Jefferson Capital Systems LLC v. Jesus Enriquez

26-04289-0 ZH1 010 IN THE DISTRICT COURT OF BRYAN COUNTY STATE OF OKLAHOMA JEFFERSON CAPITAL SYSTEMS LLC, ) ) ) ) ) ) vs. Jesus Enriquez, Defendant. PETITION FOR INDEBTEDNESS COMES NOW the Plaintiff, by and through its undersigned attorneys who hereby enter their appearance herein, and for its cause of action against the defendants alleges and states as follows: 1. ALLY BANK, provided credit to the defendant on account number XXXXXXXX5723. The Defendant defaulted on the obligation. The account has been assigned to Plaintiff. 2. Defendant owes Plaintiff $25,292.73. An Affidavit of Account and/or contract is attached hereto and incorporated by reference. WHEREFORE, Plaintiff prays for Judgment against the Defendant in the sum of $25,292.73, with interest at the statutory rate from the date of judgment, all court costs and a reasonable attorney's fee, and for such other relief as the Court may deem just and proper. William L. Nixon, Jr., #012804 Harley L. Homjak, #019736 Gracelyn Porras Dillingham, #35852 Jenifer A. Gani, #021876 Daniela Westfahl, #36242 Mariah S. Ellicott, #36309 Benjamin F. Brackett, #36580 LOVE, BEAL & NIXON, P.C. Attorney for Plaintiff P.O. Box 32738 Oklahoma City, OK 73123 Telephone: 405-720-0565 E-Mail: [email protected] 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 Fabiola Gonzalez. 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 ALLY BANK account number XXX5723, (the "Account") owed by JESUS ENRIQUEZ 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 07/02/2022, 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 6/21/2023." 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 12/22/2025, 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 $25,292.73." Fabiola Gonzalez Custodian of Records SUBSCRIBED AND SWORN before me on DEC. 26 2025. VANESSA JANSSEN NOTARY PUBLIC - MINNESOTA My Comm. Exp. Jan. 31, 2030