CJ-2026-676 - Midland Credit Management, Inc. v. Samantha V. Dobish

What's This Case About?

Let’s be real: nobody wakes up one morning and says, “You know what I want? To be sued for $20,366 over two credit cards I haven’t touched in years.” But here we are. In Tulsa County, Oklahoma, Samantha V. Dobish is now officially on the legal radar—not for anything dramatic like embezzlement or a fender bender with a celebrity, but because a debt collector wants its money, and it’s willing to file 14 pages of legal paperwork to get it. That’s the modern American dream, folks: getting sued by a company you’ve never met, over debts you may not even remember, all orchestrated by a guy named Mohamed Hassan who lives in Minnesota and has never laid eyes on you.

So who is Samantha Dobish? We don’t know much—no LinkedIn, no viral TikTok, no mugshot (thank goodness). She’s just… a person. A regular human who, at some point, applied for two credit cards: one with Comenity Bank for what was likely Loft’s Mastercard (because yes, you can get a credit card just to buy overpriced linen blazers), and another with Citibank, possibly linked to Diamond Preferred—some sort of rewards or membership program that sounds like a timeshare but could honestly be anything. She used them. She made payments. And then, somewhere around 2022, she stopped. The last recorded payment on the Loft card was August 2022. On the Diamond card? October 2022. And then… crickets. Silence. Radio silence. Financial ghosting.

Fast-forward to 2023, and the banks decided enough was enough. They “charged off” both accounts—accounting speak for “we’re not holding our breath anymore.” But that doesn’t mean the debt vanished. Oh no. In the bizarre, slightly dystopian world of American debt, when you stop paying, your balance doesn’t disappear—it gets sold. Like a distressed action figure on eBay, your unpaid credit card is auctioned off to the highest bidder in the debt collection underground. And in this case, the winner was Midland Credit Management, Inc.—a company so committed to chasing down old balances that they have an entire legal department in Oklahoma City on speed dial.

Midland didn’t lend Samantha the money. They didn’t approve her credit application. They weren’t there when she bought whatever it was that sent her balance to $16,189 on the Loft card—was it a shopping spree? Medical bills charged to plastic? A single, tragic impulse purchase of a $15,000 coat? We may never know. But Midland bought the right to collect that debt, and now they’re treating it like a sacred trust. They’ve sent their legal cavalry—Love, Beal & Nixon, P.C., a firm whose name sounds like a 19th-century law partnership from a Western—armed with affidavits, not six-shooters.

And then there’s Mohamed Hassan. He’s not a lawyer. He’s a “Legal Specialist” at Midland, based in St. Cloud, Minnesota—a city so cold it probably makes debt collection feel like a warm hug. Hassan has never met Samantha. He’s never seen her signature. But he’s sworn under penalty of perjury that, based on Midland’s records, she owes exactly $16,189.07 on the Loft account and $4,177.61 on the Diamond card. That’s $20,366.68, down to the penny. He’s so confident in these numbers that he’s willing to testify in court about them—assuming, of course, that anyone ever shows up.

Because here’s the thing: this isn’t Die Hard. There’s no hostage situation. No dramatic courtroom showdown (yet). This is a petition for indebtedness—a polite legal way of saying, “We have paperwork saying you owe us money. Please pay us, or a judge will make you.” Midland isn’t asking for punitive damages. They’re not demanding Samantha’s firstborn. They just want the money, plus interest at the statutory rate (which in Oklahoma is 5% per year if no contract rate applies, but let’s not get too nerdy). They also want court costs, which probably cover the price of printing these 14 pages and the notary fee for Hassan’s dual affidavits—yes, he had to sign two, one for each card, like a bureaucratic twin.

Now, is $20,366 a lot? Well, that depends on who you are. If you’re a hedge fund that buys distressed debt for pennies on the dollar, it’s a solid return. If you’re Samantha Dobish, living in Tulsa and possibly still recovering from whatever life event made her stop paying her credit cards—job loss, divorce, medical emergency, or just the slow creep of inflation—it’s a mountain. It’s a used car. It’s a year of rent in some parts of Oklahoma. It’s not “I lost the house” money, but it’s definitely “I can’t sleep at night” money.

And yet, the most absurd part of this whole saga isn’t the amount. It’s the machinery. Think about it: a woman in Oklahoma defaults on two credit cards. The banks give up. A company in California (Midland is based in San Diego) buys the debt. Then a guy in Minnesota reviews digital records he didn’t create, swears under oath that the numbers are real, and signs two nearly identical affidavits on the same day, notarized by the same notary in Stearns County, as if he were filing taxes for a side hustle. All of this so a law firm in Oklahoma City can ask a Tulsa judge to please, please make Samantha pay up.

We don’t know if Samantha will fight this. She might not even know about it yet—service of process is still pending, we assume. She might show up with a lawyer and dispute the debt, claiming she already paid it, or that the statute of limitations has run out (in Oklahoma, it’s three years for written contracts, and the last payments were in 2022, so… it’s cutting it close). Or she might just fold, pay the money, and add this to the list of things she’d rather forget.

But here’s what we’re rooting for: a counterclaim. Just one sentence where Samantha says, “Actually, I was misled by Loft’s rewards program,” or “Citibank never disclosed the interest rate properly,” or even, “I bought a dress that shrunk in the wash and I want my money back.” Something. Anything. Because right now, this case is a perfect example of how impersonal and industrialized debt collection has become—less “you owe me” and more “our algorithm says you owe us.”

At the end of the day, this isn’t about blazers or diamonds or preferred memberships. It’s about a system that turns personal financial struggle into a spreadsheet, then into a legal filing, then into a judgment—unless someone has the guts to say, “Wait, hold on. Let’s talk about how we got here.”

But knowing how these things go? We’re betting on the spreadsheet.

Case Overview

$20,367 Demand Petition

Jurisdiction

District Court of Tulsa County, Oklahoma

Filing Attorney

William L. Nixon, Jr.

LOVE, BEAL & NIXON, P.C.

Relief Sought

$20,367 Monetary

Plaintiffs

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

Defendants

Samantha V. Dobish individual

Claims

#	Cause of Action	Description
1	Petition for Indebtedness	Asserts two debts owed to Midland Credit Management, Inc.

Petition Text

1,175 words

25-29123-0 ZP6 008 IN THE DISTRICT COURT OF TULSA COUNTY STATE OF OKLAHOMA Midland Credit Management, Inc ) ) Plaintiff, vs. Samantha V Dobish, ) ) Defendant. 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. COMENITY BANK, provided credit to the defendant on account number XXXXXXXXXXXXXXX6004. Defendant defaulted on the obligation. The account has been assigned to Plaintiff. 2. Defendant owes Plaintiff $16,189.07. COUNT 2 1. CITIBANK, N.A., provided credit to the defendant on account number XXXXXXXXXXXXXXX6842. Defendant defaulted on the obligation. The account has been assigned to Plaintiff. 2. Defendant owes Plaintiff $4,177.61. WHEREFORE, Plaintiff prays for Judgment against the Defendant in the sum of $20,366.68, 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 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- Dobish, Samantha V, Defendant(s). AFFIDAVIT OF MOHAMED HASSAN Mohamed Hassan, 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 COMENTITY BANK/LOFT MASTERCARD account XXXXXXXXXXXXXXXX6004 (MCM Number 322358662) (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 $16,189.07 as of 2025-07-08. 5. On or about 2023-05-26, Midland Credit Management, Inc became the successor in interest to this Account. 6. MCM's records show that: 1) the Account was opened on 2015-11-27; 2) the last payment posted to the Account on 2022-08-29; and 3) the Account was charged off on 2023-04-30. 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. JUL 16 2025 Date STATE OF MINNESOTA COUNTY OF STEARNS Signed and sworn to (or affirmed) before me on JUL 16 2025 by Mohamed Hassan. Karla Ann Sutter Notary Public • Minnesota My Commission Expires 01/31/2029 Notary Public OK038 STATE OF OKLAHOMA Midland Credit Management, Inc, Plaintiff -vs- Dobish, Samantha, Defendant(s). AFFIDAVIT OF MOHAMED HASSAN Mohamed Hassan, 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./DIAMOND PREFERRED account xxxxxxxxxxxxxxxx6842 (MCM Number 322741683) (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 $4,177.61 as of 2025-07-08. 5. On or about 2023-06-21, Midland Credit Management, Inc became the successor in interest to this Account. 6. MCM's records show that: 1) the Account was opened on 2021-05-13; 2) the last payment posted to the Account on 2022-10-17; and 3) the Account was charged off on 2023-04-19. 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. Date JUL 16 2025 Mohamed Hassan STATE OF MINNESOTA COUNTY OF STEARNS Signed and sworn to (or affirmed) before me on JUL 16 2025 by Mohamed Hassan. Karla Ann Sutter Notary Public - Minnesota My Commission Expires 01/31/2029 Notary Public OK038