CS-2026-00043 - Midland Credit Management, Inc. v. Toby R. Young

What's This Case About?

Let’s be real: the most insane thing about this case isn’t that someone owes nearly nine grand. It’s that a man named Toby R. Young is being sued in Oklahoma by a company called Midland Credit Management, Inc.—a debt collector that doesn’t even pretend it was the original lender—over two credit cards he definitely used to buy stuff he probably no longer owns, possibly including something as tragically mundane as a Cabela’s fishing vest and a few Amazon purchases on Mastercard. And now, in the cold light of January 2026, we’re all here, reading affidavits from a Legal Specialist named Turae Sullivan in Minnesota, who swears under penalty of perjury that yes, the numbers add up. The drama is quiet, the stakes are financial, and the villain might just be capitalism itself.

So who are these people? On one side, we’ve got Midland Credit Management, Inc.—a professional debt buyer. Think of them as the vultures of the financial ecosystem: they don’t issue credit, they don’t hand out shiny plastic at the mall kiosk. Instead, they wait in the shadows, then swoop in and buy up defaulted accounts for pennies on the dollar from banks like Capital One and Synchrony Bank. Once they own the debt, they try to collect the full amount. It’s a lucrative business, and they’ve got an entire law firm—Love, Beal & Nixon, P.C., which sounds like a 1950s detective agency—on speed dial to file lawsuits like this one. On the other side is Toby R. Young, a private individual in Kingfisher County, Oklahoma. We don’t know his job, his hobbies, or whether he keeps his receipts in a shoebox. What we do know is that at some point, he opened two credit accounts, used them, stopped paying, and now finds himself on the wrong end of a legal sledgehammer wielded by a third-party collector he’s never met.

Here’s how we got here. Back in October 2020, Toby opened a Capital One credit card—specifically a Cabela’s Club card, which is basically a fishing-themed credit trap designed to make you buy $200 boots you don’t need while whispering, “The outdoors are calling.” He used it, paid it (we assume), and life went on. Then, in May 2022, he opened a second account—this time a Synchrony Bank Mastercard, possibly linked to Amazon, Lowe’s, or some other retailer that said, “Just one more click!” For a while, the payments kept coming. The last recorded payment on the Cabela’s card was February 17, 2024. On the Mastercard? April 19, 2024. Then… silence. The accounts went dark. By October and November of 2024, both were officially “charged off,” meaning the original lenders gave up and sold the debt to Midland Credit Management. Midland paid a fraction of the balance—maybe $1,500 total for both—and now they’re suing for the full $8,724.17. Because that’s how the game is played.

Now, why are we in court? Legally speaking, Midland is filing what’s called a “petition for indebtedness,” which is lawyer-speak for “this guy owes us money and won’t pay.” They’re not accusing Toby of fraud, theft, or identity theft. They’re not saying he skipped town or hid assets. They’re simply asserting that he used credit, failed to repay, and now they—the new owners of that debt—want a judgment from the court confirming he owes them. The legal theory is straightforward: when a debt is assigned (sold) to a new company, that company can step into the lender’s shoes and sue just like the original bank could have. Midland has attached two affidavits from Turae Sullivan, their Legal Specialist in Minnesota, who swears under oath that the records show Toby owes $5,860.68 on the Cabela’s card and $2,863.49 on the Mastercard. She didn’t see the transactions happen. She wasn’t there when Toby bought whatever it was—maybe a kayak, maybe a lawnmower, maybe just groceries during a rough patch. But she’s seen the digital trail, and she’s ready to testify that the numbers check out.

So what does Midland want? $8,724.17. Plus interest. Plus court costs. No punitive damages, no injunctions, no demands that Toby write a letter of apology or attend financial literacy classes. Just cold, hard cash. Now, is $8,700 a lot? Well, it depends. For a lot of people in rural Oklahoma, that’s several months’ rent. It’s a car down payment. It’s a year of groceries. It’s not a life-shattering sum like a medical malpractice verdict, but it’s also not the kind of money you casually Venmo over. And remember: Midland likely paid far less than that to acquire these debts. If they win, it’s pure profit. If Toby doesn’t show up to court or contest the claim, the judge will likely enter a default judgment, and then Midland can start garnishing wages or freezing bank accounts. It’s not dramatic, but it’s effective.

Our take? The most absurd part of this whole thing isn’t Toby’s spending or even Midland’s aggressive collection tactics—those are just symptoms of a broken credit system. No, the real absurdity is the theater of it all. We’ve got a man in Oklahoma being sued by a company in Minnesota, represented by a law firm in Oklahoma City, with sworn affidavits from a Legal Specialist named Turae Sullivan (and yes, we said that name correctly in our heads three times) who has never met Toby, never saw a single receipt, and is testifying solely based on digital records passed down from another company. The whole thing reads like a bureaucratic ghost story: debts haunting new owners, paper trails stretching across states, and a man in Kingfisher County who may not even know this lawsuit exists until a sheriff shows up at his door. We’re not rooting for Toby because he’s innocent—we don’t know that. We’re not rooting for Midland because they’re righteous—we know they’re profiting off pain. We’re rooting for someone to ask: when did owing money become a crime prosecuted by paperwork ninjas in St. Cloud? This isn’t a heist. It’s not a scam. It’s just… life in 2026, where your past financial stumbles can come after you in the form of a notarized affidavit and a docket number: CS-202643. And honestly? That’s scarier than any true crime murder plot. At least in those, someone sees it coming.

Case Overview

$8,724 Demand Petition

Jurisdiction

District Court, Oklahoma

Filing Attorney

William L. Nixon, Jr.

LOVE, BEAL & NIXON, P.C.

Relief Sought

$8,724 Monetary

Plaintiffs

Midland Credit Management, Inc. business
Rep: LOVE, BEAL & NIXON, P.C.

Defendants

Toby R. Young individual

Claims

#	Cause of Action	Description
1	indebtedness	$5,860.68 owed to Midland Credit Management, Inc. for defaulted credit account
2	indebtedness	$2,863.49 owed to Midland Credit Management, Inc. for defaulted credit account

Petition Text

1,197 words

IN THE DISTRICT COURT OF KINGFISHER COUNTY STATE OF OKLAHOMA Midland Credit Management, Inc. Plaintiff, vs. Toby R Young, Defendant. No. CS-202643 PETITION FOR INDEBTEDNESS COMES NOW Plaintiff, by and through its undersigned attorneys who hereby enter their appearance herein, and for cause of action against Defendant alleges and states: COUNT I 1. CAPITAL ONE, N.A., provided credit to the defendant on account number XXXXXXXXXXXXXXX1863. Defendant defaulted on the obligation. The account has been assigned to Plaintiff. 2. Defendant owes Plaintiff $5,860.68. An Affidavit of Account is attached hereto and incorporated by reference. COUNT 2 1. SYNCHRONY BANK, provided credit to the defendant on account number XXXXXXXXXXXXXXX3435. Defendant defaulted on the obligation. The account has been assigned to Plaintiff. 2. Defendant owes Plaintiff $2,863.49. An Affidavit of Account is attached hereto and incorporated by reference. WHEREFORE, Plaintiff prays for Judgment against the Defendant in the sum of $8,724.17, with interest at the statutory rate, all court costs, and for such other relief as the Court may deem just and proper. William L. Nixon, Jr., #012804 Harley L. Homjak, #019736 Gracelyn Porras Dillingham, #35852 Jenifer 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] STATE OF OKLAHOMA Midland Credit Management, Inc, Plaintiff -vs- AFFIDAVIT OF TURAE SULLIVAN Young, Toby R, Defendant(s). Turae Sullivan, whose business address is 600 W. Saint Germain St Suite 200, St. Cloud, MN 56301-3616, certifies and says: 1. I am employed as a Legal Specialist and have access to pertinent account records for Midland Credit Management, Inc. ("Plaintiff" or "MCM"). I am a competent person over eighteen years of age, and make the statements herein based upon personal knowledge of those account records maintained by Plaintiff. Plaintiff is the current owner of, and was assigned all the rights, title and interest to Defendant's CAPITAL ONE, N.A./CABELAS CLUB account XXXXXXXXXXXX1863 (MCM Number 330047573) (hereinafter "the Account"). 2. I have access to and have reviewed the electronic records pertaining to the Account maintained by MCM and am authorized to make this affidavit on MCM's behalf. The electronic records reviewed consist of (i) data and records acquired from the seller or assignor when MCM purchased or was assigned the Account, which were incorporated into MCM's business records upon purchase or assignment, and (ii) data and records generated by MCM in connection with servicing the Account since the date the Account was purchased by or was assigned to MCM. 3. I am familiar with and trained on the manner and method by which MCM creates and maintains its business records pertaining to the Account, which consist of (i) data and documents acquired from the seller or assignor, and (ii) subsequent collection and/or servicing activities by MCM. The records are acquired or created, and are kept in the regular course of MCM's business. It was in the regular course of MCM's business for a person with knowledge of the subsequent collection and/or servicing activities recorded, and a business duty to report, to make the record or data compilation, or to transmit information thereof to be included in such record, or for such information to be posted in MCM's records by a computer or similar digital means. In the regular course of MCM's business, the record or compilation of the subsequent collection activities is made at or near the time of the act or event by MCM as a regular practice. 4. MCM's records show that Defendant(s) owed a balance of $5,860.68 as of 2025-12-22. 5. On or about 2024-11-21, Midland Credit Management, Inc became the successor in interest to this Account. 6. MCM's records show that: 1) the Account was opened on 2020-10-03; 2) the last payment posted to the Account on 2024-02-17; and 3) the Account was charged off on 2024-10-14. 7. If called to testify as a witness thereon, I could and would competently testify as to all the facts stated herein. LEFT BLANK INTENTIONALLY I certify under penalty of perjury that the foregoing statements are true and correct. JAN 15 2026 Date STATE OF MINNESOTA COUNTY OF STEARNS Turae Sullivan Signed and sworn to (or affirmed) before me on JAN 15 2026 by Turae Sullivan. Christy Lynn Biess Notary Public - Minnesota My Commission Expires 05/31/2026 By Notary Public OK038 STATE OF OKLAHOMA Midland Credit Management, Inc, Plaintiff -vs- Young, Toby, Defendant(s). AFFIDAVIT OF TURAE SULLIVAN Turae Sullivan, whose business address is 600 W. Saint Germain St Suite 200, St. Cloud, MN 56301-3616, certifies and says: 1. I am employed as a Legal Specialist and have access to pertinent account records for Midland Credit Management, Inc. ("Plaintiff" or "MCM"). I am a competent person over eighteen years of age, and make the statements herein based upon personal knowledge of those account records maintained by Plaintiff. Plaintiff is the current owner of, and was assigned all the rights, title and interest to Defendant's SYNCHRONY BANK/SYNCHRONY MASTERCARD account XXXXXXXXXX3435 (MCM Number 330978242) (hereinafter "the Account"). 2. I have access to and have reviewed the electronic records pertaining to the Account maintained by MCM and am authorized to make this affidavit on MCM's behalf. The electronic records reviewed consist of (i) data and records acquired from the seller or assignor when MCM purchased or was assigned the Account, which were incorporated into MCM's business records upon purchase or assignment, and (ii) data and records generated by MCM in connection with servicing the Account since the date the Account was purchased by or was assigned to MCM. 3. I am familiar with and trained on the manner and method by which MCM creates and maintains its business records pertaining to the Account, which consist of (i) data and documents acquired from the seller or assignor, and (ii) subsequent collection and/or servicing activities by MCM. The records are acquired or created, and are kept in the regular course of MCM's business. It was in the regular course of MCM's business for a person with knowledge of the subsequent collection and/or servicing activities recorded, and a business duty to report, to make the record or data compilation, or to transmit information thereof to be included in such record, or for such information to be posted in MCM's records by a computer or similar digital means. In the regular course of MCM's business, the record or compilation of the subsequent collection activities is made at or near the time of the act or event by MCM as a regular practice. 4. MCM's records show that Defendant(s) owed a balance of $2,863.49 as of 2025-12-22. 5. On or about 2025-01-17, Midland Credit Management, Inc became the successor in interest to this Account. 6. MCM's records show that: 1) the Account was opened on 2022-05-29; 2) the last payment posted to the Account on 2024-04-19; and 3) the Account was charged off on 2024-11-11. 7. If called to testify as a witness thereon, I could and would competently testify as to all the facts stated herein. LEFT BLANK INTENTIONALLY I certify under penalty of perjury that the foregoing statements are true and correct. JAN 15 2026 Date STATE OF MINNESOTA COUNTY OF STEARNS Signed and sworn to (or affirmed) before me on JAN 15 2026 by Turae Sullivan. Christy Lynn Biès Notary Public · Minnesota My Commission Expires 09/11/2023 OK038