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CANADIAN COUNTY • CJ-2026-397

BOAC AIF A4 INTERVAL PAGANI TRUST Serviced by UPGRADE INC. v. TAMARA CRENSHAW

Filed: Apr 28, 2026
Type: CJ

What's This Case About?

Let’s be real: you don’t expect a loan dispute to sound like a Mission: Impossible spin-off with a trust named after a hypercar (yes, Pagani), but here we are — the BOAC AIF A4 INTERVAL PAGANI TRUST is suing a woman from Yukon, Oklahoma, because she stopped paying her $16,500 loan, and now they want nearly $18,000 back. And no, we don’t know why the trust has a name that sounds like a secret crypto fund designed by Tony Stark — but we do know this case is peak petty civil court drama, served with a side of financial irony.

So who are these people? On one side, you’ve got Tamara Crenshaw — a regular Oklahoma resident living at a nice, unassuming address on North Yukon Parkway. She’s not a bank, she’s not a fintech genius, she’s just… a borrower. On the other side? A mouthful: BOAC AIF A4 INTERVAL PAGANI TRUST, “serviced by Upgrade Inc.” Let’s unpack that. BOAC AIF A4 INTERVAL PAGANI TRUST is not a person. It’s not even really a company you can Google without hitting a wall of corporate shell games. It’s almost certainly a special-purpose trust — a financial vehicle designed to hold loans and sell them off to investors, like a glorified loan storage unit with a dramatic name. Think of it as the storage locker of debt, where defaulted loans go to live in quiet shame until someone sues to collect. And servicing it? Upgrade Inc., a San Francisco-based fintech that acts as the middleman between borrowers like Tamara and the faceless trusts that eventually own their debt. So Tamara didn’t borrow from a bank she’s ever met — she clicked through an online portal, agreed to terms she probably didn’t read (same, girl), and suddenly, her financial fate was tied to a trust named after a $3 million Italian supercar. That’s modern lending, baby.

Now, what actually happened? According to the petition filed in Canadian County District Court, Tamara applied for a loan through Upgrade’s online platform. Upgrade, as a tech company, doesn’t actually lend the money — that part was handled by Cross River Bank, a real, FDIC-insured bank based in New Jersey. But Upgrade runs the app, manages the payments, and, when things go south, sues on behalf of the trust that now owns the debt. It’s a very 2025 way to borrow $16,500. The loan was issued, Tamara presumably got her money (maybe for debt consolidation, maybe for a new roof, maybe for a Pagani of her own — we’ll never know), and for a while, everything was fine. She made payments. Life went on. Then — plot twist — on or about May 6, 2025, Tamara stopped paying. Poof. Default. The account was charged off, meaning the lender gave up on regular payments and decided to collect what they could through legal action. Now, the total owed? $17,758.03 — which includes the original $16,500 plus interest, fees, and whatever other financial demons creep in when a loan goes sideways.

So why are we in court? Because Upgrade — acting for the Pagani Trust — is throwing the legal kitchen sink at Tamara. First claim: breach of contract. Simple enough — you sign a loan agreement, you promise to pay, you don’t pay, you broke the contract. They want the $17k they say she owes. Second: unjust enrichment. That’s legalese for “you got something you didn’t pay for, and it’s not fair for you to keep it.” The argument here is that Tamara benefited from the $16,500 — she spent it, used it, enjoyed it — and now refusing to pay makes her a financial freeloader. The court, they argue, should step in and say, “Hey, that’s not cool.” Third claim: promissory estoppel, which sounds like a rejected boy band name but is actually a sneaky legal backup. It means even if the contract is shaky, Tamara promised to pay, and the lender relied on that promise (by giving her the money), so she should still be on the hook. It’s like if you tell your friend you’ll pay them back for concert tickets, they buy them, and then you ghost — a court might say, “Dude, you led them on, you still owe.”

Now, what do they want? $17,758.03 — not just the principal, but the full balance after default. Is that a lot? Well, for a personal loan, $16,500 isn’t crazy — it’s less than a new car, more than a solid used one. But $17,758? That’s the cost of not paying on time. Add in court costs, attorney fees, and post-judgment interest, and this number could creep even higher if the case drags on. For context, the average American has about $22,000 in personal debt — so this isn’t a drop in the bucket. But compared to, say, a mortgage or student loans? It’s a mid-tier financial stumble. Still, for someone in Yukon, Oklahoma, where the median household income is around $70,000, that kind of debt can be a real burden — especially if the car you bought with it wasn’t even a Pagani.

Here’s our take: the most absurd thing isn’t that someone defaulted on a loan. People do that every day. It’s not even that a trust named after a luxury sports car is suing an Oklahoma woman. (Though, come on — Pagani Trust? That’s like naming your LLC “Rolls Royce Ventures” and expecting people not to laugh.) No, the real absurdity is how impersonal and convoluted modern debt has become. Tamara didn’t borrow from a local banker who knew her name. She didn’t sign paper documents. She clicked through an algorithm, got money from a New Jersey bank, and now she’s being sued by a trust with a name that sounds like a spy ring, represented by a Texas law firm, all because she missed some payments. The whole system is a Rube Goldberg machine of finance — and Tamara is just a marble rolling through it, ending up in court because the machine demands its due.

Do we know why she stopped paying? Medical emergency? Job loss? Or just poor planning? The filing doesn’t say. And that’s the thing — this case isn’t about drama, or betrayal, or even crime. It’s about a spreadsheet screaming “OVERDUE” and a law firm sending a petition. We’re not rooting for the Pagani Trust — sorry, Wall Street, we don’t do rich villains. But we’re not sure we’re rooting for Tamara either, unless she’s being crushed by circumstances beyond her control. Mostly, we’re rooting for someone — anyone — to admit that the whole system is ridiculous. That a woman in Yukon is being chased by a trust named after a car that goes 230 mph is peak 2025. And honestly? We’re here for it. We’re entertainers, not lawyers — but if this case goes to trial, we’re bringing popcorn.

Case Overview

Petition
Jurisdiction
District Court of Canadian County, Oklahoma
Relief Sought
$17,758 Monetary
Plaintiffs
Defendants
Claims
# Cause of Action Description
1 breach of contract Defendant failed to make payments as agreed
2 unjust enrichment Defendant received monies and/or benefits unjustly
3 promissory estoppel Defendant made a promise to pay, resulting in detrimental reliance

Petition Text

644 words
IN THE DISTRICT COURT OF CANADIAN COUNTY STATE OF OKLAHOMA BOAC AIF A4 INTERVAL PAGANI TRUST ) Serviced by UPGRADE INC. ) Plaintiff, ) ) vs. ) ) TAMARA CRENshaw ) Defendant. ) ) Case No. CS-2026-397 JUDGE PAUL HESSE PLAINTIFF'S ORIGINAL PETITION COMES NOW Plaintiff, BOAC AIF A4 INTERVAL PAGANI TRUST Serviced by UPGRADE INC. ("Plaintiff"), and for its causes of action against Defendant, TAMARA CRENshaw states and alleges as follows: Parties 1. Plaintiff BOAC AIF A4 INTERVAL PAGANI TRUST Serviced by UPGRADE INC. may be served with notice through its attorneys of record. 2. The Defendant, TAMARA CRENshaw (hereinafter referred to as "Defendant" or "Borrower") is an individual and former customer of Plaintiff's, residing within the venue of the above referenced court and may be served at the following address, or wherever the Defendant may be found: 2880 N YUKON PKWY YUKON OK 73099. Jurisdiction & Venue 3. This Court has general and original jurisdiction over Plaintiff's claims, including its claims for breach of promissory note, breach of contract, and unjust enrichment. Furthermore, Plaintiff has sustained damages and other losses in excess of the amount required to invoke this Court's jurisdiction. 4. Venue is proper in this county pursuant to Oklahoma law because it is: (1) where Defendant resides; (2) where the statement of account, contract, promissory note or other instrument of indebtedness originated; (3) where the Defendant is subject to personal jurisdiction; and (4) where many acts giving rise to this cause of action occurred. 12 OK Stat § 142. 5. All conditions precedent to instituting this action have occurred, been performed, were waived or have otherwise been satisfied. Factual Background 6. Upgrade, Inc. operates a technology powered online marketplace which enables consumers to apply for and obtain loans that are originated and funded by lenders through the Upgrade platform. The Defendant utilized Upgrade, Inc.’s, national online consumer loan marketplace to enter into a Borrower Agreement with Cross River Bank, a New Jersey-chartered FDIC insured bank. 7. The Defendant was issued a loan in the principal amount of $16,500.00. 8. Cross River Bank funded the Defendant's loan and Plaintiff Upgrade Inc. serviced the Defendant's loan per the Borrower Agreement. 9. On or about May 6, 2025, Defendant ceased making payments, and thus, defaulted on the obligations as stated in the contract. The remaining balance due by Defendant in the amount of $17,758.03 was charged off. Breach of Contract 10. Paragraphs 1-9 are incorporated by reference as if fully set forth herein.. 11. Defendant utilized the Plaintiff’s services to enter into a valid and enforceable contract under which money was extended to Defendant. 12. Defendant breached the contract by failing to make payments as agreed. 13. Defendant's breach caused the entire balance due to be charged off as an economic loss. Plaintiff now seeks liquidated damages in the amount of $17,758.03. Unjust Enrichment 14. Paragraphs 1 through 13 are incorporated by reference. 15. Defendant knowingly and willingly accepted and received monies and/or benefits unjustly and should make restitution for those monies and/or benefits. 16. Defendant has received an unfair benefit by the refusal to repay what is owed. Equity requires that Defendant not retain the benefit of these sums owed. Further, it would be unconscionable for Defendant to retain the monies and/or benefits obtained. 17. Plaintiff is entitled to judgment against Defendant to recover the value of the benefit conferred, interest costs and attorney fees. Promissory Estoppel 18. Plaintiff also sues under the equitable action of promissory estoppel in that Defendant made a promise to pay. Defendant's promise resulted in detrimental reliance. Prayer For Relief WHEREFORE, Plaintiff prays this Honorable Court grant judgment in favor of Plaintiff and against Defendant for the following: a. The balance due in the amount of $17,758.03; b. all court costs; c. post-judgment interest as permitted by law; d. reasonable and necessary attorney's fees; and e. such other relief plaintiff may be entitled to at law or equity. Respectfully submitted, Rutledge Law Firm, P.C. By: __________________________ W. "Will" Rutledge, OBA #36346 2603 Augusta Drive Suite #500 Houston, Texas 77057 833-856-4700 832-843-0699 facsimile [email protected] ATTORNEYS FOR PLAINTIFF
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