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OKLAHOMA COUNTY • CJ-2026-1302

Jefferson Capital Systems LLC v. Paul Morgan, and Timothy Morgan

Filed: Sep 9, 2025
Type: CJ

What's This Case About?

Let’s cut straight to the most gloriously bizarre part of this case: a woman named Vanessa Janssen, who we know only through a notarized statement from Minnesota, is the star witness in a debt collection lawsuit against two men in Oklahoma—and she’s not a detective, a cop, or even a customer service rep who once spoke to them on the phone. No, she’s the “Custodian of Records” for a company that bought their debt, and now her words, signed in front of a notary in Benton County, Minnesota (population: ~40,000, and suddenly the most legally consequential county in this saga), are being used to try to extract nearly $15,000 from Paul and Timothy Morgan. That’s right—this entire case hinges on a document signed by someone who has never met the defendants, likely never set foot in Oklahoma, and whose only connection to the Morgans is that she works for the company that bought their old car loan from someone else. If that doesn’t sound like a Black Mirror episode about capitalism gone rogue, we don’t know what does.

So who are these people? On one side, we’ve got Paul and Timothy Morgan—names that sound like a folksy folk duo or maybe a pair of retired electricians from Tulsa. They’re the defendants, meaning they’re the ones being sued. According to the filing, they once had a loan with Santander Consumer USA—probably to buy a car, given the mention of “collateral” in the petition. That’s normal. People finance cars. Things go sideways. Payments stop. That part’s not wild. What’s wild is what happens next: Santander decided they weren’t getting paid, so they sold the debt—like a used guitar on Craigslist, but for financial misery—to Jefferson Capital Systems LLC. This is also normal, by the way. Debt buying is a whole industry. There are companies out there whose entire business model is scooping up defaulted loans for pennies on the dollar and then trying to collect the full amount. It’s like being a vulture, but with W-2s. Jefferson Capital is one of those vultures. Or, as they prefer to be called: “a leading acquirer of consumer receivables.” Sure, Jan.

Now, here’s where it gets weird. Jefferson Capital didn’t just say, “Hey, the Morgans owe us money.” They didn’t have a contract signed by the Morgans with them. They didn’t have a single email, text, or voicemail. Instead, they sent in Vanessa Janssen—the Custodian of Records, a title that sounds like it belongs in a fantasy novel about archivists who guard cursed ledgers. Vanessa, from her presumably quiet life in Minnesota, swears under oath that she has “personal knowledge” of the Morgans’ debt. Not because she talked to them. Not because she reviewed call logs or payment histories herself. No—because the records say so, and she’s the person who’s allowed to say the records say so. She declares that the Morgans opened an account on June 8, 2021, stopped paying on October 24, 2022, and now owe $14,446.26. She also helpfully notes that Jefferson Capital bought this debt, so now it’s theirs to collect. All of this is typed up, printed, signed, and notarized by Carly E. Briggs, Notary Public, whose commission expires January 31, 2029 (mark your calendars). And that—that—is the evidence in this case. A single affidavit, signed in Minnesota, about a loan taken out in Oklahoma, now being used to sue two men in Oklahoma County court. There’s no trial. No testimony. Just paperwork. And a notary stamp. Honestly, if you wanted to design a system that feels like a bureaucratic ghost story, you couldn’t do much better.

So why are they in court? Because Jefferson Capital wants its money. Simple as that. The legal claim here is “indebtedness”—a fancy way of saying, “These people owe us cash, and we want a judge to force them to pay.” In plain English: Jefferson Capital is asking the court to issue a judgment saying, “Yes, the Morgans owe $14,446.26,” based entirely on the affidavit from Vanessa. If the judge agrees—and in these kinds of cases, they often do, unless someone fights back—the Morgans could have their wages garnished, their bank accounts frozen, or their credit torched even further. The legal mechanism is straightforward: file the petition, attach the affidavit, and wait. No need for witnesses. No need for the plaintiff to even show up. It’s all done by paperwork. And that’s the problem. Because while this process is legal, it feels off. It feels like someone is being sued by a spreadsheet with a notary stamp slapped on it. And again—Vanessa Janssen has never met the Morgans. She didn’t process their loan. She didn’t review their credit application. She’s not saying they defaulted because she saw the missed payments herself. She’s saying it because the records indicate it. And she’s allowed to say that because… well, because the law says someone in her position can.

Now, what do they want? $14,446.26. That’s the number. Is that a lot? For a car loan balance, maybe not—especially if it’s a newer vehicle. But here’s the thing: Santander charged off the loan. That means they gave up on collecting it and wrote it off as a loss. Then they sold it to Jefferson Capital, probably for way less than $14k—maybe a few thousand bucks, tops. So Jefferson Capital is now trying to collect almost $15,000 on a debt they likely paid peanuts for. If they win, it’s a massive markup. And they’re also asking for interest, court costs, and attorney’s fees—meaning the final amount the Morgans might owe could be even higher. All of this over a debt that the original lender already declared a loss on. It’s like if a restaurant threw out spoiled milk, a scavenger took it, repackaged it, and then sued the dairy farm for the full retail price.

Our take? Look, we’re not saying people shouldn’t pay their debts. If the Morgans took out a loan and drove off in a car, yeah, they should pay for it. But this case feels less like justice and more like financial alchemy—turning defaulted debt into court-enforceable judgments with the power of a notarized affidavit and a well-placed notary stamp. The most absurd part? That a woman in Minnesota, who has no personal connection to the defendants, can single-handedly trigger a lawsuit in Oklahoma just by swearing that the records “say so.” That’s not a trial. That’s not even cross-examination. That’s paperwork warfare. And while we’re entertainers, not lawyers, we can’t help but wonder: what if Vanessa Janssen had misspelled a name? What if the notary’s commission had expired a week earlier? Would the whole case collapse like a house of legal cards? Probably. And that’s the real story here—not whether the Morgans owe money, but how easily someone’s financial fate can hinge on a single document signed in a county that sounds like it hosts annual lutefisk festivals.

We’re rooting for due process. We’re rooting for a system where someone can actually challenge the debt, see the original contract, ask how the amount was calculated, and make sure Vanessa Janssen isn’t just a name on a page. Because right now, it feels like the Morgans aren’t being sued by a company—they’re being sued by a notarized ghost. And if that’s how debt collection works in 2025, we may need to start notarizing our excuses.

Case Overview

$14,446 Demand Petition
Jurisdiction
District Court, Oklahoma
Relief Sought
$14,446 Monetary
Plaintiffs
Defendants
Claims
# Cause of Action Description
1 Debt Collection Plaintiff seeks to collect debt from Defendants

Petition Text

631 words
25-47046-0 YL2 010 IN THE DISTRICT COURT OF OKLAHOMA COUNTY STATE OF OKLAHOMA JEFFERSON CAPITAL SYSTEMS LLC, ) ) ) ) ) ) Plaintiff, ) vs. ) PAUL MORGAN, and TIMOTHY MORGAN, Defendants. PETITION FOR INDEBTEDNESS COMES NOW the Plaintiff, by and through its undersigned attorneys who hereby enter their appearance herein, and for its cause of action against the defendant alleges and states as follows: 1. Defendants executed a contract with SANTANDER CONSUMER USA INC relating to the purchase of collateral with an account number of XXXXXXXXXXXXXXXXX1000. The contract granted a security interest in the collateral. Defendants defaulted on the obligations required under the contract. After all due credits were applied to the indebtedness owed by the defendants, there remained a balance due. 2. The indebtedness arising therefrom has been duly assigned to JEFFERSON CAPITAL SYSTEMS LLC, Plaintiff herein. 3. Defendants remain indebted to the Plaintiff in the amount of $14,446.26. An Affidavit of Account and/or contract is attached hereto and incorporated by reference. WHEREFORE, Plaintiff prays for Judgment against Defendants in the sum of $14,446.26, with interest at the statutory rate from the date of judgment, all court costs and a reasonable attorney's fee, and for such other and further relief as to this Court may deem equitable, just and proper. William L. Nixon, Jr., #012804 Harley L. Homjak, #019736 Jennifer A. Gani, #021876 Daniela Westfahl, #36242 Mariah S. Ellicott, #36309 Benjamin F. Brackett, #36580 LOVE, BEAL & NIXON, P.C. Attorney for Plaintiff P.O. Box 32738 Oklahoma City, OK 73123 Telephone: 405-720-0565 E-Mail: [email protected] Affidavit of Account STATE OF MINNESOTA COUNTY OF BENTON Before me, the undersigned authority, personally appeared the individual whose name is subscribed below, and who, being by me duly sworn, deposed as follows: 1. "My name is Vanessa Janssen. I am of sound mind, over the age of eighteen (18), have never been convicted of a felony or crime involving moral turpitude, and am capable of making this affidavit. I have personal knowledge of the facts herein stated as more fully set forth below." 2. "I am an Authorized Representative of Jefferson Capital Systems, LLC and in that capacity act as a Custodian of Records. These records are kept in the ordinary course of business. This affidavit pertains to the collection of a SANTANDER CONSUMER USA account number XXX1000, (the "Account") owed by PAUL MORGAN TIMOTHY MORGAN the "Defendant(s)." 3. "Jefferson Capital Systems, LLC has acquired the Account pursuant to an assignment and is the owner and beneficiary of all rights, title and interest with regard to the Account, including the outstanding balance of the Account and any accrued interest thereon. The information transmitted to Jefferson Capital Systems, LLC in connection with its acquisition of the Account specifically described: (1) the obligation of the Defendant with regard to the Account, (2) the open date of the Account, (3) the charge-off balance of the Account after all payments, credits and offsets had been applied, (4) the applicable rate at which interest continues to accrue on the Account, and (5) other usage and identification information related to both the Defendant and to the Account. My testimony herein is based upon that information." 4. "On or about 06/08/2021, the Defendant made application to open the Account. Thereafter, the Defendant utilized the Account, or the proceeds thereof, and became obligated to repay the Account pursuant to its terms." 5. "The Defendant did not repay the Account and ceased making payments on the Account. The last payment date was 10/24/2022." 6. "The Account was ultimately closed and charged-off, at which time there remained a balance due and owing on the Account that the Defendant has not paid." 7. "As of 08/18/2025, the reference date of this affidavit, the amount due and owing on the Account, after all just and lawful offsets, payments, and credits had been allowed, is $14,446.26." Vanessa Janssen Custodian of Records SUBSCRIBED AND SWORN before me on SEP 09 2025. CARLY E BRIGGS NOTARY PUBLIC - MINNESOTA My Comm. Exp. Jan. 31, 2029
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