Complaint,Petition: GFS II V GVON JOHNSON ET AL (E-CASE)

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                                Electronically Filed - ST LOUIS COUNTY - April 17, 2024 - 07:18 AM
                                                                                  24SL-AC10993

                       IN THE CIRCUIT COURT OF SAINT LOUIS COUNTY
                                   ASSOCIATE DIVISION
                                    STATE OF MISSOURI

 GFS II D/B/A GATEWAY FINANCIAL                                   )
 SOLUTIONS                                                        )
                                                                  )
                                                                  )       Case NO:
                                                                  )
                                                                  )
                                                                  )       Division: 44W
          Plaintiff,                                              )
                                                                  )
    v.                                                            )
                                                                  )
 GVON JOHNSON AND TIARA JOHNSON                                   )
 Serve GVON JOHNSON
 at: 606 BELMONT PL
 FERGUSON, MO 63136

 And

 Serve TIARA JOHNSON
 at: 31829 UTICA ROAD
 FRASER, MI 48026
         Defendants.

                                              PETITION

         COMES NOW, Plaintiff, GFS II D/B/A GATEWAY FINANCIAL SOLUTIONS, by and
through counsel, and for its Petition states as follows:
         1.      GFS II D/B/A GATEWAY FINANCIAL SOLUTIONS (herein after “Plaintiff”)
is a foreign corporation registered to do business in the state of Missouri.
         2.      Gvon Johnson And Tiara Johnson (hereinafter “Defendant(s)”) is/are resident(s)
of the County of Saint Louis, State of Missouri.
         3.      Defendant(s) is/are not actively enlisted in the United States Military.
         4.      That on December 13, 2021, Defendant(s) executed a contract with an automotive
dealership (“Contract”), a copy of which is attached hereto and incorporated herein.
         5.      Pursuant to the Contract, all the automotive dealership’s rights and obligations
under the contract were assigned to Plaintiff.
         6.      Plaintiff fulfilled all of its obligations under the Contract.
                                                                                                       Electronically Filed - ST LOUIS COUNTY - April 17, 2024 - 07:18 AM
        7.     The Defendant(s) breached the contract by failing to make all payments pursuant
to the Contract.
        8.     Plaintiff sent Defendant(s) notice(s) of right to cure, notice to sell, and/or notice
of deficiency, which are attached hereto and herein incorporated.
        9.     All acts by Plaintiff in regard to Contract were conducted in a commercially
reasonable matter.
        10.    Plaintiff is damaged in the amount of all outstanding payments owed to it by
Defendant(s) pursuant to the contract (“Balance”).
        11.    As of the date of this Petition, Defendant(s) owe(s) Plaintiff $8,642.80 plus
interest.
        12.    Pursuant to the Contract, Plaintiff is entitled to reasonable attorney’s fees.
        13.    Despite Plaintiff’s demand, Defendant(s) failed and refused to pay.
        WHEREFORE, Plaintiff respectfully requests a judgment in favor of Plaintiff and against
Defendant(s) in the principal sum of $8,642.80 together with interest, reasonable attorney’s fees
pursuant to Contract, costs of Court and for all other relief that this Court deems just and proper.
                                                   Respectfully Submitted,
                                                   GFS II D/B/A GATEWAY
                                                   FINANCIAL SOLUTIONS

                                                   By: /s/ Dennis J. Barton III
                                                   Dennis J. Barton III, #55176
                                                   The Barton Law Group, LLC
                                                   17600 Chesterfield Airport Rd., Ste. 201
                                                   Chesterfield, MO 63005
                                                   Ph: 636-778-9520
                                                   Fax: (636) 216-6004
                                                   info@bartonlawllc.com
                                                   Our File #: 55294
                                                   Account: 901-101-2029129-0001