Tinker Federal Credit Union v. Joanna Seaton

IN THE DISTRICT COURT OF OKLAHOMA COUNTY STATE OF OKLAHOMA TINKER FEDERAL CREDIT UNION ) ) Plaintiff, vs. ) JOANNA SEATON, Defendant. PETITION CLAIM ONE: BREACH OF CONTRACT-PROMISSORY NOTE Plaintiff, Tinker Federal Credit Union ("TFCU"), for its First cause of action against Defendant, Joanna Seaton ("Defendant"), alleges and states as follows: 1. On or about January 31, 2024, Defendant executed a promissory note (hereinafter referred to as the "Contract") and became obligated to pay TFCU the principal amount of $19,516.67. A true and correct copy is attached hereto as Exhibit “A”. 2. Defendant has defaulted on the Contract by failing to timely pay and is indebted to TFCU in the amount of $16,913.79 as of October 3, 2025. 3. TFCU is entitled to reasonable attorney's fees and its reasonable costs of collection under the terms of the Contract and under 12 O.S. §936. 4. TFCU is entitled to pre and post judgment interest at the contractual rate of 14.9500% per annum. 5. Pursuant to the Servicemember’s Civil Relief Act of 2003, TFCU has reviewed the Department of Defense website and determined Defendant is not in the military. See the Affidavit attached hereto as Exhibit “B”. 6. Pursuant to 40 O.S. §4-508(D), TFCU 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. WHEREFORE, Tinker Federal Credit Union prays for judgment against Defendant, Joanna Seaton for $16,913.79, plus pre and post judgment interest at 14.9500% per annum and all contractual charges as set forth in the Contract, plus Plaintiff's court costs and a reasonable attorney's fee and all other relief this Court deems just. CLAIM TWO: BREACH OF CONTRACT-CREDIT CARD Plaintiff, Tinker Federal Credit Union ("TFCU"), for its Second cause of action against Defendant, Joanna Seaton ("Defendant"), alleges and states as follows: 7. On or about June 1, 2015, Defendant executed a credit card open account (hereinafter referred to as the "Contract") and became obligated to pay TFCU for all charges made thereon. See Exhibit “A”. 8. Defendant defaulted on the Contract by failing to timely pay and is indebted to TFCU in the amount of $18,648.19 as of October 3, 2025. 9. TFCU is entitled to contractual interest, reasonable attorney's fees and its reasonable costs of collection under the terms of the Contract and under 12 O.S. §936. 10. Pursuant to the Servicemember’s Civil Relief Act of 2003, TFCU has reviewed the Department of Defense website and determined Defendant is not in the military. See the Affidavit attached hereto as Exhibit “B”. 11. Pursuant to 40 O.S. §4-508(D), TFCU 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. WHEREFORE, Tinker Federal Credit Union prays for judgment against Defendant, Joanna Seaton for $18,648.19, plus contractual interest, TFCU's reasonable attorney's fees and costs incurred in pursuit of this action, TFCU's reasonable attorney's fees and costs incurred in collection of the Judgment and for such other and further relief as this Court deems just and proper. Respectfully submitted, Jeffery S. Ludlam, OBA #17822 HALL & LUDLAM, PLLC 210 Park Ave, Suite 3001 Oklahoma City, OK 73102 (405) 600-9500 Telephone (405) 871-5403 Facsimile [email protected] Loan and Security Agreements and Disclosure Statement Covered Borrower Under Military Lending Act FIXED RATE STEP RATE VARIABLE RATE LOAN DATE: 01/31/2024 LOAN NUMBER MATURITY DATE: 02/16/2029 BORROWER 1 (Name & Address) JOANNA SEATON 1712 S Willow Wind Dr Midwest City, OK 73130-6511 BORROWER 2 (Name & Address) BORROWER 3 (Name & Address) BORROWER 4 (Name & Address) TRUTH IN LENDING DISCLOSURE ('e' means an estimate) <table> <tr> <th>ANNUAL PERCENTAGE RATE</th> <th>FINANCE CHARGE</th> <th>Amount Financed</th> <th>Total of Payments</th> <th>Total Sale Price</th> </tr> <tr> <td>The cost of Your credit as a yearly rate.</td> <td>The dollar amount the credit will cost You.</td> <td>The amount of credit provided to You or on Your behalf.</td> <td>The amount You will have paid after You have made all payments as scheduled.</td> <td>The total cost of Your purchase on credit is<br>$ N/A<br>which includes Your downpayment of $ N/A</td> </tr> <tr> <td>14.950 %</td> <td>$ 8,487.70 e</td> <td>$19,516.67</td> <td>$ 28,004.37 e</td> <td></td> </tr> </table> Your Payment Schedule Will Be: <table> <tr> <th>Number of Payments</th> <th>Amount of Payments</th> <th>When Payments Are Due</th> </tr> <tr> <td>059</td> <td>$ 466.75</td> <td>Monthly BEGINNING 03/16/2024</td> </tr> <tr> <td>1</td> <td>$ 466.12 e</td> <td>Maturing 02/16/2029</td> </tr> </table> Prepayment: If You pay off early You will not have to pay a penalty. Required Deposit: The Annual Percentage Rate does not take into account Your required deposit, if any. Demand: [ ] This obligation has a demand feature. [ ] All disclosures are based on an assumed maturity of one year. Property Insurance: You may obtain property insurance from anyone You want that is acceptable to the Credit Union. If You get the insurance from the Credit Union You will pay $ Filing Fees: $ 0.00 Non-Filing Insurance: $ N/A Late Charge: If any payment or portion of payment you make is more than ten days past its due date, you will be charged the greater of $20.50 or 5.00% of the unpaid amount of the scheduled monthly payment. No late charge will be assessed on any payment when the delinquency is caused only by late fees assessed on earlier payments, and the payment received is otherwise a full payment. Security: Collateral securing other loans with the Credit Union may also secure this Loan. You are giving a security interest in Your shares and dividends and, if any, Your deposits and interest in the Credit Union; and the Property described below: <table> <tr> <th>Collateral</th> <th>Property/Model/Make</th> <th>Year</th> <th>I.D. Number</th> <th>Type</th> <th>Value</th> <th>Key Number</th> </tr> <tr> <td>N/A</td> <td></td> <td></td> <td></td> <td>N/A</td> <td>$ N/A</td> <td>N/A</td> </tr> <tr> <td>N/A</td> <td></td> <td></td> <td></td> <td>N/A</td> <td>$ N/A</td> <td>N/A</td> </tr> <tr> <td>N/A</td> <td></td> <td></td> <td></td> <td>N/A</td> <td>$ N/A</td> <td>N/A</td> </tr> </table> Other (Describe) Pledge of Shares $ 0.00 in Account No. $ 0.00 in Account No. Variable Rate: N/A See Your contract documents for any additional information about nonpayment, default, and any required repayment in full before the scheduled date. ITEMIZATION OF THE AMOUNT FINANCED ('e' means an estimate) <table> <tr> <th>Itemization of Amount Financed of</th> <th>Amount Given to You Directly</th> <th>Amount Paid on Your Account</th> <th>Prepaid Finance Charge</th> </tr> <tr> <td>$19,516.67</td> <td>$0.00</td> <td>$0.00</td> <td>$0.00</td> </tr> </table> Amounts Paid to Others on Your Behalf: (If an amount is marked with an asterisk (*) We will be retaining a portion of the amount.) <table> <tr> <th></th> <th></th> <th></th> <th></th> </tr> <tr> <td>$574.01</td> <td>To Synchrony Bank/CareCredit</td> <td>$0.00</td> <td>To</td> </tr> <tr> <td>$823.16</td> <td>To Sams Club MC/Syncb</td> <td>$0.00</td> <td>To</td> </tr> <tr> <td>$14,577.71</td> <td>To Tinker Federal Credit Uni</td> <td>$0.00</td> <td>To</td> </tr> <tr> <td>$3,541.79</td> <td>To Bob Mills Furniture</td> <td>$0.00</td> <td>To</td> </tr> <tr> <td>$0.00</td> <td>To</td> <td>$0.00</td> <td>To</td> </tr> <tr> <td>$0.00</td> <td>To</td> <td>$0.00</td> <td>To</td> </tr> <tr> <td>$0.00</td> <td>To</td> <td>$</td> <td>To</td> </tr> </table> MILITARY LENDING ACT DISCLOSURES Federal law provides important protections to members of the Armed Forces and their dependents relating to extensions of consumer credit. In general, the cost of consumer credit to a member of the Armed Forces and his or her dependent may not exceed an annual percentage rate of 36 percent. This rate must include, as applicable to the credit transaction or account: The costs associated with credit insurance premiums; fees for ancillary products sold in connection with the credit transaction; any application fee charged (other than certain application fees for specified credit transactions or accounts); and any participation fee charged (other than certain participation fees for a credit card account). Please call Us at 1-844-756-3767 to receive oral disclosures of the Military Lending Act disclosure above and a description of the payment obligation. A "Covered Borrower" for purposes of this loan means a consumer who, at the time the consumer becomes obligated on this loan, is a covered member or a dependent of a covered member as defined by the Military Lending Act. A Covered Borrower does not mean a consumer who (though a Covered Borrower at the time he or she became obligated on this transaction) no longer is a covered member or a dependent of a covered member as defined by the Military Lending Act. LOAN AGREEMENT In this Loan Agreement ("Agreement") all references to "Credit Union", "We", "Our" or "Us" mean the Credit Union whose name appears above and anyone to whom the Credit Union assigns or transfers this Agreement. All references to "You" or "Your" mean each person who signs, or otherwise authenticates, this Agreement as a borrower. 1. PROMISE TO PAY - You promise to pay $19,516.67 to the Credit Union plus interest on the unpaid balance until what You owe has been repaid. For fixed rate loans, the interest rate is 14.95% per year. For step-rate loans, the initial interest rate will be N/A % until N/A and then the interest rate will be N/A % until the balance is repaid in full. For variable rate loans, the initial interest rate is N/A % per year and will vary as follows: N/A You will pay principal and interest by making payments each month. Your initial monthly payment will be in the amount of U.S. $466.75 . You will make payments on the 16th day of each month beginning on 03/16/2024 . Subject only to the payment terms below, You will make these payments every month until You have paid all of the principal and interest and any other charges, described below, that You may owe under this Agreement. If, on 02/16/2029 , You still owe amounts under this Agreement, You will pay all amounts in full on that date. Collection Costs: In the event of default, You are liable for and agree to pay reasonable costs of collection to the extent permitted by applicable law. You agree to pay reasonable expenses and costs We incur in realizing on the security interest, including, without limitation, repossession costs, court costs, fees for replevin bonds, expert fees, storage costs, repair costs, preparation for sale expenses, filling costs, and selling costs. If You default and We refer Your debt to an attorney who is not one of Our salaried employees, You agree to pay reasonable attorney's fees in the amount of 15% of the unpaid debt. In the event of litigation or action to enforce Our rights, a court may award reasonable attorney's fees to a prevailing party in any transaction where such expenses and fees may be awarded in accordance with applicable law. 2. PAYMENTS - If you elect voluntary payment protection, we will include the premium or program fee in your payments. If you subsequently elect voluntary payment protection, we will either include the premium or program fee in your payments or extend the term of your loan. If the term is extended, you will be required to make additional payments of the scheduled amount, until what you owe has been paid. All prepayments will be applied first to accrued and unpaid fees and Finance Charge(s). Any language to the contrary notwithstanding, the balance of any prepayments may be applied, at the option of Lender, (i) to the final installments of the principal, beginning with the final installment, which may shorten the maturity of the loan or reduce the final payment or payments, (unless there is a missed payment) or (ii) to the prepayment of the next forthcoming installments of principal and interest, in order, which will not shorten the maturity of the loan or reduce any remaining payments. If you do not make payments exactly as scheduled, your final payment may be more or less than the amount of the final payment that is disclosed. You are allowed to prepay your loan balance and make monthly payments early without penalty; however, the "due date" for your next payment will not advance more than three (3) months. You are expected to make and continue to make and/or schedule a payment each month to meet the requirements of your loan agreement with us and to avoid default until your loan is paid in full. You promise to make all payments to the place we choose. If this loan refinances another loan we have with you, the other loan will be canceled and refinanced as of the date of this loan. Unless otherwise required by law, payments will be applied to amounts owed in the manner we choose. 3. LOAN PROCEEDS BY MAIL - If the proceeds of this loan are mailed to You, interest on this loan begins on the date the loan proceeds are mailed to You. 4. SECURITY FOR LOAN - This Agreement is secured by all property described in the "Security" section of the Truth in Lending Disclosure. Property securing other loans You have with Us also secures this loan, unless the property is a dwelling or otherwise prohibited by federal and/or state law. In addition to Your pledge of shares, We may also have what is known as a statutory lien on all individual and joint accounts You have with Us. A statutory lien means We have the right under federal and/or state law to claim an interest in Your accounts. Unless otherwise prohibited by federal and/or state law, We can enforce a statutory lien against Your shares and dividends and, if any, interest and deposits, in all individual and joint accounts You have with Us to satisfy any outstanding financial obligation that is due and payable to Us. We may exercise Our right to enforce this lien without further notice to You, to the extent permitted by law. For all borrowers: You pledge as security for this loan all shares and dividends and, if any, all deposits and interest in all joint and individual accounts You have with the Credit Union now and in the future. The statutory lien and/or Your pledge will allow Us to apply the funds in Your account(s) to what You owe when You are in default. If a dollar amount and account number are listed in the "Security" section of the Truth in Lending Disclosure, You may not withdraw the amount that has been specifically pledged to secure this loan until the Credit Union agrees to release all or part of the pledged amount. The statutory lien and Your pledge do not apply to any Individual Retirement Account or any other account that would lose special tax treatment under state or federal law if given as security. 5. DEFAULT - You will be in default under this Agreement if You do not make a payment of the amount required on or before the date it is due. You will be in default if You break any promise You made in connection with this loan or if anyone is in default under any security agreement made in connection with this Agreement. You will be in default if You die, file for bankruptcy, become insolvent (that is, unable to pay Your bills and loans as they become due), or if You made any false or misleading statements in Your loan application. You will also be in default if something happens that We believe may seriously affect Your ability to repay what You owe under this Agreement or if You are in default under any other loan agreement You have with Us. 6. ACTIONS AFTER DEFAULT - When You are in default, We may demand immediate payment of the entire unpaid balance under this Agreement. If We demand immediate payment, You will continue to pay interest at the rate provided for in this Agreement, until what You owe has been repaid. We will also apply against what You owe any shares and/or deposits given as security under this Agreement. We may also exercise any other rights given by law when You are in default. Unless You are a Covered Borrower under the Military Lending Act, You waive any right You have to receive demand for payment, notice of intent to demand immediate payment and notice of demand for immediate payment. 7. EACH PERSON RESPONSIBLE - Each person who signs, or otherwise authenticates, this Agreement will be individually and jointly responsible for paying the entire amount owed under this Agreement. This means We can enforce Our rights against any one of You individually or against all of You together. 8. LATE CHARGE - If You are late in making a payment, You promise to pay the late charge shown in the Truth in Lending Disclosure. If no late charge is shown, You will not be charged one. 9. DELAY IN ENFORCING RIGHTS - We can delay enforcing any of Our rights under this Agreement any number of times without losing the ability to exercise Our rights later. We can enforce this Agreement against Your heirs or legal representatives. 10. CONTINUED EFFECTIVENESS - If any part of this Agreement is determined by a court to be unenforceable, the rest will remain in effect. 11. NOTICES - Notices will be sent to You at the most recent address You have given Us in writing. Notice to any one of You will be notice to all. 12. USE OF ACCOUNT - You promise to use Your account for consumer (personal, family or household) purposes, unless the Credit Union gives You written permission to use the account also for agricultural or commercial purposes, or to purchase real estate. 13. NO ORAL AGREEMENTS -- THIS NOTE CONSTITUTES A "WRITTEN LOAN AGREEMENT" PURSUANT TO SECTION 26.02 OF THE TEXAS BUSINESS AND COMMERCE CODE, IF SUCH SECTION APPLIES. THIS WRITTEN LOAN AGREEMENT REPRESENTS THE FINAL AGREEMENT BETWEEN THE PARTIES AND MAY NOT BE CONTRADICTED BY EVIDENCE OF PRIOR, CONTEMPORANEOUS, OR SUBSEQUENT ORAL AGREEMENTS OF THE PARTIES. THERE ARE NO UNWRITTEN ORAL AGREEMENTS BETWEEN THE PARTIES. 14. The following is required by Vermont law: NOTICE TO COSIGNER: YOUR SIGNATURE ON THIS NOTE MEANS THAT YOU ARE EQUALLY LIABLE FOR REPAYMENT OF THIS LOAN. IF THE BORROWER DOES NOT PAY, THE LENDER HAS A LEGAL RIGHT TO COLLECT FROM YOU. 15. NOTICE TO UTAH BORROWERS: This written Agreement is the final expression of the Agreement between You and the Credit Union. This written Agreement may not be contradicted by evidence of any oral agreement. 16. GOVERNING LAW - Unless otherwise required by applicable federal or state law, this Agreement is governed by Oklahoma state law. 17. ARBITRATION - For any disputes or claims arising out of this Agreement, all such disputes or claims will be handled in accordance with the Terms and Conditions of Your Account with Tinker Federal Credit Union. THE ARBITRATION OF CLAIMS AND DISPUTES AND CLASS ACTION WAIVER SECTION IN YOUR TERMS AND CONDITIONS OF YOUR ACCOUNT CONTAINS IMPORTANT INFORMATION REGARDING HOW DISPUTES WILL BE HANDLED ARISING OUT OF THIS AGREEMENT, INCLUDING A REQUIREMENT TO HANDLE DISPUTES THROUGH ARBITRATION AND GIVING UP YOUR RIGHT TO A JURY TRIAL OR ABILITY TO PARTICIPATE AS A CLASS REPRESENTATIVE. This waiver will apply unless you are a Covered Borrower under the Military Lending Act or unless otherwise prohibited by law. 18. OTHER PROVISIONS - SECURITY AGREEMENT In this Security Agreement ("Agreement") all references to "Credit Union", "We", "Our" or "Us" mean the Credit Union whose name appears on this document and anyone to whom the Credit Union assigns or transfers this Agreement. All references to the "Loan" mean the loan described in the Loan Agreement that is part of this document. All references to "You" or "Your" mean any person who signs, or otherwise authenticates, this Agreement. 1. THE SECURITY FOR THE LOAN - You give Us what is known as a security interest in the Property described in the "Security" section of the Truth in Lending Disclosure that is part of this document ("the Property"). The security interest You give includes all accessions. Accessions are things which are attached to or installed in the Property now or in the future. The security interest also includes any replacements for the Property which You buy within 10 days of the Loan and any extensions, renewals or refinancings of the Loan. It also includes any money You receive from selling the Property or from insurance You have on the Property. If the value of the Property declines, You promise to give Us more property as security if asked to do so. 2. WHAT THE SECURITY INTEREST COVERS/CROSS COLLATERAL PROVISIONS - The security interest secures the Loan and any extensions, renewals or refinancings of the Loan. Unless prohibited by applicable law, the security interest also secures any other loans, including any credit card loan, You have now or receive in the future from Us and any other amounts You owe Us for any reason now or in the future, except any loan secured by Your principal dwelling. If the Property is household goods as defined by the Federal Trade Commission Credit Practices Rule or Your principal dwelling, the Property will secure only this Loan and not other loans or amounts You owe Us. 3. OWNERSHIP OF THE PROPERTY - You promise that You own the Property or, if this Loan is to buy the Property, You promise You will use the Loan proceeds for that purpose. You promise that no one else has any interest in or claim against the Property that You have not already told Us about. You promise not to sell or lease the Property or to use it as security for a loan with another creditor until the Loan is repaid. You promise You will allow no other security interest or lien to attach to the Property either by Your actions or by operation of law. 4. PROTECTING THE SECURITY INTEREST - If Your state issues a title for the Property, You promise to have Our security interest shown on the title. We may have to file what is called a financing statement to protect Our security interest from the claims of others. You irrevocably authorize Us to execute (on Your behalf), if applicable, and file one or more financing, continuation or amendment statements pursuant to the Uniform Commercial Code (UCC) in a form satisfactory to Us. You promise to do whatever else We think is necessary to protect Our security interest in the Property. You also promise to pay all costs, including but not limited to any attorney fees, We incur in protecting Our security interest and rights in the Property, to the extent permitted by applicable law. 5. USE OF PROPERTY - Until the Loan has been paid off, You promise You will: (1) Use the Property carefully and keep it in good repair. (2) Obtain Our written permission before making major changes to the Property or changing the address where the Property is kept. (3) Inform Us in writing before changing Your address. (4) Allow Us to inspect the Property. (5) Promptly notify Us if the Property is damaged, stolen or abused. (6) Not use the Property for any unlawful purpose. (7) Not retitle the Property in another state without telling Us. 6. PROPERTY INSURANCE, TAXES AND FEES - You promise to pay all taxes and fees (like registration fees) due on the Property and to keep the Property insured against loss and damage. The amount and coverage of the property insurance must be acceptable to Us. You may provide the property insurance through a policy You already have, or through a policy You get and pay for. You promise to make the insurance policy payable to Us and to deliver the policy or proof of coverage to Us if asked to do so. If You cancel Your insurance and get a refund, We have a right to the refund. If the Property is lost or damaged, We can use the insurance settlement to repair the Property or apply it towards what You owe. You authorize Us to endorse any draft or check which may be payable to You in order for Us to collect any refund or benefits due under Your insurance policy. If You do not pay the taxes or fees on the Property when due or keep it insured, We may pay these obligations, but We are not required to do so. Any money We spend for taxes, fees or insurance will be added to the unpaid balance of the Loan and You will pay interest on those amounts at the same rate You agreed to pay on the Loan. We may receive payments in connection with the insurance from a company which provides the insurance. We may monitor Our loans for the purpose of determining whether You and other borrowers have complied with the insurance requirements of Our loan agreements or may engage others to do so. The insurance charge added to the Loan may include (1) the insurance company's payments to Us and (2) the cost of determining compliance with the insurance requirements. If We add amounts for taxes, fees or insurance to the unpaid balance of the Loan, We may increase Your payments to pay the amount added within the term of the insurance or term of the Loan. 7. INSURANCE NOTICE - If You do not purchase the required property insurance, the insurance We may purchase and charge You for will cover only Our interest in the Property. The premium for this insurance may be higher because the insurance company may have given Us the right to purchase insurance after uninsured collateral is lost or damaged. The insurance will not be liability insurance and will not satisfy any state financial responsibility or no fault laws. 8. DEFAULT - You will be in default if You break any promise You make or fail to perform any obligation You have under this Agreement. You will also be in default under this Agreement if the Loan is in default. You will be in default if any Property You have given Us as security is repossessed by someone else, seized under a forfeiture or similar law, or if anything else happens that significantly affects the value of the Property or Our security interest in it. 9. WHAT HAPPENS IF YOU ARE IN DEFAULT - When You are in default, We may demand immediate payment of the outstanding balance of the Loan without giving You advance notice and take possession of the Property. You agree the Credit Union has the right to take possession of the Property without judicial process if this can be done without breach of the peace. If We ask, You promise to deliver the Property at a time and place We choose. If the Property is a motor vehicle or boat, You agree that We may obtain a key or other device necessary to unlock and operate it, when You are in default. We will not be responsible for any other property not covered by this Agreement that You leave inside the Property or that is attached to the Property. We will try to return that property to You or make it available for You to claim. After We have possession of the Property, We can sell it and apply the money to any amounts You owe Us. We will give You notice of any public disposition or the date after which a private disposition will be held. Our expenses for taking possession of and selling the Property will be deducted from the money received from the sale. Those costs may include the cost of storing the Property, preparing it for sale and attorney’s fees to the extent permitted under state law or awarded under the Bankruptcy Code. If You have agreed to pay the Loan, You must pay any amount that remains unpaid after the sale money has been applied to the unpaid balance of the Loan and to what You owe under this Agreement. You agree to pay interest on that amount at the same rate as the Loan until that amount has been paid. 10. DELAY IN ENFORCING RIGHTS AND CHANGES IN THE LOAN - We can delay enforcing any of Our rights under this Agreement any number of times without losing the ability to exercise Our rights later. We can enforce this Agreement against Your heirs or legal representatives. If We change the terms of the Loan, You agree that this Agreement will remain in effect. 11. CONTINUED EFFECTIVENESS - If any part of this Agreement is determined by a court to be unenforceable, the rest will remain in effect. 12. NOTICE FOR ARIZONA OWNERS OF PROPERTY - It is unlawful for You to fail to return a motor vehicle that is subject to a security interest, within thirty days after You have received notice of default. The notice will be mailed to the address You gave Us. It is Your responsibility to notify Us if Your address changes. The maximum penalty for unlawful failure to return a motor vehicle is one year in prison and/or a fine of $150,000.00. ☐ The following notice applies ONLY when the box at left is marked. 13. 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. 14. OTHER PROVISIONS -Unless otherwise required by applicable federal or state law, this Agreement is governed by Oklahoma state law. For any disputes or claims arising out of this Agreement, all such disputes or claims will be handled in accordance with the Terms and Conditions of Your Account with Tinker Federal Credit Union. THE ARBITRATION OF CLAIMS AND DISPUTES AND CLASS ACTION WAIVER SECTION IN YOUR TERMS AND CONDITIONS YOUR ACCOUNT CONTAINS IMPORTANT INFORMATION REGARDING HOW DISPUTES WILL BE HANDLED ARISING OUT OF THIS AGREEMENT, INCLUDING A REQUIREMENT TO HANDLE DISPUTES THROUGH ARBITRATION AND GIVING UP YOUR RIGHT TO A JURY TRIAL OR ABILITY TO PARTICIPATE AS A CLASS REPRESENTATIVE. SIGNATURES By signing, or otherwise authenticating, as Borrower, You agree to the terms of the Loan Agreement. If Property is described in the "Security" section of the Truth in Lending Disclosure, You also agree to the terms of the Security Agreement. If You sign, or otherwise authenticate, as "Owner of Property" You agree only to the terms of the Security Agreement. CAUTION: IT IS IMPORTANT THAT YOU THOROUGHLY READ THE AGREEMENT BEFORE YOU SIGN IT <table> <tr> <th>Borrower 1 Signature</th> <th>Date</th> </tr> <tr> <td>JOANNA SEATON</td> <td>01/31/2024<br>(Seal)</td> </tr> </table> <table> <tr> <th>Borrower 2 Signature</th> <th>Date</th> </tr> <tr> <td></td> <td>01/31/2024<br>(Seal)</td> </tr> </table> <table> <tr> <th>Signature</th> <th>Date</th> </tr> <tr> <td>X</td> <td>01/31/2024<br>(Seal)</td> </tr> </table> <table> <tr> <th>Signature</th> <th>Date</th> </tr> <tr> <td>X</td> <td>01/31/2024<br>(Seal)</td> </tr> </table> ☐ Borrower 3: ☐ Owner of Property ☐ Witness ☐ Borrower 4: ☐ Owner of Property ☐ Witness Credit Union Tinker Federal Credit Union P.O. Box 45750 Tinker AFB, OK 73145 BORROWER 1 (Name & Address) JOANNA SEATON 1712 S Willow Wind Dr Midwest City OK 73130-6511 OWNER OF PROPERTY NAME AND ADDRESS <table> <tr> <th>Collateral</th> <th>Property/Model/Make</th> <th>Year</th> <th>I.D. Number</th> <th>Lien Amount</th> <th>Value</th> <th>Key Number</th> </tr> <tr> <td></td> <td></td> <td></td> <td></td> <td>$ 0.00</td> <td>$ N/A</td> <td>N/A</td> </tr> <tr> <td></td> <td></td> <td></td> <td></td> <td>$ N/A</td> <td>$ N/A</td> <td>N/A</td> </tr> <tr> <td></td> <td></td> <td></td> <td></td> <td>$ N/A</td> <td>$ N/A</td> <td>N/A</td> </tr> </table> Other (Describe) Pledge of Shares $0.00 in Account No. $0.00 in Account No. SECURITY AGREEMENT In this Security Agreement ("Agreement") all references to "Credit Union", "We", "Our" or "Us" mean the Credit Union whose name appears on this document and anyone to whom the Credit Union assigns or transfers this Agreement. All references to the "Loan" mean the loan described in the Loan Agreement that is part of this document. All references to "You" or "Your" mean any person who signs, or otherwise authenticates, this Agreement. 1. THE SECURITY FOR THE LOAN - You give Us what is known as a security interest in the Property described in the "Security" section of the Truth in Lending Disclosure that is part of this document ("the Property"). The security interest You give includes all accessions. Accessions are things which are attached to or installed in the Property now or in the future. The security interest also includes any replacements for the Property which You buy within 10 days of the Loan and any extensions, renewals or refinancings of the Loan. It also includes any money You receive from selling the Property or from insurance You have on the Property. If the value of the Property declines, You promise to give Us more property as security if asked to do so. 2. WHAT THE SECURITY INTEREST COVERS/CROSS COLLATERAL PROVISIONS - The security interest secures the Loan and any extensions, renewals or refinancings of the Loan. Unless prohibited by applicable law, the security interest also secures any other loans, including any credit card loan, You have now or receive in the future from Us and any other amounts You owe Us for any reason now or in the future, except any loan secured by Your principal dwelling. If the Property is household goods as defined by the Federal Trade Commission Credit Practices Rule or Your principal dwelling, the Property will secure only this Loan and not other loans or amounts You owe Us. 3. OWNERSHIP OF THE PROPERTY - You promise that You own the Property or, if this Loan is to buy the Property, You promise You will use the Loan proceeds for that purpose. You promise that no one else has any interest in or claim against the Property that You have not already told Us about. You promise not to sell or lease the Property or to use it as security for a loan with another creditor until the Loan is repaid. You promise You will allow no other security interest or lien to attach to the Property either by Your actions or by operation of law. 4. PROTECTING THE SECURITY INTEREST - If Your state issues a title for the Property, You promise to have Our security interest shown on the title. We may have to file what is called a financing statement to protect Our security interest from the claims of others. You irrevocably authorize Us to execute (on Your behalf), if applicable, and file one or more financing, continuation or amendment statements pursuant to the Uniform Commercial Code (UCC) in a form satisfactory to Us. You promise to do whatever else We think is necessary to protect Our security interest in the Property. You also promise to pay all costs, including but not limited to any attorney fees, We incur in protecting Our security interest and rights in the Property, to the extent permitted by applicable law. 5. USE OF PROPERTY - Until the Loan has been paid off, You promise You will: (1) Use the Property carefully and keep it in good repair. (2) Obtain Our written permission before making major changes to the Property or changing the address where the Property is kept. (3) Inform Us in writing before changing Your address. (4) Allow Us to inspect the Property. (5) Promptly notify Us if the Property is damaged, stolen or abused. (6) Not use the Property for any unlawful purpose. (7) Not retitle the Property in another state without telling Us. 6. PROPERTY INSURANCE, TAXES AND FEES - You promise to pay all taxes and fees (like registration fees) due on the Property and to keep the Property insured against loss and damage. The amount and coverage of the property insurance must be acceptable to Us. You may provide the property insurance through a policy You already have, or through a policy You get and pay for. You promise to make the insurance policy payable to Us and to deliver the policy or proof of coverage to Us if asked to do so. If You cancel Your insurance and get a refund, We have a right to the refund. If the Property is lost or damaged, We can use the insurance settlement to repair the Property or apply it towards what You owe. You authorize Us to endorse any draft or check which may be payable to You in order for Us to collect any refund or benefits due under Your insurance policy. If You do not pay the taxes or fees on the Property when due or keep it insured, We may pay these obligations, but We are not required to do so. Any money We spend for taxes, fees or insurance will be added to the unpaid balance of the Loan and You will pay interest on those amounts at the same rate You agreed to pay on the Loan. We may receive payments in connection with the insurance from a company which provides the insurance. We may monitor Our loans for the purpose of determining whether You and other borrowers have complied with the insurance requirements of Our loan agreements or may engage others to do so. The insurance charge added to the Loan may include (1) the insurance company's payments to Us and (2) the cost of determining compliance with the insurance requirements. If We add amounts for taxes, fees or insurance to the unpaid balance of the Loan, We may increase Your payments to pay the amount added within the term of the insurance or term of the Loan. 7. INSURANCE NOTICE - If You do not purchase the required property insurance, the insurance We may purchase and charge You for will cover only Our interest in the Property. The premium for this insurance may be higher because the insurance company may have given Us the right to purchase insurance after uninsured collateral is lost or damaged. The insurance will not be liability insurance and will not satisfy any state financial responsibility or no fault laws. 8. DEFAULT - You will be in default if You break any promise You make or fail to perform any obligation You have under this Agreement. You will also be in default under this Agreement if the Loan is in default. You will be in default if any Property You have given Us as security is repossessed by someone else, seized under a forfeiture or similar law, or if anything else happens that significantly affects the value of the Property or Our security interest in it. 9. WHAT HAPPENS IF YOU ARE IN DEFAULT - When You are in default, We may demand immediate payment of the outstanding balance of the Loan without giving You advance notice and take possession of the Property. You agree the Credit Union has the right to take possession of the Property without judicial process if this can be done without breach of the peace. If We ask, You promise to deliver the Property at a time and place We choose. If the Property is a motor vehicle or boat, You agree that We may obtain a key or other device necessary to unlock and operate it, when You are in default. We will not be responsible for any other property not covered by this Agreement that You leave inside the Property or that is attached to the Property. We will try to return that property to You or make it available for You to claim. After We have possession of the Property, We can sell it and apply the money to any amounts You owe Us. We will give You notice of any public disposition or the date after which a private disposition will be held. Our expenses for taking possession of and selling the Property will be deducted from the money received from the sale. Those costs may include the cost of storing the Property, preparing it for sale and attorney's fees to the extent permitted under state law or awarded under the Bankruptcy Code. If You have agreed to pay the Loan, You must pay any amount that remains unpaid after the sale money has been applied to the unpaid balance of the Loan and to what You owe under this Agreement. You agree to pay interest on that amount at the same rate as the Loan until that amount has been paid. 10. DELAY IN ENFORCING RIGHTS AND CHANGES IN THE LOAN - We can delay enforcing any of Our rights under this Agreement any number of times without losing the ability to exercise Our rights later. We can enforce this Agreement against Your heirs or legal representatives. If We change the terms of the Loan, You agree that this Agreement will remain in effect. 11. CONTINUED EFFECTIVENESS - If any part of this Agreement is determined by a court to be unenforceable, the rest will remain in effect. 12. NOTICE FOR ARIZONA OWNERS OF PROPERTY - It is unlawful for You to fail to return a motor vehicle that is subject to a security interest, within thirty days after You have received notice of default. The notice will be mailed to the address You gave Us. It is Your responsibility to notify Us if Your address changes. The maximum penalty for unlawful failure to return a motor vehicle is one year in prison and/or a fine of $150,000.00. ☐ The following notice applies ONLY when the box at left is marked. 13. 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. 14. OTHER PROVISIONS - Unless otherwise required by applicable federal or state law, this Agreement is governed by Oklahoma state law. For any disputes or claims arising out of this Agreement, all such disputes or claims will be handled in accordance with the Terms and Conditions of Your Account with Tinker Federal Credit Union. THE ARBITRATION OF CLAIMS AND DISPUTES AND CLASS ACTION WAIVER SECTION IN YOUR TERMS AND CONDITIONS YOUR ACCOUNT CONTAINS IMPORTANT INFORMATION REGARDING HOW DISPUTES WILL BE HANDLED ARISING OUT OF THIS AGREEMENT, INCLUDING A REQUIREMENT TO HANDLE DISPUTES THROUGH ARBITRATION AND GIVING UP YOUR RIGHT TO A JURY TRIAL OR ABILITY TO PARTICIPATE AS A CLASS REPRESENTATIVE. SIGNATURES By signing, or otherwise authenticating, You agree to the terms of this Security Agreement. <table> <tr> <th>Owner of Property</th> <th>Date</th> </tr> <tr> <td>X<br>(Seal)</td> <td>01/31/2024</td> </tr> <tr> <th>Signature</th> <th>Date</th> </tr> <tr> <td>X<br>(Seal)</td> <td>01/31/2024</td> </tr> </table> <table> <tr> <th>Owner of Property</th> <th>Date</th> </tr> <tr> <td>X<br>(Seal)</td> <td>01/31/2024</td> </tr> <tr> <th>Signature</th> <th>Date</th> </tr> <tr> <td>X<br>(Seal)</td> <td>01/31/2024</td> </tr> </table> ☐ Owner of Property | ☐ Witness Account 0002361653 Account Type: General Membership Member JOANNA RUTHERFORD JODI KYLE ZACHARY L FAY KELLI J WALRAVEN JODI KYLE ZACHARY L FAY KELLI J WALRAVEN JODI KYLE ZACHARY L FAY KELLI J WALRAVEN Type Primary Beneficiary S 0001 Beneficiary S 0001 Beneficiary S 0001 Beneficiary S 0004 Beneficiary S 0004 Beneficiary S 0004 Beneficiary S 0007 Beneficiary S 0007 Beneficiary S 0007 Home Phone 405-737-6648 Joanna Rutherford Heritage 3303 MOCKINGBIRD LN MIDWEST CITY, OK 73110-3813 Share | Description | Maturity Date | Available | Balance S 0001 | PRIMARY SHARE | | 869.86 | 874.86 S 0004 | HERITAGE CHECKING | | 2,697.30 | 2,697.30 S 0007 | COMMAND FUND | | 317.89 | 317.89 Loan | Description | Due Date | Payment | Avail/DQ* | Balance L 0061 | IDL 2014 FORD F-150 | 06/01/2015 | 771.21 T | | 57,813.31 L 0062 | SIGNATURE CLOSED END FIXED | 05/28/2015 | 285.40 C | | 13,406.69 BS SEATON, JOANNA**11355 S BRYANT AVE LOT 2**EDMOND*OK*73034-8615* CRCD 840 10/03/25 11:14 CUR BAL 18,564.94 STTS CD INT/EX D/ HOME PHONE 405-694-6554 CRDT LIMIT 20,000 CYCLE CODE 19 WORK PHONE 405-594-6554 AVLB CRDT 1,435 OPEN DATE 06-15 SOC SEC # LS BAL 18,564.94 EXP DATE 06-26 CHECKING PRV H BAL 18,565 PLST# 01 TYPE 1 SAVINGS 0002361653 LST PMT AM 1,000 LST PMT DT 05-15-25 ANNUAL CHARGE 00-00 0 AM DUE 2,457 LST MON 10-02-25 A CREDIT LINE 11-19 M DSP 0 0 0 LST NM 09-21-25 791 FX PY AM 0.00 AM DLQ 1,900 AUTH FLG PIN TR 0 RENEWAL CODE 6 CONTROL 0 # DAYS DELINQUENT 133 OVERLIMIT HIST 0 USER FLAGS V # TIMES 1 CYCLE 4 TERMS LEVEL 1 SPECIAL FLAGS H # TIMES 2 CYCLES 0 HIST 43CR QQQQ RRBQ MISC F 532 BENSON # TIMES 3 CYCLES 2 REAGE COUNTER 00 MONTHS GROSS ACTIVE 33 REOURSE FLAG N STS CD CHG 00-00-00 DELQ SCENARIO 0000 CASH OUT 0 AUTO PAYMNT FLAG 0 SCORE: BH 263 CR 774 YTD INT 346.29 CRDT BUREAU FLAG 1 CREDIT LIFE 0 / DUALITY 0 CROSS REFERENCE 1 0000000000000000 2 0000000000000000 3 CPO SEATON, JOANNA**11355 S BRYANT AVE LOT 2**EDMOND*OK*73034-8615* PER DAY INTEREST ACCOUNT PAYOFF 10/03/25 18,648.1855 10/04/25 18,654.5890 10/05/25 18,660.9925 10/06/25 18,667.3960 10/07/25 18,673.7995 10/08/25 18,680.2030 10/09/25 18,686.6065 10/10/25 18,693.0100 10/11/25 18,699.4135 10/12/25 18,705.8170 10/13/25 18,712.2205 CSS ** ENTER CPF TO DISPLAY NEXT CRCD 840 RL 0001 OF 0001 11:14:43 10/03/2 SEATON, JOANNA**11355 S BRYANT AVE LOT 2**EDMOND*OK*73034-8615* 0919 1014 31N 2457.00 D 20000 143507 0 01 LATE FEE 22.00 02 TOTAL FEES FOR THIS PERIOD 22.00 03 Interest Charge on Purchases 191.92 04 Interest Charge on Cash Advances - 05 TOTAL INTEREST FOR THIS PERIOD 191.92 06 CUREWARDS POINTS ACTIVITY 07 BEGINNING BALANCE 53,175 08 POINTS EARNED 0 09 POINTS REDEEMED 0 10 POINTS AVAILABLE 53,175 11 12 POINTS TO EXPIRE 9,835 13 EXPIRATION DATE DEC 2025 14 15 FOR CUREWARDS PROGRAM QUESTIONS CALL (800) 637-7728 18351.02 .00 .00 .00 .00 22.00 191.92 18564.94 1.083 13.00 .00 BRK PNT BRK PNT ADB MDSE ADB CASH 1.083 13.00 .00 ***************************** 17721.31 .00 ; AFFIDAVIT STATE OF OKLAHOMA COUNTY OF OKLAHOMA ) ss. Tay Parker, of lawful age, being first duly sworn, upon oath deposes and states: 1. I am a Collections Legal Specialist for Tinker Federal Credit Union and I am authorized to make this Affidavit of its behalf. Based on a review of the Department of Defense website Joanna Seaton not in the military. A copy is attached hereto. Signed under penalty of perjury, Parker Tay Parker Subscribed and sworn to before me this 3rd day of October, 2025. [signature] Notary Public My Commission Expires: (SEAL) Status Report Pursuant to Servicemembers Civil Relief Act SSN: XXX-XX-6972 Birth Date: Last Name: SEATON First Name: JOANNA Middle Name: Status As Of: Oct-03-2025 Certificate ID: F2ZSFC3GQKX5PWX <table> <tr> <th colspan="4">On Active Duty On Active Duty Status Date</th> </tr> <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> <tr> <td colspan="4">This response reflects the individuals' active duty status based on the Active Duty Status Date</td> </tr> </table> <table> <tr> <th colspan="4">Left Active Duty Within 367 Days of Active Duty Status Date</th> </tr> <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> <tr> <td colspan="4">This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date</td> </tr> </table> <table> <tr> <th colspan="4">The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date</th> </tr> <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> <tr> <td colspan="4">This response reflects whether the individual or his/her unit has received early notification to report for active duty</td> </tr> </table> 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.