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TULSA COUNTY • CJ-2026-1102

Euler Hermes North America Insurance Company v. Dynasty Marble & Granite, LLC

Filed: Mar 10, 2026
Type: CJ

What's This Case About?

Let’s get one thing straight: this isn’t just a marble and granite company that didn’t pay its bills. No, no. This is a full-blown corporate game of musical chairs with debt, where an insurance company swoops in like a caped financial avenger, buys someone else’s unpaid invoices, and then sues for $62,786.06 like it’s their birthright. And honestly? It’s glorious.

Picture this: Dynasty Marble & Granite, LLC, a modest operation based in Jenks, Oklahoma—yes, Jenks, the city so nice they named it once—has a habit of ordering high-end stone materials. Countertops, slabs, the works. The kind of stuff that makes your kitchen look like it belongs in a Southern Living spread. Their supplier? Pacific Shore Holding, Inc., a Texas-based distributor that’s probably got more square footage of polished quartz in its warehouse than most people have in their entire lives. Business as usual: invoices fly, materials ship, deadlines loom. But somewhere around late 2023, the payments stop. Not all at once, but like a slow kitchen sink drip—first a few overdue invoices, then more, then way more. By February 2024, the unpaid balance hits a cool $62,786.06. That’s not chump change, folks. That’s a down payment on a Tesla, or a full kitchen remodel… or, ironically, a lot of marble.

But here’s where it gets deliciously corporate. Pacific Shore didn’t just sit there crying into their ledger. They had insurance. Not health insurance. Not car insurance. Trade credit insurance. Yes, that’s a thing. It’s like a financial safety net for businesses that sell on credit: if your customer ghosts you, the insurance company steps in and pays you—so you don’t go under because Bob from Tulsa skipped town with $60K worth of Italian Carrara. Enter Euler Hermes North America Insurance Company, the self-proclaimed “assignee” in this drama. They paid out the claim to Pacific Shore, took ownership of the debt (via a very official-looking Assignment Agreement dated May 28, 2024), and now—drumroll, please—they’re the ones knocking on Dynasty Marble’s door. Or, more accurately, filing a lawsuit in Tulsa County District Court.

Now, you might think: “Wait, so an insurance company is suing a countertop shop over a debt they didn’t even originally own?” Bingo. That’s exactly what’s happening. Euler Hermes isn’t mad about the marble. They’re mad about the money. And they’ve got the paperwork to prove it—pages and pages of invoices, each more dramatic than the last. Invoice 21498066: $52,171.69. Invoice 21504560: $15,675.79. The dates stack up like a horror movie countdown: September 2023, October, November, December… all the way to February 2024. Due dates come and go. Payments? Crickets. The customer statement reads like a tragic financial opera—running balances climbing higher, credit slowly evaporating, and by the end, the entire $62,786.06 is either 61–90 days late or over 90 days past due. That’s not just late. That’s “forgot your own birthday” late.

So why are we in court? Because Euler Hermes, now the proud legal owner of this debt, wants their money. They’re suing Dynasty Marble for breach of contract—basically saying, “You agreed to pay. You didn’t. Now we’re taking you to court.” It’s not about fraud. It’s not about defective granite. It’s about a simple, brutal truth: you get the stone, you pay the bill. And when you don’t? Someone else comes to collect—with interest. Oh yes, they’re asking for 18% annual interest from April 8, 2024, onward. That’s the kind of rate usually reserved for payday loans and bad decisions. Add on attorney’s fees, court costs, and a sprinkle of corporate indignation, and you’ve got yourself a lawsuit.

Now, is $62,786.06 a lot? In the grand scheme of civil court, it’s not exactly King v. Queen of Hearts levels of extravagance. But for a local stone fabrication business, it’s a serious chunk of change. That’s payroll for months. That’s equipment maintenance. That’s not skipping a payment because you forgot to balance the checkbook—it’s a systemic failure. And yet, Dynasty Marble & Granite hasn’t shown up in this filing. No defense. No counterclaim. No “actually, the slabs were chipped” excuse. Just… silence. Which makes you wonder: did they go under? Did they just decide countertops weren’t worth the stress? Or are they playing the long game, hoping Euler Hermes gets bored and walks away?

Our take? This case is the perfect blend of mundane and magnificent. On the surface, it’s a dry, by-the-books debt collection suit—something that probably happens a thousand times a day across America. But the layers! The insurance company stepping in like a debt superhero! The cold, clinical precision of the customer statement, ticking up like a financial doomsday clock! The fact that someone, somewhere, thought $62,786.06 was worth a full legal petition, notarized affidavits, and a trip to the Tulsa County courthouse! It’s not sensational, but it’s symphonic in its petty corporate drama.

And honestly? We’re rooting for the paper trail. Not because we love insurance companies (we don’t), but because there’s something deeply satisfying about a system that says: “You made a deal. You broke it. Now the paperwork comes for you.” Whether Dynasty Marble is down bad or just plain bad at paying bills, one thing’s clear—nobody escapes the invoice. Not even in Jenks.

Case Overview

$62,786 Demand Petition
Jurisdiction
District Court of Tulsa County, Oklahoma
Relief Sought
$62,786 Monetary
Plaintiffs
Defendants
Claims
# Cause of Action Description
1 breach of contract plaintiff seeks payment of $62,786.06 for goods and services furnished to defendant

Petition Text

1,375 words
IN THE DISTRICT COURT OF TULSA COUNTY STATE OF OKLAHOMA EULER HERMES NORTH AMERICA ) INSURANCE COMPANY, as assignee of ) PACIFIC SHORE HOLDING, INC., Plaintiff, vs. DYNASTY MARBLE & GRANITE, LLC, Defendant. FILED DISTRICT COURT TULSA COUNTY, OKLAHOMA Case Number CJ-2026-1102 PETITION COMES NOW the plaintiff and for its cause of action against the defendant alleges and states: 1. Euler Hermes North America Insurance Company ("Euler Hermes"), is an assignee of Pacific Shore Holding, Inc. (the "Assignor"). See Affidavit, Exhibit 1. 2. Euler Hermes is in the business of providing trade credit insurance, and provided trade credit insurance to its Assignor against non-payment for goods delivered or services rendered to Defendant Dynasty Marble & Granite, LLC. 3. The account which is the subject matter of this litigation was assigned to Euler Hermes following payment of an insurance claim to Assignor. A copy of the assignment is attached as Exhibit A to the Affidavit, Exhibit 1. 4. The insurance claim was paid after review of a sworn insurance claim that included records provided by Assignor as true and accurate evidence of the facts stated therein, and have been incorporated into Euler Hermes business records and relied on to adjust Assignor’s insurance claim. These records are kept by Euler Hermes in the regular course of business. The records attached hereto are the original or exact duplicates of the original documents received by Euler Hermes from Assignor. 5. Euler Hermes is owed the sum of $62,786.06 for goods, materials and/or services furnished to the Defendant by Pacific Shore Holding, Inc., plus interest and attorney’s fees, less credits for payments made and lawful offsets. A true and correct copy of the Statement of Account is attached as Exhibit B. WHEREFORE, plaintiff prays judgment against the defendant for the sum of $62,786.06 with interest thereon at the rate of 18% per annum from April 8, 2024 until paid, for plaintiff’s costs of this action including a reasonable attorney fee, and all other relief the Court deems just and proper. REYNOLDS, RIDINGS, MOGT & ROBERTSON, P.L.L.C. By: [signature] Lisa Robertson, OBA #16155 Attorneys for Plaintiff 101 Park Avenue, Suite 1010 Oklahoma City, OK 73102 (405) 232-8131 (405) 232-7911 Facsimile [email protected] AFFIDAVIT IN SUPPORT OF CLAIM BEFORE ME, the undersigned authority, personally appeared Chyna Kelly known to me and who, after being duly sworn, upon your Affiant’s oath that: 1. I am the Senior Legal Coordinator of Euler Hermes North America Insurance Company ("Euler Hermes"), as assignee of Pacific Shore Holding, Inc. (the "Assignor"). 2. I am authorized by Euler Hermes to make this Affidavit and I have personal knowledge of the contents of this Affidavit with respect to Euler Hermes operations and procedures based on my knowledge and experience gained in the course of my employment, and I have knowledge of the facts supporting the claim based on my review of Euler Hermes books and records. 3. That Euler Hermes is a corporation organized under the laws of the State of Maryland. 4. Euler Hermes is in the business of providing trade credit insurance, and provided trade credit insurance to its Assignor against non-payment for goods delivered or services rendered by Defendant Dynasty Marble & Granite, LLC. 5. The account which is the subject matter of this litigation was assigned to Euler Hermes following payment of an insurance claim to Assignor. A copy of the assignment is attached as Exhibit A. 6. The insurance claim was paid after review of a sworn insurance claim that included the below records provided by Assignor as true and accurate evidence of the facts stated therein, and have been incorporated into Euler Hermes business records and relied on to adjust Assignor’s insurance claim. These records are kept by Euler Hermes in the regular course of business. The records attached hereto are the original or exact duplicates of the original documents received by Euler Hermes from Assignor. 7. Euler Hermes is owed the sum of $62,786.06 for goods, materials and/or services furnished to the Defendant, plus interest and attorney’s fees, less credits for payments madeand lawful offsets. Copies of evidence of the debt and statements of account are attached as Exhibit B. (Signature) Chyna Kelly, Senior Legal Coordinator (Print Name and Title) STATE OF Maryland COUNTY OF Baltimore City The foregoing instrument was acknowledged before me this 10 day of February, 2018, by Chyna Kelly, who is personally known to me or who produced ____________________________ as identification and who did take an oath. MADDISON EG HIRTZ NOTARY PUBLIC CARROLL COUNTY, MD MARYLAND MY COMMISSION EXPIRES APRIL 18, 2026 Notary Public Name: Maddison Hirtz Commission No: _______________________ Commission Expires: 4/18/2026 ASSIGNMENT THIS AGREEMENT OF ASSIGNMENT is made this May 28, 2024 by and between PACIFIC SHORE HOLDING, INC., 1211 ARION PKWY STE 112, San Antonio Texas 78216 (herein called the Insured) and Euler Hermes North America Insurance Company (herein called the Company) 100 International Drive, 22nd Floor , Baltimore, MD 21202. In consideration of this Loss Payment made by the Company to the Insured under their Credit Insurance Policy, receipt of which is hereby acknowledged: Subject to the terms and conditions of the Policy, the INSURED does hereby assign, transfer and set over unto the Company, its claims and demands, together with all securities and guarantees relating thereto, against the following debtor or debtors in the amount or amounts shown thereafter: <table> <tr> <th>Claim</th> <th>Policy</th> <th>Debtor</th> <th>Debtor Location</th> <th>Claim Balance Amount</th> </tr> <tr> <td>CLUS015516</td> <td>5126726</td> <td>DYNASTY MARBLE & GRANITE LLC</td> <td>Jenks Oklahoma</td> <td>62,786.06 USD</td> </tr> </table> Witness: Sara Russell Printed Name of Witness Signature of Witness 06/13/2024 Date PACIFIC SHORE HOLDING, INC. Authorized Representative Linda Mendez Printed Name of Representative Signature of Representative Customer Statement To: Dynasty Marble 6702 East 11th Street Tulsa, OK 74112 <table> <tr> <th>Invoice #</th> <th>Type</th> <th>P.O. #</th> <th>Inv. Date</th> <th>Due Date</th> <th>Inv. Amt</th> <th>Bal. Due</th> <th>Running Bal.</th> </tr> <tr> <td>21498066</td> <td>Invoice</td> <td>kathleen bernardo-ch</td> <td>Sep 25, 2023</td> <td>Nov 09, 2023</td> <td>$52,171.69</td> <td>$5,369.65</td> <td>$5,369.65</td> </tr> <tr> <td>21499177</td> <td>Invoice</td> <td></td> <td>Oct 16, 2023</td> <td>Nov 15, 2023</td> <td>$1,289.71</td> <td>$1,289.71</td> <td>$6,659.36</td> </tr> <tr> <td>21499556</td> <td>Invoice</td> <td></td> <td>Oct 23, 2023</td> <td>Nov 22, 2023</td> <td>$3,915.43</td> <td>$3,915.43</td> <td>$10,574.79</td> </tr> <tr> <td>21499555</td> <td>Invoice</td> <td></td> <td>Oct 23, 2023</td> <td>Nov 22, 2023</td> <td>$1,726.59</td> <td>$1,726.59</td> <td>$12,301.38</td> </tr> <tr> <td>21500471</td> <td>Invoice</td> <td></td> <td>Nov 08, 2023</td> <td>Dec 08, 2023</td> <td>$2,427.47</td> <td>$2,427.47</td> <td>$14,728.85</td> </tr> <tr> <td>21500470</td> <td>Invoice</td> <td>heidi agauas</td> <td>Nov 08, 2023</td> <td>Dec 08, 2023</td> <td>$2,396.08</td> <td>$1,198.04</td> <td>$15,926.89</td> </tr> <tr> <td>21500469</td> <td>Invoice</td> <td>gail</td> <td>Nov 08, 2023</td> <td>Dec 08, 2023</td> <td>$1,143.04</td> <td>$1,143.04</td> <td>$17,069.93</td> </tr> <tr> <td>21500468</td> <td>Invoice</td> <td></td> <td>Nov 08, 2023</td> <td>Dec 08, 2023</td> <td>$4,349.71</td> <td>$4,349.71</td> <td>$21,419.64</td> </tr> <tr> <td>21501361</td> <td>Invoice</td> <td></td> <td>Nov 29, 2023</td> <td>Dec 29, 2023</td> <td>$1,108.86</td> <td>$1,108.86</td> <td>$22,528.50</td> </tr> <tr> <td>21501359</td> <td>Invoice</td> <td></td> <td>Nov 29, 2023</td> <td>Dec 29, 2023</td> <td>$587.69</td> <td>$587.69</td> <td>$23,116.19</td> </tr> <tr> <td>21501744</td> <td>Invoice</td> <td></td> <td>Dec 06, 2023</td> <td>Jan 05, 2024</td> <td>$4,665.23</td> <td>$4,665.23</td> <td>$27,781.42</td> </tr> <tr> <td>21501738</td> <td>Invoice</td> <td></td> <td>Dec 06, 2023</td> <td>Jan 05, 2024</td> <td>$15,765.79</td> <td>$11,824.34</td> <td>$39,605.76</td> </tr> <tr> <td>21501632</td> <td>Invoice</td> <td></td> <td>Dec 06, 2023</td> <td>Jan 05, 2024</td> <td>$2,483.95</td> <td>$2,483.95</td> <td>$42,089.71</td> </tr> <tr> <td>21501629</td> <td>Invoice</td> <td></td> <td>Dec 06, 2023</td> <td>Jan 05, 2024</td> <td>$977.24</td> <td>$977.24</td> <td>$43,066.95</td> </tr> <tr> <td>21503195</td> <td>Invoice</td> <td></td> <td>Jan 09, 2024</td> <td>Feb 08, 2024</td> <td>$2,415.51</td> <td>$2,415.51</td> <td>$45,482.46</td> </tr> <tr> <td>21503193</td> <td>Invoice</td> <td>hitzman</td> <td>Jan 09, 2024</td> <td>Feb 08, 2024</td> <td>$1,627.81</td> <td>$1,627.81</td> <td>$47,110.27</td> </tr> <tr> <td>21504560</td> <td>Invoice</td> <td></td> <td>Feb 07, 2024</td> <td>Mar 08, 2024</td> <td>$15,675.79</td> <td>$15,675.79</td> <td>$62,786.06</td> </tr> </table> Cont. Credit Limit: $100,000.00 Available Credit $37,213.94 Aged Amounts: <table> <tr> <th>Current</th> <th>1 - 30</th> <th>31 - 60</th> <th>61 - 90</th> <th>Over 90</th> <th>Total</th> </tr> <tr> <td>$0.00</td> <td>$15,675.79</td> <td>$4,043.32</td> <td>$21,647.31</td> <td>$21,419.64</td> <td>$62,786.06</td> </tr> </table>
Disclaimer: This content is sourced from publicly available court records. Crazy Civil Court is an entertainment platform and does not provide legal advice. We are not lawyers. All information is presented as-is from public filings.