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JACKSON COUNTY • CJ-2025-00113

Midland Credit Management, Inc. v. John Earls

Filed: Nov 7, 2025
Type: CJ

What's This Case About?

Let’s get one thing straight: John Earls didn’t technically do anything wrong in this story—at least, not according to the court filing. He didn’t embezzle, he didn’t assault, he didn’t even fail to return a Netflix DVD (though honestly, that might’ve been more dramatic). No, John Earls allegedly did the most American thing possible: he opened a credit card… and then didn’t pay it. And now, over $10,000 later, he’s being sued by a company he’s never met, represented by a law firm with six attorneys listed like it’s a Broadway cast, all because Citibank decided it didn’t want to chase him anymore and sold his debt to the financial equivalent of a repo man.

So who are these people? On one side, we’ve got John Earls of Jackson County, Oklahoma—a man whose entire legal footprint in this case consists of existing and allegedly not paying a bill. We don’t know if he’s a rancher, a mechanic, or just a guy who really liked buying stuff online during the pandemic. What we do know is that back in February 2020—right before the world shut down—he opened a credit card account with Citibank under the brand name “Simplicity.” (Yes, Simplicity. The irony is thicker than Oklahoma barbecue sauce.) Fast forward four years, and John’s last recorded payment was in February 2024. By September of that same year, Citibank had given up, declared the account “charged off”—which sounds dramatic but really just means “we’re writing this off as a loss for tax purposes”—and then promptly sold the debt to Midland Credit Management, Inc., a debt buyer based in Minnesota that specializes in scooping up delinquent accounts like bargain-bin Halloween candy and trying to collect on them.

Enter Midland Credit Management, Inc.—not a bank, not a lender, not even the original creditor. They’re what’s known in the biz as a “debt collector,” but more specifically, a debt buyer. These companies purchase bundles of unpaid debts for pennies on the dollar, then try to collect the full amount (plus interest, fees, and their own sense of moral superiority). Midland didn’t lend John Earls a dime. They didn’t approve his credit application. They weren’t there when he swiped that card for whatever mysterious purchases led to a $10,635 balance. But now, they’re the ones suing him, with all the confidence of someone who just found your lost wallet and decided to keep the cash.

The story here is as straightforward as a highway billboard: John Earls had a credit card. He stopped paying it. Citibank washed its hands of the situation. Midland bought the debt. Now Midland wants its money—$10,635, to be exact—and since polite collection letters apparently didn’t work (we assume; the filing doesn’t say, but let’s give John the benefit of the doubt), they’ve escalated to the nuclear option: a lawsuit in Jackson County District Court. The legal claim? “Petition for Indebtedness,” which in plain English means, “Hey, this person owes us money, and we want the court to force them to pay.” It’s not fraud. It’s not breach of contract in the dramatic sense. It’s just… math. Or at least, it’s what Midland says the math is.

To back this up, they’ve attached an affidavit from Joyce Hylla—Legal Specialist at Midland, based in St. Cloud, Minnesota—who swears under penalty of perjury that, yes, the records show John Earls owes $10,635 as of August 8, 2025. She says she has access to the electronic records, that they’re kept in the regular course of business, and that Midland became the rightful owner of the debt on October 22, 2024. She also notes the account was opened in 2020, the last payment was in early 2024, and it was charged off later that year. All standard stuff, really—except for the fact that none of this involves John Earls saying a single word. He hasn’t admitted to owing the money. He hasn’t disputed it (yet). As of this filing, he hasn’t even responded. This is a one-sided story told entirely through corporate paperwork, not unlike a breakup letter written by a credit card company.

Now, what does Midland want? $10,635. That’s the number. Is that a lot? Well, for a single credit card balance, sure—it’s not a mortgage, but it’s enough to buy a used car, pay off a year of rent in some parts of Oklahoma, or fund a really ambitious yard renovation. But here’s the kicker: Midland probably didn’t pay anywhere near that for the debt. Industry standards suggest debt buyers pay between 4 and 20 cents on the dollar for charged-off accounts. So Midland may have acquired John’s $10,635 “obligation” for as little as $400 to $2,000. If they win, they could pocket the difference—plus statutory interest, court costs, and the quiet satisfaction of knowing they turned a $2,000 investment into a court-enforceable judgment. That’s not just collecting debt. That’s scalping debt.

And yet, here’s where our snarky hearts pause for a moment. Because while Midland is playing by the rules—technically—the whole system feels a little… off. A man gets sued by a company that wasn’t his lender, based on records maintained by someone who’s never met him, all because a bank decided it didn’t want to deal with him anymore. The affidavit is signed in Minnesota, the law firm is in Oklahoma City, the defendant is in Jackson County, and the original transaction might’ve happened on a website at 2 a.m. during a Target shopping spree. There’s no drama, no betrayal, no twist—just a quiet, bureaucratic machine grinding away at someone’s financial life.

Our take? The most absurd part isn’t that John Earls might owe money. It’s that the entire American debt collection system runs on this kind of ghost story—where debts are bought and sold like fantasy football players, and people get sued by corporations that materialized out of thin air with a spreadsheet and a notary stamp. We’re not rooting for anyone to dodge responsibility. But we are rooting for a system where if you’re going to get sued, at least the person holding the clipboard used to work at the same bank you signed up with. There’s something almost poetic about a lawsuit filed by six attorneys, not because the case is complicated, but because capitalism demands efficiency—even in collecting your late credit card bill.

So here’s to John Earls, the silent protagonist of this tale. Will he fight back? Will he settle? Will he show up to court with a notarized letter from his dog explaining the economic hardships of 2023? We may never know. But one thing’s for sure: in the wild world of civil court, sometimes the most shocking crime isn’t what you did—it’s what you didn’t pay.

Case Overview

Petition
Jurisdiction
District Court, Oklahoma
Relief Sought
$10,635 Monetary
Plaintiffs
Defendants
Claims
# Cause of Action Description
1 Petition for Indebtedness

Petition Text

830 words
25-34533-0 YE1 008 IN THE DISTRICT COURT OF JACKSON COUNTY STATE OF OKLAHOMA Midland Credit Management, Inc., vs. John Earls, PETITION FOR INDEBTEDNESS COMES NOW the Plaintiff, by and through its undersigned attorneys who hereby enter their appearance herein, and for cause of action against the Defendant alleges and states: 1. Defendant Defaulted on CITIBANK, N.A. obligation with account number xxxxxxxxxxxxxx3484. Defendant defaulted on the obligation. The account has been assigned to Plaintiff. 2. Defendant owes Plaintiff $10,635.00. An Affidavit of Account and/or contract is attached hereto and incorporated by reference. WHEREFORE, Plaintiff prays for Judgment against the Defendant in the sum of $10,635.00, 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 Peggy S. Horinek, #010344 Jenifer A. Gani, #021876 Alexander M. Hall, #33900 Mariah S. Ellicott, #36309 Mingmei "Elaine" Pok, #36236 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- Earls, John, Defendant(s). AFFIDAVIT OF JOYCE HYLLA Joyce Hylla, 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 CITIBANK, N.A./SIMPLICITY account XXXXXXXXXXXXX3484 (MCM Number 329446144) (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 $10,635.00 as of 2025-08-08. 5. On or about 2024-10-22, Midland Credit Management, Inc became the successor in interest to this Account. 6. MCM's records show that: 1) the Account was opened on 2020-02-20; 2) the last payment posted to the Account on 2024-02-07; and 3) the Account was charged off on 2024-09-10. 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 25-34533-0 YE1 008 IN THE DISTRICT COURT OF JACKSON COUNTY STATE OF OKLAHOMA Midland Credit Management, Inc., ) ) ) ) Plaintiff, vs. No. CJ:25·113 John Earls, ) ) ) Defendant. PETITION FOR INDEBTEDNESS COMES NOW the Plaintiff, by and through its undersigned attorneys who hereby enter their appearance herein, and for cause of action against the Defendant alleges and states: 1. Defendant Defaulted on CITIBANK, N.A. obligation with account number XXXXXXXXXXXXXX3484. Defendant defaulted on the obligation. The account has been assigned to Plaintiff. 2. Defendant owes Plaintiff $10,635.00. An Affidavit of Account and/or contract is attached hereto and incorporated by reference. WHEREFORE, Plaintiff prays for Judgment against the Defendant in the sum of $10,635.00, 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 Peggy S. Horinek, #010344 Jenifer A. Gani, #021876 Alexander M. Hall, #33900 Mariah S. Ellicott, #36309 Mingmei "Elaine" Pok, #36236 LOVE, BEAL & NIXON, P.C. Attorney for Plaintiff P.O. Box 32738 Oklahoma City, OK 73123 Telephone: 405-720-0565 E-Mail: [email protected] I certify under penalty of perjury that the foregoing statements are true and correct. AUG 19 2025 Date STATE OF MINNESOTA COUNTY OF STEARNS Signed and sworn to (or affirmed) before me on AUG 19 2025 by Joyce Hylla. Christy Lynn Biss Notary Public - Minnesota My Commission Expires 01/31/2029 OK038
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.