On January 03, 2024 a
Complaint,Petition
was filed
in the District Court of Oklahoma County.
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CS:arnt4- 3
OMe
*1057 mun IN THE DISTRICT COURT OF OKLAHOMA COUNTY
the
STATE OF OKLAHOMA
AUTO ADVANTAGE FINANCE, LLC
vs.
Plaintiff,
No.
W-2024-24
ASHLEY NICOLE MARSHALL and
CHARLES RUSSELL MARSHALL II
CT COURT
FILED IN DISTRICO’
OKLAHOMA
Defendants.
JAN-3 2024
Cc N
COURT CLERK
107 ——______—
PETITION
COMES NOW the plaintiff, by and through its undersigned attorneys, and states as follows:
Express Credit Auto and the defendants executed a contract on May 18, 2022 whereby
the defendants purchased a 2015 CHRYSLER TOWN & COUNTRY ("motor vehicle").
The defendants have defaulted in the obligations required under the contract.
The motor vehicle was recovered and sold. After the proceeds of the sale were applied
to the indebtedness owed by the defendants, there remains a deficiency balance owed
under the contract.
The defendants are indebted to plaintiff, as assignee, in the principal amount of
$9,870.05, with interest at the contractual rate of 19.9785 % per annum from May 09,
2023 through December 05, 2023 in the amount of $1,134.51.
WHEREFORE, Plaintiff prays for judgment against the defendants as follows:
The principal amount of $9,870.05;
Prejudgment and post judgment interest at the co actual rate (12 O.S. § 727.1);
/.
All costs of this action (12 O.S. § 928);
A reasonable attorney fee (12 0.S. § 936
Such other relief to which plaintiff may bs of
Hu
4X3 ge (O! # 20487)
Dani L. Schi inzing (OBA# 32113)
Emily R. Remmert (OBA# 22110)
Sean A. Nelson (OBA# 30194)
Robinson, Hoover & Fudge, PLLC
P.O.Box 1748
OKLAHOMA CITY, OK 73101
(405) 232-6464 | (833) 342-0001 Toll Free
lawmail@rhfok.com | (405) 232-6363 fax
Attorney for Plaintiff
***** ATTORNEY'S LIEN CLAIMED* ****
0100-23-3664
Document Filed Date
January 03, 2024
Case Filing Date
January 03, 2024
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CS:arnt4- 3 OMe *1057 mun IN THE DISTRICT COURT OF OKLAHOMA COUNTY the STATE OF OKLAHOMA AUTO ADVANTAGE FINANCE, LLC vs. Plaintiff, No. W-2024-24 ASHLEY NICOLE MARSHALL and CHARLES RUSSELL MARSHALL II CT COURT FILED IN DISTRICO’ OKLAHOMA Defendants. JAN-3 2024 Cc N COURT CLERK 107 ——______— PETITION COMES NOW the plaintiff, by and through its undersigned attorneys, and states as follows: Express Credit Auto and the defendants executed a contract on May 18, 2022 whereby the defendants purchased a 2015 CHRYSLER TOWN & COUNTRY ("motor vehicle"). The defendants have defaulted in the obligations required under the contract. The motor vehicle was recovered and sold. After the proceeds of the sale were applied to the indebtedness owed by the defendants, there remains a deficiency balance owed under the contract. The defendants are indebted to plaintiff, as assignee, in the principal amount of $9,870.05, with interest at the contractual rate of 19.9785 % per annum from May 09, 2023 through December 05, 2023 in the amount of $1,134.51. WHEREFORE, Plaintiff prays for judgment against the defendants as follows: The principal amount of $9,870.05; Prejudgment and post judgment interest at the co actual rate (12 O.S. § 727.1); /. All costs of this action (12 O.S. § 928); A reasonable attorney fee (12 0.S. § 936 Such other relief to which plaintiff may bs of Hu 4X3 ge (O! # 20487) Dani L. Schi inzing (OBA# 32113) Emily R. Remmert (OBA# 22110) Sean A. Nelson (OBA# 30194) Robinson, Hoover & Fudge, PLLC P.O.Box 1748 OKLAHOMA CITY, OK 73101 (405) 232-6464 | (833) 342-0001 Toll Free lawmail@rhfok.com | (405) 232-6363 fax Attorney for Plaintiff ***** ATTORNEY'S LIEN CLAIMED* **** 0100-23-3664