IN THE DISTRICT COURT OF MCCLAIN COUNTY
STATE OF OKLAHOMA
JPMORGAN CHASE BANK, N.A.,
Plaintiff,
v.
DAWN JEAN BLEVINS;
TWISTED ROO MEDIA, LLC,
Defendants.
VERIFIED PETITION
NOW COMES THE PLAINTIFF, by and through its attorneys, Bonial & Associates, P.C., and sets forth the allegations in support of its Petition as follows:
1. The Plaintiff, JPMorgan Chase Bank, N.A. is organized under the laws of the United States and conducts business in the State of Oklahoma.
2. Upon information and belief, the Defendant, Dawn Jean Blevins “Defendant (“Blevins”), is a natural person residing at 3333 Brierwood, Newcastle, OK 73065.
3. Upon information and belief, the Defendant, Twisted Roo Media, LLC “Defendant (“Twisted Roo”), is an Oklahoma limited liability company with a business address of 7394 Mcravins Way, Lexington, OK 73051.
4. That on or about March 16, 2023, the Defendants executed and delivered a Retail Installment Sale Contract - Simple Finance Charge (with Arbitration Provision), to Ferguson Buick GMC, LLC in the amount of $88,868.00 (“Agreement”). The Agreement was assigned to Plaintiff. See Exhibit “1” attached hereto for a true and correct redacted version removing personal information.
5. Pursuant to the terms of the Agreement, Defendants agreed to repay monthly installments of $1,788.21 for 72 months.
6. The Defendants are the owners of a certain motor vehicle, described as a 2023 GMC Yukon XL, VIN 1GKS2KKT9PR290030 ("Vehicle"), which, on information and belief is kept at 3333 Brierwood, Newcastle, OK 73065.
7. The Plaintiff is the current holder of the Agreement.
8. The Agreement is secured by the Vehicle.
9. The Plaintiff's security interest in the Vehicle was duly perfected and constitutes a valid lien against the Vehicle as evidenced by the Certificate of Title State of Oklahoma. See Exhibit "2" attached hereto for a true and correct redacted version removing personal information.
COUNT I: Breach of Contract
10. The Plaintiff reasserts and incorporates by reference Paragraphs 1 through 9.
11. The Defendants are in default of the Agreement by virtue of their failure to make timely payment due and owing to Plaintiff in connection with the Agreement. Despite non-payment, Defendants retain possession of the Vehicle.
12. The Defendants have breached the Agreement by failing to make payments that have become due beginning on September 30, 2024, or by failing to return possession of the Vehicle to Plaintiff.
13. As a result of Defendants' breach of the Agreement, Plaintiff is entitled to possession of the Vehicle due to its security interest in the Vehicle as shown by the Agreement and Certificate of Title State of Oklahoma.
14. Defendants continued possession of said property is wrongful because of Plaintiff’s interest therein. Defendants continue to use said property to the detriment of Plaintiff.
15. The Plaintiff has demanded payment from the Defendants or possession of the Vehicle. See Exhibit "3" attached hereto for a true and correct version of the demand letter.
16. The Defendants have failed to cure the default or reinstate the debt set forth in the Agreement, despite demand. As a result, Plaintiff has accelerated the amount due and owing under the Agreement.
17. As of November 20, 2025, the Defendants owe the Plaintiff the principal balance of $74,675.05.
COUNT II: Replevin
18. The Plaintiff reasserts and incorporates by reference Paragraphs 1 through 17.
19. The Defendants have continued to use and enjoy possession of the Vehicle despite their default on the obligations set forth in the Agreement as alleged herein.
20. To the Plaintiff’s best knowledge, information, and belief, the Vehicle is located at 3333 Brierwood, Newcastle, OK 73065, and may be in a locked garage, behind a fence or chain, behind a locked gate or door, or otherwise inaccessible to Plaintiff and its agents or contractors in the absence of the ability to force open such impediments.
21. The Defendants have failed to make payments that have become due, or to return possession of the Vehicle to Plaintiff, despite demand.
22. In the event of default, the Agreement grants Plaintiff the immediate right to repossess the Vehicle to satisfy the debt.
23. According to the J.D. Power Guide dated November 20, 2025, the Vehicle has a clean retail value of $76,925.00.
24. The Plaintiff claims return of the Vehicle or its value.
25. On information and belief there are no other known lienholders.
26. To Plaintiff’s best knowledge, information, and belief, the Vehicle was not taken in execution on any order or judgment against said Plaintiff, or for the payment of any tax, fine or amercement assessed against it, or by virtue of an order of delivery under 12 O.S. §1571 et
seq., or any other mesne or final process issued against said Plaintiff; or, if taken in execution or on any order or judgment against the Plaintiff, that is exempt by law from being so taken.
WHEREFORE, Plaintiff demands judgment in its favor and against Defendants in the amount of $74,675.05 and for immediate possession of the Vehicle, together with such other relief as this Honorable Court may deem necessary and appropriate.
1. Order that once Plaintiff takes possession of the Vehicle, Plaintiff is entitled to sell the Vehicle via public auction, and Defendants are liable for any deficiency left pursuant to the security agreement. In the event Plaintiff is unable to recover possession of the Vehicle, Plaintiff is entitled to the principal balance due and owing in the amount of $74,675.05.
2. Award such other, further, and different relief deemed just and proper.
Respectfully submitted,
BONIAL & ASSOCIATES, P.C.
/s/ Joseph H. Rogers, III
Joseph H. Rogers, III, OBA#31541
Arthur Demske, OBA#35496
14841 Dallas Parkway, Suite 350
Dallas, Texas 75254
Phone: 1-800-766-7761
Fax: 405-285-8951
Email:
[email protected]
Attorneys for Plaintiff
This communication is from a debt collector and is an attempt to collect a debt.
Any information obtained will be used for that purpose.
VERIFICATION
I, Ariana L Stevens, am a Business Analysis Spec. IV, employed by JPMorgan Chase Bank, N.A. ("Chase"), the Plaintiff in this action. I am familiar with business records maintained by Chase for the purpose of servicing automobile loans. These records (which include data compilations, electronically imaged documents, and others) are made at or near the time by, or from information provided by, persons with knowledge of the activity and transactions reflected in such records and are kept in the course of business activity conducted regularly by Chase. It is the regular practice of Chase's business to make these records. In connection with making this verification, I affirm that I have acquired personal knowledge of the matters stated herein by examining these business records. The facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information, and belief, based on my familiarity with the records maintained by JPMorgan Chase Bank, N.A. with respect to the matters that are subject of this action.
[date] Ariana L Stevens
Business Analysis Spec. IV
JPMORGAN CHASE BANK, N.A.
STATE OF ARIZONA
COUNTY OF MARICOPA
SUBSCRIBED AND SWORN TO before me this 6th day of February, 2026 by Ariana L Stevens.
MARY ELISE LIUSKA
Notary Public - Arizona
MARICOPA COUNTY
Commission # 672456
Expires August 12, 2028
RETAIL INSTALLMENT SALE CONTRACT – SIMPLE FINANCE CHARGE (WITH ARBITRATION PROVISION)
Buyer Name and Address (Including County and Zip Code)
TWISTED ROO MEDIA LLC
7364 MCRAVINS WAY
LEXINGTON OK 73051
COUNTY: MCCLAIN
Co-Buyer Name and Address (Including County and Zip Code)
DAWN JEAN BLEVINS
3333 BRIERWOOD
NEWCASTLE OK 73065
Seller-Creditor (Name and Address)
FERGUSON BUICK GMC, LLC
1015 N. INTERSTATE DRIVE
NORMAN, OK 73069
Cell:
Email:
You, the Buyer (and Co-Buyer, if any), may buy the vehicle below for cash or on credit. By signing this contract, you choose to buy the vehicle on credit under the agreements in this contract. You agree to pay the Seller - Creditor (sometimes "we" or "us" in this contract) the Amount Financed and Finance Charge in U.S. funds according to the payment schedule below. We will figure your finance charge on a daily basis. The Truth-In-Ending Disclosures below are part of this contract.
<table>
<tr>
<th>Used/Used</th>
<th>Year</th>
<th>Make and Model</th>
<th>Odometer</th>
<th>Vehicle Identification Number</th>
<th>Primary Use For Which Purchased</th>
</tr>
<tr>
<td>NEW</td>
<td>2023</td>
<td>GMC YUKON XL</td>
<td>13</td>
<td>1GKS2KKTQPR290030</td>
<td>Personal, family, or household unless otherwise indicated below<br>☑ business<br>☐ agricultural<br>☐ N/A</td>
</tr>
</table>
FEDERAL TRUTH-IN-LENDING DISCLOSURES
<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>12.89 %</td>
<td>$ 39883.12</td>
<td>$ 88888.00</td>
<td>$ 128751.12</td>
<td>$ 158751.12</td>
</tr>
</table>
Your Payment Schedule Will Be:
(e) means an estimate
<table>
<tr>
<th>Number of Payments</th>
<th>Amount of Payments</th>
<th>When Payments Are Due</th>
</tr>
<tr>
<td>72</td>
<td>$ 1788.21</td>
<td>MONTHLY beginning 04/30/2023</td>
</tr>
<tr>
<td>N/A</td>
<td>$ N/A</td>
<td>N/A</td>
</tr>
<tr>
<td colspan="3">N/A</td>
</tr>
</table>
Late Charge: If payment is not received in full within 10 days after it is due, you will pay a late charge of $ 29.00 or 5% of the part of the payment that is late, whichever is greater.
Prepayment: If you pay early, you will not have to pay a penalty.
Security Interest: You are giving a security interest in the vehicle being purchased.
Additional Information: See this contract for more information including information about nonpayment, default, any required repayment in full before the scheduled date and security interest.
Used Car Buyers Guide. The information you see on the window form for this vehicle is part of this contract. Information on the window form overrides any contrary provisions in the contract of sale.
Spanish Translation: Guía para compradores de vehículos usados. La información que ve en el formulario de la ventana para este vehículo forma parte del presente contrato. La información del formulario de la ventana deja sin efecto toda disposición en contrario contenida en el contrato de venta.
WARRANTIES SELLER DISCLAIMS
Unless the Seller makes a written warranty, or enters into a service contract within 90 days from the date of this contract, the Seller makes no warranties, express or implied, on the vehicle, and there will be no implied warranties of merchantability or of fitness for a particular purpose.
This provision does not affect any warranties covering the vehicle that the vehicle manufacturer may provide.
☐ VENDOR'S SINGLE INTEREST INSURANCE (VSI insurance): If the preceding box is checked, the Creditor requires VSI insurance for the initial term of the contract to protect the Creditor for loss or damage to the vehicle (collision, fire, theft, concealment, skip). VSI insurance is for the Creditor's sole protection. This insurance does not protect your interest in the vehicle. You may choose the insurance company through which the VSI Insurance is obtained. If you elect to purchase VSI insurance through the Creditor, the cost of this insurance is $ N/A and is also shown in Item 4B of the Itemization of Amount Financed. The coverage is for the initial term of the contract.
Agreement to Arbitrate: By signing below, you agree that, pursuant to the Arbitration Provision on page 5 of this contract, you or we may elect to resolve any disputes by neutral, binding arbitration and not by a court action. See the Arbitration Provision for additional information concerning the agreement to arbitrate.
Buyer Signs X Twisted Roo Media LLC -Tros
Co-Buyer Signs X Dawn Blevins
EXHIBIT 1
ITEMIZATION OF AMOUNT FINANCED
1 Cash Price (including $ N/A sales/excise tax) $ 110292.00 (1)
2 Total Downpayment =
Trade-in N/A
(Year) (Make) (Model)
Gross Trade-In Allowance $ N/A
Less: Pay Off Made By Seller to N/A $ N/A
Equals Net Trade In $ N/A
+ Cash $ 30000.00
+ Other N/A $ N/A
+ Other N/A $ N/A
+ Other N/A $ N/A
(if total downpayment is negative, enter "0" and see 4i below)
$ 30000.00 (2)
$ 80292.00 (3)
3 Unpaid Balance of Cash Price (1 minus 2)
4 Other Charges Including Amounts Paid to Others on Your Behalf (Seller may keep part of these amounts):
A Cost of Optional Credit Insurance Paid to Insurance Company or Companies:
Life $ N/A
Disability $ N/A $ N/A
B Vendor's Single Interest Insurance Paid to Insurance Company $ N/A
C Other Optional Insurance Paid to Insurance Company or Companies $ N/A
D Optional Gap Contract $ N/A
E Official Fees Paid to Government Agencies
to N/A for N/A $ N/A
to N/A for N/A $ N/A
to N/A for N/A $ N/A
F Government Taxes Not Included in Cash Price $ N/A
G Government License and/or Registration Fees N/A
LIEN FEE $ 10.00
H Government Certificate of Title Fees $ N/A
I Other Charges (Seller must identify who is paid and describe purpose.)
to N/A for Prior Credit or Lease Balance $ 0.00
to FERGUSON BUICK GMC, LLC for DOCUMENTARY FEE $ 599.00
to N/A for N/A $ N/A
to ENDURANCE for VEHICLE SERVICE CONTRACT $ 7987.00
to N/A for N/A $ N/A
to N/A for N/A $ N/A
to N/A for N/A $ N/A
to N/A for N/A $ N/A
to N/A for N/A $ N/A
to N/A for N/A $ N/A
to N/A for N/A $ N/A
Total Other Charges and Amounts Paid to Others on Your Behalf $ 8576.00 (4)
5 Amount Financed (3 + 4) $ 88868.00 (5)
OPTION: ☐ You pay no finance charge if the Amount Financed, item 5, is paid in full on or before _______________, Year N/A . SELLER'S INITIALS N/A
OPTIONAL GAP CONTRACT. A gap contract (debt cancellation contract) is not required to obtain credit and will not be provided unless you sign below and agree to pay the extra charge. If you choose to buy a gap contract, the charge is shown in Item 4D of the Itemization of Amount Financed. See your gap contract for details on the terms and conditions it provides. It is a part of this contract.
Term N/A Mos. N/A
I want to buy a gap contract.
Name of Gap Contract
Buyer Signs X N/A
Returned Check Charge: You agree to pay a charge of $ 25.00 if any check you give us is dishonored.
Insurance. You may buy the physical damage insurance this contract requires from anyone you choose who is acceptable to us. You may also provide the physical damage insurance through an existing policy owned or controlled by you that is acceptable to us. You are not required to buy any other insurance to obtain credit unless the box indicating Vendor's Single Interest Insurance is checked on page 1 of this contract.
If any insurance is checked below, policies or certificates from the named insurance companies will describe the terms and conditions.
Check the Insurance you want and sign below:
Optional Credit Insurance
☐ Credit Life: ☐ Buyer ☐ Co-Buyer ☐ Both
☐ Credit Disability: ☐ Buyer ☐ Co-Buyer ☐ Both
Premium:
Credit Life $ N/A
Credit Disability $ N/A
Insurance Company Name N/A
N/A
Home Office Address N/A
N/A
Credit life insurance and credit disability insurance are not required to obtain credit. Your decision to buy or not buy credit life insurance and credit disability insurance will not be a factor in the credit approval process. They will not be provided unless you sign and agree to pay the extra cost. If you choose this insurance, the cost is shown in Item 4A of the Itemization of Amount Financed. Credit life insurance is based on your original payment schedule. This insurance may not pay all you owe on this contract if you make late payments. Credit disability insurance does not cover any increase in your payment or in the number of payments. Coverage for credit life insurance and credit disability insurance ends on the original due date for the last payment unless a different term for the insurance is shown below.
Other Optional Insurance
☐ N/A N/A
Type of Insurance Term
Premium $ N/A
Insurance Company Name N/A
Home Office Address N/A
☐ N/A N/A
Type of Insurance Term
Premium $ N/A
Insurance Company Name N/A
Home Office Address N/A
Other optional insurance is not required to obtain credit. Your decision to buy or not buy other optional insurance will not be a factor in the credit approval process. It will not be provided unless you sign and agree to pay the extra cost.
I want the insurance checked above.
X N/A N/A
Buyer Signature Date
X N/A N/A
Co-Buyer Signature Date
THIS INSURANCE DOES NOT INCLUDE INSURANCE ON YOUR LIABILITY FOR BODILY INJURY OR PROPERTY DAMAGE CAUSED TO OTHERS. WITHOUT SUCH INSURANCE YOU MAY NOT OPERATE THIS VEHICLE ON PUBLIC HIGHWAYS.
OTHER IMPORTANT AGREEMENTS
FINANCE CHARGE AND PAYMENTS
a. How we will figure Finance Charge. We will figure the Finance Charge on a daily basis at the Annual Percentage Rate on the unpaid part of the Amount Financed.
b. How we will apply payments. We may apply each payment to the earned and unpaid part of the Finance Charge, to the unpaid part of the Amount Financed and to other amounts you owe under this contract in any order we choose as the law allows.
c. How late payments or early payments change what you must pay. We based the Finance Charge, Total of Payments, and Total Sale Price shown on page 1 of this contract on the assumption that you will make every payment on the day it is due. Your Finance Charge, Total of Payments, and Total Sale Price will be more if you pay late and less if you pay early. Changes may take the form of a larger or smaller final payment or, at our option, more or fewer payments of the same amount as your scheduled payment with a smaller final payment. We will send you a notice telling you about these changes before the final scheduled payment is due.
d. You may prepay. You may prepay all or part of the unpaid part of the Amount Financed at any time without penalty. If you do so, you must pay the earned and unpaid part of the Finance Charge and all other amounts due up to the date of your payment.
e. Your right to refinance a balloon payment. A balloon payment is a scheduled payment that is more than twice as large as the average of your earlier scheduled payments. If you are buying the vehicle primarily for personal, family or household use, you have the right to refinance the balloon payment when due without penalty. The terms of the refinancing will be no less favorable to you than the terms of this contract. This provision does not apply if we adjusted your payment schedule to your seasonal or irregular income.
YOUR OTHER PROMISES TO US
a. If the vehicle is damaged, destroyed, or missing. You agree to pay us all you owe under this contract even if the vehicle is damaged, destroyed, or missing.
b. Using the vehicle. You agree not to remove the vehicle from the U.S. or Canada, or to sell, rent, lease, or transfer any interest in the vehicle or this contract without our written permission. You agree not to expose the vehicle to misuse, seizure, confiscation, or involuntary transfer. If we pay any repair bills, storage bills, taxes, fines, or charges on the vehicle, you agree to repay the amount when we ask for it.
c. Security Interest.
You give us a security interest in:
• The vehicle and all parts or goods put on it;
• All money or goods received (proceeds) for the vehicle;
• All insurance, maintenance, service, or other contracts we finance for you; and
• All proceeds from insurance, maintenance, service, or other contracts we finance for you. This includes any refunds of premiums or charges from the contracts.
This secures payment of all you owe on this contract. It also secures your other agreements in this contract. You will make sure the title shows our security interest (lien) in the vehicle. You will not allow any other security interest to be placed on the title without our written permission.
d. Insurance you must have on the vehicle.
You agree to have physical damage insurance covering loss or of damage to the vehicle for the term of this contract. The insurance must cover our interest in the vehicle. You agree to name us on your insurance policy as loss payee. If you do not have this insurance, we may, if we choose, buy physical damage insurance. If we decide to buy physical damage insurance, we may either buy insurance that covers your interest and our interest in the vehicle, or buy insurance that covers only our interest. If we buy either type of insurance, we will tell you which type and the charge you must pay. The charge will be the premium for the insurance and a finance charge computed at the Annual Percentage Rate shown on page 1 of this contract. If the vehicle is lost or damaged, you agree that we may use any insurance settlement to reduce what you owe or repair the vehicle.
e. What happens to returned insurance, maintenance, service, or other contract charges. If we get a refund of insurance, maintenance, service, or other contract charges, you agree that we may subtract the refund from what you owe.
3. IF YOU PAY LATE OR BREAK YOUR OTHER PROMISES
a. You may owe late charges. You will pay a late charge on each late payment as shown on page 1 of this contract. Acceptance of a late payment does not excuse your late payment or mean that you may keep making late payments. If you pay late, we may also take the steps described below.
b. You may have to pay all you owe at once. If you break your promises (default), we may demand that you pay all you owe on this contract at once. Default means:
• You do not pay any payment on time;
• You give false, incomplete, or misleading information during credit application;
• You start a proceeding in bankruptcy or one is started against you or your property; or
• You break any agreements in this contract.
The amount you will owe will be the unpaid part of the Amount Financed plus the earned and unpaid part of the Finance Charge, any late charges, and any amounts due because you defaulted.
c. You may have to pay collection costs. If we hire an attorney who is not our salaried employee to collect what you owe, you will pay the attorney's fee and court costs the law permits. The maximum attorney's fee you will pay will be 15% of the amount you owe, unless a court awards an additional amount.
d. We may take the vehicle from you. If you default, we may take (repossess) the vehicle from you if we do so peacefully and if the law allows it. If your vehicle has an electronic tracking device (such as GPS), you agree that we may use the device to find the vehicle. If we take the vehicle, any accessories, equipment, and replacement parts will stay with the vehicle. If any personal items are in the vehicle, we may store them for you. If you do not ask for these items back, we may dispose of them as the law allows.
e. How you can get the vehicle back if we take it. If we repossess the vehicle, you may pay to get it back (redeem). We will tell you how much to pay to redeem. Your right to redeem ends when we sell the vehicle.
1. We will sell the vehicle if you do not get it back. If you do not redeem, we will sell the vehicle. We will send you a written notice of sale before selling the vehicle.
We will apply the money from the sale, less allowed expenses, to the amount you owe. Allowed expenses are expenses we pay as a direct result of taking the vehicle, holding it, preparing it for sale, and selling it. Attorney fees and court costs, if the law permits, are also allowed expenses. If any money is left (surplus), we will pay it to you unless the law requires us to pay it to someone else. If money from the sale is not enough to pay the amount you owe, you must pay the rest to us unless the law provides otherwise. If you do not pay this amount when we ask, we may charge you interest at a rate not exceeding the highest lawful rate until you pay.
g. What we may do about optional insurance, maintenance, service, or other contracts. This contract may contain charges for optional insurance, maintenance, service, or other contracts. If we demand that you pay all you owe at once or we repossess the vehicle, you agree that we may claim benefits under these contracts and cancel them to obtain refunds of unearned charges to reduce what you owe or repair the vehicle. If the vehicle is a total loss because it is confiscated, damaged, or stolen, we may claim benefits under these contracts and cancel them to obtain refunds of unearned charges to reduce what you owe.
4. SERVICING AND COLLECTION CONTACTS
In consideration of our extension of credit to you, you agree to provide us your contact information for our servicing and collection purposes. You agree that we may use this information to contact you in writing, by e-mail, or using prerecorded/artificial voice messages, text messages, and automatic telephone dialing systems, as the law allows. You also agree that we may try to contact you in these and other ways at any address or telephone number you provide us, even if the telephone number is a cell phone number or the contact results in a charge to you. You agree to allow our agents and service providers to contact you as agreed above.
You agree that you will, within a reasonable time, notify us of any change in your contact information.
5. APPLICABLE LAW
Federal law and the law of the state of Oklahoma apply to this contract.
6. NEGATIVE CREDIT REPORT NOTICE
We may report information about your account to credit bureaus. Late payments, missed payments, or other defaults on your account may be reflected in your credit report.
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.
The preceding NOTICE applies only to goods or services obtained primarily for personal, family, or household use. In all other cases, Buyer will not assert against any subsequent holder or assignee of this contract any claims or defenses the Buyer (debtor) may have against the Seller, or against the manufacturer of the vehicle or equipment obtained under this contract.
ARBITRATION PROVISION
PLEASE REVIEW - IMPORTANT - AFFECTS YOUR LEGAL RIGHTS
1. EITHER YOU OR WE MAY CHOOSE TO HAVE ANY DISPUTE BETWEEN YOU AND US DECIDED BY ARBITRATION AND NOT IN COURT OR BY JURY TRIAL.
2. IF A DISPUTE IS ARBITRATED, YOU WILL GIVE UP YOUR RIGHT TO PARTICIPATE AS A CLASS REPRESENTATIVE OR CLASS MEMBER ON ANY CLASS CLAIM YOU MAY HAVE AGAINST US INCLUDING ANY RIGHT TO CLASS ARBITRATION OR ANY CONSOLIDATION OF INDIVIDUAL ARBITRATIONS.
3. DISCOVERY AND RIGHTS TO APPEAL IN ARBITRATION ARE GENERALLY MORE LIMITED THAN IN A LAWSUIT, AND OTHER RIGHTS THAT YOU AND WE WOULD HAVE IN COURT MAY NOT BE AVAILABLE IN ARBITRATION.
Any claim or dispute, whether in contract, tort, statute or otherwise (including the interpretation and scope of this Arbitration Provision, any allegation of waiver of rights under this Arbitration Provision, and the arbitrability of the claim or dispute), between you and us or our employees, agents, successors or assigns, which arises out of or relates to your credit application, purchase or condition of this Vehicle, this contract or any resulting transaction or relationship (including any such relationship with third parties who do not sign this contract) shall, at your or our election, be resolved by neutral, binding arbitration and not by a court action. If federal law provides that a claim or dispute is not subject to binding arbitration, this Arbitration Provision shall not apply to such claim or dispute. Any claim or dispute is to be arbitrated by a single arbitrator only on an individual basis and not as a plaintiff in a collective or representative action, or a class representative or member of a class on any class claim. The arbitrator may not preside over a consolidated, representative, class, collective, injunctive, or private attorney general action. You expressly waive any right you may have to arbitrate a consolidated, representative, class, collective, injunctive, or private attorney general action. You or we may choose the American Arbitration Association (www.adr.org) or National Arbitration and Mediation (www.namadr.com) as the arbitration organization to conduct the arbitration. If you and we agree, you or we may choose a different arbitration organization. You may get a copy of the rules of an arbitration organization by contacting the organization or visiting its website. Arbitrators shall be attorneys or retired judges and shall be selected pursuant to the applicable rules. The arbitrator shall apply governing substantive law and the applicable statute of limitations. The arbitration hearing shall be conducted in the federal district in which you reside unless the Seller-Creditor is a party to the claim or dispute, in which case the hearing will be held in the federal district where this transaction was originated. We will pay the filing, administration, service, or case management fee and the arbitrator or hearing fee up to a maximum of $5,000, unless the law or the rules of the chosen arbitration organization require us to pay more. You and we will pay the filing, administration, service, or case management fee and the arbitrator or hearing fee over $5,000 in accordance with the rules and procedures of the chosen arbitration organization. The amount we pay may be reimbursed in whole or in part by decision of the arbitrator if the arbitrator finds that any of your claims is frivolous under applicable law. Each party shall be responsible for its own attorney, expert and other fees, unless awarded by the arbitrator under applicable law. If the chosen arbitration organization's rules conflict with this Arbitration Provision, then the provisions of this Arbitration Provision shall control. Any arbitration under this Arbitration Provision shall be governed by the Federal Arbitration Act (9 U.S.C. §§ 1 et seq.) and not by any state law concerning arbitration. Any award by the arbitrator shall be in writing and will be final and binding on all parties, subject to any limited right to appeal under the Federal Arbitration Act.
You and we retain the right to seek remedies in small claims court for disputes or claims within that court's jurisdiction, unless such action is transferred, removed or appealed to a different court. Neither you nor we waive the right to arbitrate any related or unrelated claims by filing any action in small claims court, or by using self-help remedies; such as repossession, or by filing an action to recover the vehicle, to recover a deficiency balance, or for individual or statutory public injunctive relief. Any court having jurisdiction may enter judgment on the arbitrator's award. This Arbitration Provision shall survive any termination, payoff or transfer of this contract. If any part of this Arbitration Provision, other than waivers of class rights, is deemed or found to be unenforceable for any reason, the remainder shall remain enforceable. You agree that you expressly waive any right you may have for a claim or dispute to be resolved on a class basis in court or in arbitration. If a court or arbitrator finds that this class arbitration waiver is unenforceable for any reason with respect to a claim or dispute in which class allegations have been made, the rest of this Arbitration Provision shall also be unenforceable.
The Annual Percentage Rate may be negotiable with the Seller. The Seller may assign this contract and retain its right to receive a part of the Finance Charge.
HOW THIS CONTRACT CAN BE CHANGED: This contract contains the entire agreement between you and us relating to this contract. Any change to this contract must be in writing and we must sign it. No oral changes are binding.
Buyer Signs X Buyer Printed Name TWISTED ROO MEDIA LLC Date 03/16/2023 Co-Buyer Prints N/A Co-Buyer Printed Name DAWN JEAN BLEVINS
If any part of this contract is not valid, all other parts stay valid. We may delay or refrain from enforcing any of our rights under this contract without losing them. For example, we may extend the time for making some payments without extending the time for making others.
See the rest of this contract for other important agreements.
NOTICE TO RETAIL BUYER: Do not sign this contract in blank. You are entitled to a copy of the contract at the time you sign. Keep it to protect your legal rights.
You agree to the terms of this contract. You confirm that before you signed this contract, we gave it to you, and you were free to take it and review it. You acknowledge that you have read all pages of this contract, including the arbitration provision above, before signing below. You confirm that you received a completely filled-in copy when you signed it.
Buyer Prints N/A Buyer Printed Name TWISTED ROO MEDIA LLC Date 03/16/2023 Co-Buyer Prints N/A Co-Buyer Printed Name DAWN JEAN BLEVINS
If the "business" use box is checked in "Primary Use for Which Purchased". Print Name N/A Title N/A
Co-Buyers and Other Owners — A co-buyer is a person who is responsible for paying the entire debt. An other owner is a person whose name is on the title to the vehicle but does not have to pay the debt. The other owner agrees to the security interest in the vehicle given to us in this contract.
Other owner signs here X N/A Address N/A Seller signs FERGUSON BUICK GMC, LLC Date 03/16/2023 By X Title F&I MGR
Seller assigns its interest in this contract to JP MORGAN CHASE BANK, N.A. (Assignee) under the terms of Seller's agreement(s) with Assignee.
Assigned with recourse ☐ Assigned without recourse ☒ Assigned with limited recourse
Seller FERGUSON BUICK GMC, LLC By X Title F&I MGR
CERTIFICATE OF TITLE
STATE OF OKLAHOMA
VEHICLE IDENTIFICATION NUMBER 1GKS2KKT9PR290030
YEAR 2023
MAKE GMC
BODY TYPE UT
MODEL YUKON XL
AGENT NO M4410
COLOR Silver
APPLICATION DATE 28-Jul-2023
TITLE NO
DATE 1st SOLD 05-Apr-2023
ODOMETER 13 Actual
DATE ISSUED 31-Jul-2023
TYPE OF TITLE Original
MAILING ADDRESS
JP MORGAN CHASE BANK, NA
PO BOX 901098
FORT WORTH TX 76101-2098
THIS VEHICLE IS SUBJECT TO THE FOLLOWING LIEN(S)
3/16/2023
JP MORGAN CHASE BANK, NA
NAME AND ADDRESS OF THE VEHICLE OWNER
TWISTED ROO MEDIA LLC And/or
DAWN JEAN BLEVINS
7394 MCRAVINS WAY
LEXINGTON OK 73051-1049
It is hereby certified that according to the records of the Oklahoma Tax Commission, the person named herein is the owner of the vehicle described (above which is subject to a lien(s)) as shown; however, the vehicle may be subject to other liens or security interests.
CONTROL NO.
(This is not a title number)
ASSIGNMENT OF TITLE BY REGISTERED OWNER
(IF Dealer, List License # Here ________)
If REGISTERED OWNER (SELLER) IS A LICENSED DEALER PLACE OKLAHOMA MOTOR VEHICLE TAX STAMP HERE
We hereby assign and warrant ownership of the vehicle described on this certificate to the following subject only to the liens or encumbrances if any property noted on this certificate:
Purchaser(s) Name (Type or Print) ____________________________
Purchaser(s) Complete Address ____________________________________________________________
Actual Purchase Price of Vehicle ___________
I certify to the best of my knowledge that the ODOMETER READING reflected on the vehicle's odometer and listed below is the ACTUAL MILEAGE of the vehicle UNLESS one of the accompanying statements is checked
[ ] [ ] [ ] [ ] [ ] [ ] [ ] (NO TENTHS) [ ] 1 The odometer has exceeded its mechanical limits
[ ] [ ] [ ] [ ] [ ] [ ] [ ] [ ] [ ] 2 The odometer reading is NOT the actual mileage Warning—Odometer Discrepancy
Signature of Seller(s) ____________________ Printed Name of Seller(s) ____________________
Subscribed and Sworn to Before me this _____ Day of _____ 20_____
Notary Public ___________________________ Commission Expiration _______________________
Notorization required only of seller's signature(s) Affix notary seal/stamp to the right
Signature of Buyer(s) ____________________ Printed Name of Buyer(s) ____________________
OKLAHOMA TAX COMMISSION / MOTOR VEHICLE DIVISION
NOTICE OF TRANSFER
(SUBMISSION OF THIS FORM IS OPTIONAL. REFER TO INSTRUCTIONS ON REVERSE)
VEHICLE IDENTIFICATION NUMBER 1GKS2KKT9PR290030
TITLE NUMBER ________
BUYER'S NAME (Printed) ________________________________________________________________
BUYER'S ADDRESS/CITY/STATE/ZIP _______________________________________________________
SELLER'S NAME (Printed) ________________________________________________________________
SELLER'S ADDRESS/CITY/STATE/ZIP _______________________________________________________
SIGNATURE OF SELLER __________________________________ DATE OF SALE ______________________
CONTROL No (Not a Title Number) ____________________ VEHICLE LICENSE PLATE NUMBER __________________
NOTICE OF TRANSFER FILING FEE $10.00
Ownership Transfer Information
Federal and state law requires that the odometer reading and its accuracy be disclosed upon every transfer of ownership of a motor vehicle unless otherwise exempted Failure to complete or providing false information may result in fines and/or imprisonment.
The presence of any lien or encumbrance on this vehicle is to be so noted where indicated on the bottom of this page
State law requires a transfer of ownership to be completed within thirty (30) days of acquiring ownership Failure to do so subjects the owner or possessor to the assessment of delinquent penalties, as provided by law
ALL SELLERS SIGNATURES ON THIS DOCUMENT MUST BE SWORN TO BEFORE A NOTARY PUBLIC
REASSIGNMENT OF TITLE BY LICENSED DEALER NUMBER _______________________
PLACE OKLAHOMA MOTOR VEHICLE TAX STAMP HERE
I/we hereby assign and warrant ownership of the vehicle described on this certificate to the following subject only to the liens or encumbrances, if any properly noted on this certificate
Purchaser(s) Name (Type or Prnt)
Purchaser(s) Complete Address
Actual Purchase Price of Vehicle, Excluding Credit for Any Trade-in.
I certify to the best of my knowledge that the ODOMETER READING reflected on the vehicle's odometer and listed below is the ACTUAL MILEAGE of the vehicle UNLESS one of the accompanying statements is checked
[ ] [ ] [ ] [ ] [ ] [ ] (NO TENTHS)
1 The odometer has exceeded its mechanical limits
2 The odometer reading is NOT the actual mileage Warning — Odometer Discrepancy
Signature of Seller(s) ____________________________________________ Printed Name of Seller(s) __________________________
Subscribed and Sworn to Before me this __________________ Day of________________________ 20________
Notary Public __________________________ Commission Expiration __________________________
Notarization required only of seller's signature(s) Affix notary seal/stamp to the right
Signature of Buyer(s) ____________________________________________ Printed Name of Buyer(s) ________________
REASSIGNMENT OF TITLE BY LICENSED DEALER NUMBER _______________________
PLACE OKLAHOMA MOTOR VEHICLE TAX STAMP HERE
I/we hereby assign and warrant ownership of the vehicle described on this certificate to the following subject only to the liens or encumbrances if any properly noted on this certificate
Purchaser(s) Name (Type or Prnt)
Purchaser(s) Complete Address
Actual Purchase Price of Vehicle, Excluding Credit for Any Trade-in.
I certify to the best of my knowledge that the ODOMETER READING reflected on the vehicle's odometer and listed below is the ACTUAL MILEAGE of the vehicle UNLESS one of the accompanying statements is checked
[ ] [ ] [ ] [ ] [ ] [ ] (NO TENTHS)
1 The odometer has exceeded its mechanical limits
2 The odometer reading is NOT the actual mileage Warning — Odometer Discrepancy
Signature of Seller(s) ____________________________________________ Printed Name of Seller(s) __________________________
Subscribed and Sworn to Before me this __________________ Day of________________________ 20________
Notary Public __________________________ Commission Expiration __________________________
Notarization required only of seller's signature(s) Affix notary seal/stamp to the right
Signature of Buyer(s) ____________________________________________ Printed Name of Buyer(s) ________________
LIENHOLDER INFORMATION
Any active lien or encumbrance against this vehicle is to be described below Any active lien reflected on the face of this certificate will carry forward to any subsequent Oklahoma title issued unless a proper release of lien has been executed
LIENHOLDER NAME ____________________________________________ DATE OF LIEN ________________
LIENHOLDER ADDRESS / CITY / STATE / ZIP ______________________________________________________
NOTICE OF TRANSFER INSTRUCTIONS
THIS NOTICE OF TRANSFER IS AN OPTIONAL FORM THAT SERVES ONLY AS A NOTIFICATION TO THE OKLAHOMA TAX COMMISSION OF THE ASSIGNMENT OF OWNERSHIP OF THE DESCRIBED VEHICLE. IT IS INTENDED TO RECORD THAT ASSIGNMENT IN OTC COMPUTER FILES AND TO PREVENT CERTAIN TRANSACTIONS FROM BEING PROCESSED UNTIL A TRANSFER OF TITLE IS COMPLETED BY THE ASSIGNEE ALL REQUESTED INFORMATION MUST BE PROVIDED IN ORDER FOR THIS NOTICE TO BE FILED
TO RECORD THIS NOTICE OF TRANSFER DETACH FROM TITLE CERTIFICATE AND DELIVER OR MAIL COMPLETED FORM AND FILING FEE TO ANY OKLAHOMA TAG AGENCY. COMPLETION AND FILING OF THIS FORM DOES NOT CONSTITUTE A TRANSFER OF TITLE
NOTICE TO BUYER(S)
OKLAHOMA LAW REQUIRES TRANSFER OF TITLE WITHIN THIRTY (30) DAYS OF THE OWNERSHIP ASSIGNMENT DATE TRANSFER MAY BE COMPLETED BY PRESENTING THE ASSIGNED CERTIFICATE OF TITLE AND PROPER REMITTANCE TO THE OKLAHOMA TAX COMMISSION OR ANY OKLAHOMA MOTOR LICENSE AGENT (TAG AGENT). A LISTING OF TAG AGENCY LOCATIONS AND CONTACT INFORMATION IS AVAILABLE IN THE MOTOR VEHICLE INFORMATION SECTION OF THE OKLAHOMA TAX COMMISSION WEB SITE AT WWW.TAX.OK.GOV
FAILURE BY THE NEW OWNER(S) TO APPLY FOR A TRANSFER OF TITLE WITHIN THIRTY (30) DAYS WILL RESULT IN DELINQUENT PENALTIES
NOTICE OF TRANSFER FILING FEE $10.00
CHASE Auto
JPMorgan Chase Bank, N.A.
PO Box 182055
Columbus, OH 43218-2055
Questions?
1-800-388-4223
We accept operator relay calls
02316 ICF 662 040 31124 NNNNNNNNNNN CM2206
TWISTED ROO MEDIA LLC
7394 MCRAVINS WAY
LEXINGTON OK 73051
November 06, 2024
Account Number: Ending in 5708
Vehicle: 2023 Gmc Yukon XI 1GKS2KKT9PR290030
Contract Date: March 16, 2023
Important: You are in default under the terms of your contract but have a right to cure
Dear Twisted Roo Media Llc:
You are in default under the terms of your contract for the above-referenced account. You have the right to cure this default by paying the Total Due of $3,876.95 by 11/18/2024. If you fail to cure, we may repossess the vehicle where allowed under applicable federal and state law1 and/or accelerate the debt. This means the entire outstanding balance would become immediately due in full.
Please make your payment by 11/18/2024
If you pay the Total Due on time, you can continue making payments as if you had not defaulted. If you cannot pay the Total Due on time, please contact us to discuss options.
This is how we calculated the amount you owe:
<table>
<tr>
<th>Past due payments</th>
<td>$3,533.02</td>
</tr>
<tr>
<th>Unpaid late charges</th>
<td>$343.93</td>
</tr>
<tr>
<th>Other Charges<sup>2</sup></th>
<td>$0.00</td>
</tr>
<tr>
<th>Total Due</th>
<td>$3,876.95</td>
</tr>
</table>
You can still get the vehicle back if we repossess it
If we repossess the vehicle, please contact us to discuss options to get back the vehicle.
1 Active-duty and recently discharged Servicemembers: Your rights under the Servicemembers Civil Relief Act (SCRA), similar state laws, and/or Chase Policy will guide what happens with your account. If you are eligible, Chase will not repossess the vehicle during your active service and for a period of 180 days thereafter without appropriate authorization or your written consent. To determine if you are eligible and learn more about any benefits you or your dependents may be entitled to under the SCRA, please contact us at 1-877-469-0110.
2 Other charges may include expenses associated with a prior repossession that remain unpaid.
If you have questions, please call us at 1-800-388-4223. We're here Monday through Friday from 7:30 AM to 11:00 PM and Saturday from 8:00 AM to 8:00 PM ET. You can also write us at the following correspondence address:
Chase Auto
700 Kansas Lane
Mail Code LA4-4025
Monroe, LA 71203
Here's how you can make your payment
• Call us at 1-800-388-4223 if you would like to arrange a payment by phone.
• Make a payment at any full-service Chase branch, if one is available near you.
• You can also send a payment from any Western Union or MoneyGram location. Western Union and MoneyGram may require additional fees.
• Western Union: Use the City Code Chaseauto NY payable to Chase and your account number when sending payment.
• MoneyGram: Use the code 3852 payable to Chase and your account number when sending payment.
• Write your account number on your check or money order and mail it to the following payment address:
Chase Auto
P.O. Box 78067
Phoenix, AZ 85062
Sincerely,
JPMorgan Chase Bank, N.A.
This is an attempt to collect a debt and any information obtained will be used for that purpose.
Esta carta contiene información importante de la cuenta.
Si tiene alguna pregunta, por favor llame al 1-800-388-4223.
CHASE Auto
JPMorgan Chase Bank, N.A.
PO Box 182055
Columbus, OH 43218-2055
Questions?
1-800-388-4223
We accept operator relay calls
02319 ICF 662 040 31124 NNNNNNNNNNN CM2206
DAWN J BLEVINS
3333 BRIERWOOD
NEWCASTLE OK 73065
Account Number: Ending in 5708
Vehicle: 2023 Gmc Yukon XI 1GKS2KKT9PR290030
Contract Date: March 16, 2023
November 06, 2024
Important: You are in default under the terms of your contract but have a right to cure
Dear Dawn J Blevins:
You are in default under the terms of your contract for the above-referenced account. You have the right to cure this default by paying the Total Due of $3,876.95 by 11/18/2024. If you fail to cure, we may repossess the vehicle where allowed under applicable federal and state law¹ and/or accelerate the debt. This means the entire outstanding balance would become immediately due in full.
Please make your payment by 11/18/2024
If you pay the Total Due on time, you can continue making payments as if you had not defaulted. If you cannot pay the Total Due on time, please contact us to discuss options.
This is how we calculated the amount you owe:
<table>
<tr>
<th>Past due payments</th>
<td>$3,533.02</td>
</tr>
<tr>
<th>Unpaid late charges</th>
<td>$343.93</td>
</tr>
<tr>
<th>Other Charges²</th>
<td>$0.00</td>
</tr>
<tr>
<th>Total Due</th>
<td>$3,876.95</td>
</tr>
</table>
You can still get the vehicle back if we repossess it
If we repossess the vehicle, please contact us to discuss options to get back the vehicle.
¹ Active-duty and recently discharged Servicemembers: Your rights under the Servicemembers Civil Relief Act (SCRA), similar state laws, and/or Chase Policy will guide what happens with your account. If you are eligible, Chase will not repossess the vehicle during your active service and for a period of 180 days thereafter without appropriate authorization or your written consent. To determine if you are eligible and learn more about any benefits you or your dependents may be entitled to under the SCRA, please contact us at 1-877-469-0110.
² Other charges may include expenses associated with a prior repossession that remain unpaid.
If you have questions, please call us at 1-800-388-4223. We're here Monday through Friday from 7:30 AM to 11:00 PM and Saturday from 8:00 AM to 8:00 PM ET. You can also write us at the following correspondence address:
Chase Auto
700 Kansas Lane
Mail Code LA4-4025
Monroe, LA 71203
Here's how you can make your payment
• Call us at 1-800-388-4223 if you would like to arrange a payment by phone.
• Make a payment at any full-service Chase branch, if one is available near you.
• You can also send a payment from any Western Union or MoneyGram location. Western Union and MoneyGram may require additional fees.
• Western Union: Use the City Code Chaseauto NY payable to Chase and your account number when sending payment.
• MoneyGram: Use the code 3852 payable to Chase and your account number when sending payment.
• Write your account number on your check or money order and mail it to the following payment address:
Chase Auto
P.O. Box 78067
Phoenix, AZ 85062
Sincerely,
JPMorgan Chase Bank, N.A.
This is an attempt to collect a debt and any information obtained will be used for that purpose.
Esta carta contiene información importante de la cuenta.
Si tiene alguna pregunta, por favor llame al 1-800-388-4223.