terms and conditions of said Agreement at the time it was issued to Defendant(s)
7. That as a result of the use of said credit by Defendant(s), the Defendant(s) did accrue certain indebtedness on said revolving credit charge account pursuant to the Agreement.
8. That THE BANK OF MISSOURI fully performed under the terms of the Agreement.
9. That in accord with normal business practices, THE BANK OF MISSOURI mailed itemized monthly billing statements to Defendant. Defendant did not object to any of the charges made on the monthly statements at issue herein, in writing, for over sixty (60) days.
10. That Defendant accepted the charges shown on the monthly billing statements as demonstrated by Defendant’s continued use of the account, payments made on the account, and the absence of any attempt to cancel the agreement between Defendant and THE BANK OF MISSOURI despite having received the monthly billing statements for several months.
11. That Defendant(s) failed to perform under the terms of the revolving retail credit charge agreement and is therefore in breach.
12. That as a direct and proximate result of Defendant’s breach, THE BANK OF MISSOURI was damaged in the amount claimed of $2362.66.
13. Pursuant to Oklahoma statute, Plaintiff is entitled to reasonable attorney fees.
14. That Plaintiff, the current owner of the Agreement, has made demand upon the Defendant(s) for payment of the same, but the Defendant(s) failed and/or refused to pay.
15. Pursuant to the SCRA §201(b)(4), Plaintiff declares under penalty of perjury that Defendant(s) DEBBIE COKER is/are not in the Armed Forces for the United States, verified on 03/25/2026 via the U.S. Department of Defense website.
WHEREFORE, Plaintiff prays for Judgment against Defendant(s) in the amount of:
Amount claimed: $2362.66;
Interest: at the rate of 8.75% per annum from the date of Judgment until paid;
Attorney fees;
All costs herein expended, including but not limited to court costs, sheriff’s fees, and any fees for service of the summons.
Count II—Suit On Account
COMES NOW the Plaintiff and pleads in the alternative for its cause of action against the Defendant(s) and states as follows:
1. Plaintiff restates and re-alleges each and every paragraph of Count I as if fully set forth herein.
2. That Plaintiff is a LIMITED LIABILITY COMPANY organized and existing under the laws of GEORGIA.
3. That the cause of action herein accrued under the laws of the State of Oklahoma; at least one of the Defendant(s) reside(s) in or may be found in KINGFISHER County, Oklahoma and within the venue of this court.
4. That Defendant(s) is/are presently indebted on the account and claim herein in the amount claimed of $2362.66 for credit extended by THE BANK OF MISSOURI and used by the Defendant to purchase goods and/or services, hereinafter referred to as “items.”
5. That all sums owed to THE BANK OF MISSOURI are now due to the Plaintiff by virtue of assignment of said debt from THE BANK OF MISSOURI to various parties and ultimately to the Plaintiff.
6. That said credit was provided at the instance, request, and/or authorization of said Defendant(s).
7. That the prices charged for the extension of credit for the Defendant to purchase such items are and were in each case reasonable; that said prices were the amounts specifically agreed upon between THE BANK OF MISSOURI and Defendant(s), or in the alternative the usual and customary charges of THE BANK OF MISSOURI.
8. That Defendant(s) expressly, or in the alternative impliedly, promised and agreed to pay for said credit charges when due.
9. Pursuant to Oklahoma statute, Plaintiff is entitled to reasonable attorney fees.
10. That Plaintiff, the current owner of the Agreement, has made demand upon the Defendant(s) for payment of the same, but the Defendant(s) failed and/or refused to pay.
11. Pursuant to the SCRA §201(b)(4), Plaintiff declares under penalty of perjury that Defendant(s) DEBBIE COKER is/are not in the Armed Forces for the United States, verified on 03/25/2026 via the U.S. Department of Defense website.
WHEREFORE, Plaintiff prays for Judgment against Defendant(s) in the amount of:
Amount claimed: $2362.66;
Interest: at the rate of 8.75% per annum from the date of Judgment until paid;
Attorney fees;
All costs herein expended, including but not limited to court costs, sheriff's fees, and any fees for service of summons.
Count III—Quantum Meruit
COMES NOW the Plaintiff and pleads in the alternative for its cause of action against the Defendant(s) and states as follows:
1. Plaintiff restates and re-alleges each and every paragraph of Count I and Count II as if fully set forth herein.
2. That Plaintiff is a LIMITED LIABILITY COMPANY organized and existing under the laws of GEORGIA.
3. That the cause of action herein accrued under the laws of the State of Oklahoma; at least one of the Defendant(s) reside(s) in or may be found in KINGFISHER County, Oklahoma and within the venue of this court.
4. That Defendant(s) is/are presently indebted on the account and claim herein in the amount claimed of $2362.66 for credit extended by THE BANK OF MISSOURI and used by the Defendant to purchase goods and/or services, hereinafter referred to as "items."
5. That the credit issued to Defendant to purchase said items was provided to and for Defendant(s).
6. That said credit was provided at the instance, request, and/or authorization of said Defendant(s).
7. That the prices charged for the extension of credit items are and were in each case reasonable; that said prices were the amounts specifically agreed upon between Creditor and Defendant(s), or in the alternative the usual and customary charges of said Creditor.
8. That Defendant(s) expressly, or in the alternative impliedly, promised and agreed to pay for said extension of credit immediately upon the providing thereof or promptly thereafter.
9. That Creditor has, by virtue of Sale and Assignment, transferred all causes of action against Defendant related to the facts and issues set forth herein to various parties including and ultimately to Plaintiff..
10. Pursuant to Oklahoma statute, Plaintiff is entitled to reasonable attorney fees.
11. That Plaintiff, the current owner of the Cause of Action, has made demand upon the Defendant(s) for payment of the same, but the Defendant(s) failed and/or refused to pay.
12. Pursuant to the SCRA §201(b)(4), Plaintiff declares under penalty of perjury that Defendant(s) DEBBIE COKER is/are not in the Armed Forces for the United States, verified on 03/25/2026 via the U.S. Department of Defense website.
WHEREFORE, Plaintiff prays for Judgment against Defendant(s) in the amount of:
Amount claimed: $2362.66;
Interest: at the rate of 8.75% per annum from the date of Judgment until paid;
Attorney fees;
All costs herein expended, including but not limited to court costs, sheriff’s fees and any fees for service of the summons.
Respectfully Submitted,
FABER AND BRAND L.L.C.
BY:
/s/ Michael L. Foster
Michael L. Foster OK #20701
Jason P. Gubbins OK #22576
James M. Mucklestone OK #36520
P.O. Box 10110
Columbia, Missouri 65205-4000
(888) 233-3141
(573) 442-1072 FAX
[email protected]
ATTORNEY FOR PLAINTIFF
THIS IS A COMMUNICATION FROM A DEBT COLLECTOR IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
F&B Acct. No: 584205
Affidavit of Account
STATE OF MINNESOTA
COUNTY OF BENTON
Before me, the undersigned authority, personally appeared the individual whose name is subscribed below, and who, being by me duly sworn, deposed as follows:
1. "My name is Vanessa Janssen. I am of sound mind, over the age of eighteen (18), have never been convicted of a felony or crime involving moral turpitude, and am capable of making this affidavit. I have personal knowledge of the facts herein stated as more fully set forth below."
2. "I am an Authorized Representative of Jefferson Capital Systems, LLC and in that capacity act as a Custodian of Records. These records are kept in the ordinary course of business. This affidavit pertains to the collection of a ASPIRE CREDIT CARD account number XXX6850, (the "Account") owed by DEBBIE COKER the "Defendant(s)."
3. "Jefferson Capital Systems, LLC has acquired the Account pursuant to an assignment and is the owner and beneficiary of all rights, title and interest with regard to the Account, including the outstanding balance of the Account and any accrued interest thereon. The information transmitted to Jefferson Capital Systems, LLC in connection with its acquisition of the Account specifically described: (1) the obligation of the Defendant with regard to the Account, (2) the open date of the Account, (3) the charge-off balance of the Account after all payments, credits and offsets had been applied, (4) the applicable rate at which interest continues to accrue on the Account, and (5) other usage and identification information related to both the Defendant and to the Account. My testimony herein is based upon that information."
4. "On or about 11/28/2021, the Defendant made application to open the Account. Thereafter, the Defendant utilized the Account, or the proceeds thereof, and became obligated to repay the Account pursuant to its terms."
5. "The Defendant did not repay the Account and ceased making payments on the Account. The last payment date was 2/13/2024."
6. "The Account was ultimately closed and charged-off, at which time there remained a balance due and owing on the Account that the Defendant has not paid."
7. "As of 09/18/2025, the reference date of this affidavit, the amount due and owing on the Account, after all just and lawful offsets, payments, and credits had been allowed, is $2,362.66."
Vanessa Janssen
Custodian of Records
SUBSCRIBED AND SWORN before me on SEP 22 2025.
CARLY E BRIGGS
NOTARY PUBLIC - MINNESOTA
My Comm. Exp. Jan. 31, 2029
EXHIBIT II
BILL OF SALE
For value received and in further consideration of the mutual covenants and conditions set forth in the Forward Flow Account Purchase Agreement (the “Agreement”) dated September 30, 2022 by and between The Bank of Missouri (“Seller”) and Jefferson Capital Systems, LLC (“Buyer”), Seller hereby transfers, sells, conveys, grants, and delivers to Buyer, its successors and assigns, without recourse except as set forth in the Agreement the Accounts as set forth in the Account Schedule attached hereto as Exhibit I delivered by Seller to Buyer on each Closing Date, and as further described in the Agreement.
Lot Number: 24-1036
Aggregate Unpaid Balance:
Number of Accounts:
DATED: October 21, 2024
SELLER: The Bank of Missouri
______________________________
By: ____________
Name (print): Mark Barker
Title: Chief Contract Services Officer
Affidavit of Account
STATE OF MINNESOTA
COUNTY OF BENTON
Before me, the undersigned authority, personally appeared the individual whose name is subscribed below, and who, being by me duly sworn, deposed as follows:
1. "My name is Vanessa Janssen. I am of sound mind, over the age of eighteen (18), have never been convicted of a felony or crime involving moral turpitude, and am capable of making this affidavit. I have personal knowledge of the facts herein stated as more fully set forth below."
2. "I am an Authorized Representative of Jefferson Capital Systems, LLC and in that capacity act as a Custodian of Records. These records are kept in the ordinary course of business. This affidavit pertains to the collection of a ASPIRE CREDIT CARD account number XXX6850, (the "Account") owed by DEBBIE COKER the "Defendant(s)."
3. "Jefferson Capital Systems, LLC has acquired the Account pursuant to an assignment and is the owner and beneficiary of all rights, title and interest with regard to the Account, including the outstanding balance of the Account and any accrued interest thereon. The information transmitted to Jefferson Capital Systems, LLC in connection with its acquisition of the Account specifically described: (1) the obligation of the Defendant with regard to the Account, (2) the open date of the Account, (3) the charge-off balance of the Account after all payments, credits and offsets had been applied, (4) the applicable rate at which interest continues to accrue on the Account, and (5) other usage and identification information related to both the Defendant and to the Account. My testimony herein is based upon that information."
4. "On or about 11/28/2021, the Defendant made application to open the Account. Thereafter, the Defendant utilized the Account, or the proceeds thereof, and became obligated to repay the Account pursuant to its terms."
5. "The Defendant did not repay the Account and ceased making payments on the Account. The last payment date was 2/13/2024."
6. "The Account was ultimately closed and charged-off, at which time there remained a balance due and owing on the Account that the Defendant has not paid."
7. "As of 09/18/2025, the reference date of this affidavit, the amount due and owing on the Account, after all just and lawful offsets, payments, and credits had been allowed, is $2,362.66."
Vanessa Janssen
Custodian of Records
SUBSCRIBED AND SWORN before me on SEP 22 2025.
CARLY E BRIGGS
NOTARY PUBLIC - MINNESOTA
My Comm. Exp. Jan. 21, 2029
Aspire Credit Card
Summary of Account Activity
Account Number [REDACTED]
Statement Closing Date September 12, 2024
Number of days in billing cycle 31
Total Credit Line $2,373.00
Available Credit $0
Overlimit Amount $0.00
Past Due Amount $252.00
Previous Balance $2,362.66
Payments $0.00
Credits $0.00
Purchases $0.00
Balance Transfers $0.00
Cash Advances $0.00
Interest Charged $0.00
Fees Charged $0.00
New Balance $2,362.66
Payment Information
New Balance $2,362.66
Minimum Payment Due $288.00
Payment Due Date Oct 09, 2024
Minimum Payment Warning: If you make only the 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 pay off 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 minimum payment</td>
<td>5 years</td>
<td>$2,363.00</td>
</tr>
</table>
If you would like information about credit counseling services, call 1-877-740-1191.
Cardholder Services
Payment Processing P.O. BOX 650832 DALLAS TX 75265-0832
Dispute Resolution P.O. BOX 105374 ATLANTA GA 30348-5374
Correspondence P.O. BOX 105555 ATLANTA GA 30348-5555
Account Inquiry (855) 802-5572
www.aspire.com
TTY Service (855) 921-5760
Important News
YOUR ACCOUNT IS SERIOUSLY PAST DUE $252.00.
2024 Year-to-Date Totals
Total Fees Charged in 2024 $276.00
Total Interest Charged in 2024 $341.81
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 (APR)</th>
<th>BALANCE SUBJECT TO INTEREST RATE</th>
<th>INTEREST CHARGE</th>
</tr>
<tr>
<td>Purchases</td>
<td>0.00%</td>
<td>$1,561.01</td>
<td>$0.00</td>
</tr>
<tr>
<td>Cash Advances</td>
<td>0.00%</td>
<td>$617.65</td>
<td>$0.00</td>
</tr>
</table>
PLEASE DETACH AND RETURN WITH YOUR PAYMENT
SEE REVERSE SIDE FOR IMPORTANT INFORMATION
Account Number: [REDACTED]
<table>
<tr>
<th>Minimum Payment Due</th>
<th>Payment Due Date</th>
<th>New Balance</th>
</tr>
<tr>
<td>$288.00</td>
<td>10/09/2024</td>
<td>$2,362.66</td>
</tr>
</table>
Amount Enclosed $[REDACTED]
Make checks payable to Aspire
Check here and complete reverse side for change of address [ ]
Mail Payment To: PAYMENT PROCESSING
P.O. BOX 650832
DALLAS TX 75265-0832
CHARGE OF ACCESS
Aspire Credit Card
Summary of Account Activity
Account Number [REDACTED]
Statement Closing Date March 12, 2024
Number of days in billing cycle 29
Total Credit Line $2,250.00
Available Credit $0
Overlimit Amount $0.00
Past Due Amount $130.54
Previous Balance $2,328.52
Payments $375.31
Credits $0.00
Purchases $0.00
Balance Transfers $0.00
Cash Advances $0.00
Interest Charged $52.40
Fees Charged $46.00
New Balance $2,051.61
Payment Information
New Balance $2,051.61
Minimum Payment Due $253.94
Payment Due Date Apr 09, 2024
Late Payment Warning: If we do not receive your minimum payment by the Payment Due Date shown above, you may have to pay up to a $41.00 late fee.
Minimum Payment Warning: If you make only the 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 pay off 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 minimum payment</td>
<td>6 years</td>
<td>$3,986.00</td>
</tr>
</table>
If you would like information about credit counseling services, call 1-877-740-1191.
Cardholder Services
Payment Processing P.O. BOX 650832 DALLAS TX 75265-0832
Dispute Resolution P.O. BOX 105374 ATLANTA GA 30348-5374
Correspondence P.O. BOX 105555 ATLANTA GA 30348-5555
Account Inquiry (855) 802-5572
TTY Service (855) 921-5760
www.aspire.com
Important News
YOUR ACCOUNT IS PAST DUE $130.54. THIS AMOUNT IS INCLUDED IN YOUR MINIMUM PAYMENT.
Transaction Summary
PAYMENTS & CREDITS
TRANS DATE POST DATE DESCRIPTION OF PAYMENT OR CREDIT AMOUNT
02/13/24 02/13/24 PHONE PAYMENT RECEIVED -- THANK YOU $375.31 PY
Fees Charged
TRANS DATE POST DATE DESCRIPTION OF TRANSACTION AMOUNT
03/03/24 03/03/24 ACCOUNT MAINTENANCE FEE $5.00
03/09/24 03/09/24 LATE PAYMENT CHARGE $41.00
TOTAL FEES FOR THIS PERIOD $46.00
Interest Charged
TRANS DATE POST DATE DESCRIPTION OF TRANSACTION AMOUNT
03/12/24 03/12/24 INTEREST CHARGE PURCHASE $36.66
03/12/24 03/12/24 INTEREST CHARGE CASH ADVANCE $15.74
PLEASE DETACH AND RETURN WITH YOUR PAYMENT
SEE REVERSE SIDE FOR IMPORTANT INFORMATION
Account Number: [REDACTED]
<table>
<tr>
<th>Minimum Payment Due</th>
<th>Payment Due Date</th>
<th>New Balance</th>
</tr>
<tr>
<td>$253.94</td>
<td>04/09/2024</td>
<td>$2,051.61</td>
</tr>
</table>
Amount Enclosed $__________.__________ Make checks payable to Aspire
Check here and complete reverse side for change of address ☐
Mail Payment To: PAYMENT PROCESSING
P.O. BOX 650832
DALLAS TX 75265-0832
[Unclear text]
<table>
<tr>
<th>TRANS DATE</th>
<th>POST DATE</th>
<th>DESCRIPTION OF TRANSACTION</th>
<th>AMOUNT</th>
</tr>
<tr>
<td colspan="3">TOTAL INTEREST FOR THIS PERIOD</td>
<td>$52.40</td>
</tr>
</table>
2024 Year-to-Date Totals
<table>
<tr>
<th></th>
<th></th>
<th></th>
</tr>
<tr>
<td>Total Fees Charged in 2024</td>
<td></td>
<td>$138.00</td>
</tr>
<tr>
<td>Total Interest Charged in 2024</td>
<td></td>
<td>$168.76</td>
</tr>
</table>
Interest Charge Calculation
<table>
<tr>
<th>TYPE OF BALANCE</th>
<th>ANNUAL PERCENTAGE RATE (APR)</th>
<th>BALANCE SUBJECT TO INTEREST RATE</th>
<th>INTEREST CHARGE</th>
</tr>
<tr>
<td>Purchases</td>
<td>31.24%</td>
<td>$1,408.64</td>
<td>$36.66</td>
</tr>
<tr>
<td>Cash Advances</td>
<td>34.24%</td>
<td>$551.94</td>
<td>$15.74</td>
</tr>
</table>
Your Annual Percentage Rate (APR) is the annual interest rate on your account.
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