CJ-2025-5145 - Midland Credit Management, Inc. v. Celia Deleon

What's This Case About?

Let’s cut right to the chase: a debt collector is suing a woman in Tulsa for $34,655.28—because she didn’t pay off her Caesars Rewards and AAdvantage credit cards. Yes, you read that right. A debt buyer named Midland Credit Management, Inc. is now dragging Celia Deleon to court over unpaid balances on a casino rewards card and an airline mileage card, like this is some high-stakes episode of Law & Order: Frequent Flyer Miles. We’re not in Atlantic City. We’re in Tulsa County District Court. And the house always wins—especially when the house is a third-party debt collector with a notary in Minnesota and a spreadsheet full of old credit lines.

So who are these people? On one side, we’ve got Celia Deleon, an Oklahoma resident who, at some point, decided life needed more Caesar’s Palace vibes and American Airlines upgrades. She opened two credit accounts: one with Comenity Bank tied to Caesars Rewards (because nothing says “responsible financial planning” like a credit card that encourages you to gamble and eat all-you-can-eat buffets), and another with Citibank for the AAdvantage MileUp card (which, for the uninitiated, is basically a credit card that rewards you for pretending you’re rich enough to fly business class). On the other side? Midland Credit Management, Inc.—a company that doesn’t issue credit, doesn’t run casinos, and doesn’t operate a single flight. Instead, they buy up defaulted debts for pennies on the dollar and then sue people to collect the full amount. Think of them as the vultures of the financial ecosystem: they don’t cause the crash, but they’re the first to circle when someone’s credit score hits the pavement.

Now, here’s how we got here. According to the court filing—backed by a notarized affidavit from one Isaac Buse, Legal Specialist and apparently the oracle of Midland’s digital records—Celia opened the Caesars Rewards card in January 2022. That’s right in the middle of the Great Post-Pandemic Spending Spree, when everyone suddenly remembered vacations, dining out, and pretending they were high rollers at a slot machine. She made her last payment on that account in July 2023. By February 2024, the account was “charged off,” which is banker-speak for “we’ve given up on you paying this voluntarily.” Around the same time, her AAdvantage card—opened way back in December 2019, possibly during a layover at DFW—also went dark. Her last payment there was in August 2023, and Citibank pulled the plug in March 2024. Both debts were then sold or assigned to Midland Credit Management, which, like a financial phoenix rising from the ashes of poor credit decisions, now claims full ownership of what Celia owes.

And what does she owe? $10,371.03 on the Caesars card. $24,284.25 on the AAdvantage card. Combined, that’s $34,655.28—plus interest, court costs, and whatever emotional toll it takes to be sued by a company in Minnesota over a credit card you probably used to book a flight to Cancun three years ago. Midland isn’t asking for punitive damages. They’re not demanding an apology. They’re not even asking for her frequent flyer miles. No, they just want the money. Cold, hard cash. And they’re willing to file a lawsuit in Tulsa County to get it.

But let’s break this down in plain English, because the legal jargon here is about as exciting as a Terms & Conditions scroll. Midland is filing what’s called a “Petition for Indebtedness,” which is just a fancy way of saying, “Hey, this person owes money, and we have the paperwork to prove it.” They’re not accusing Celia of fraud. They’re not claiming she denied the debt ever existed. They’re just saying: the records show she borrowed money, stopped paying, the accounts were charged off, we bought the debt, and now we want the court to order her to pay up. It’s a routine debt collection play—so routine, in fact, that the same law firm, LOVE, BEAL & NIXON, P.C., files dozens of these every month across Oklahoma. Their attorney, William L. Nixon, Jr., probably drafted this petition between sips of lukewarm office coffee while thinking about lunch.

Now, is $34,655 a lot? In the grand scheme of civil lawsuits, it’s not a king’s ransom. It’s not covering a down payment on a house, but it’s also not chump change. For the average Oklahoman, that’s a year’s worth of groceries, two used cars, or a solid chunk of a mortgage payment. It’s the kind of sum that can wreck a credit score, trigger wage garnishment, and make your phone ring off the hook with collection calls. And yet, here’s the absurd part: Midland likely didn’t pay anywhere near that much for these debts. When banks “charge off” an account, they write it off as a loss and often sell the debt to collectors for 5–10% of the balance. So Midland might have paid as little as $1,700 to $3,500 total for both accounts. If they win? They pocket the difference. That’s not just collecting a debt—that’s profiteering off someone else’s financial downfall.

What’s our take? Look, no one’s saying Celia Deleon should get a free pass if she racked up thousands on credit cards and ghosted the bill. Personal responsibility matters. But there’s something deeply dystopian about a system where a woman gets sued in Tulsa by a company in Minnesota over a casino rewards card—a product literally designed to make you spend more at a place where the odds are mathematically rigged against you. And let’s not pretend the AAdvantage MileUp card is some utilitarian tool. It’s marketed to millennials with wanderlust and a Spotify subscription, promising “5x miles on travel” and “2x on dining.” It’s not a necessity. It’s a lifestyle product sold with the quiet understanding that not everyone who signs up will keep up with the payments.

The most absurd part? Isaac Buse, the “Legal Specialist” whose affidavit forms the backbone of this case, has never met Celia Deleon. He’s never seen her credit application. He’s never reviewed her income or spending habits. He’s basing his entire sworn testimony on electronic records “acquired from the seller or assignor”—which means he’s essentially vouching for data he didn’t create, didn’t verify in person, and can’t independently confirm. Yet, in the eyes of the court, that’s enough to justify a lawsuit that could upend someone’s financial life.

We’re not rooting for anyone to dodge their debts. But we are rooting for a system that doesn’t treat credit card debt like a blood debt, where third-party collectors with no skin in the original transaction get to play judge, jury, and executioner. And if we’re being honest? We’d love to see Celia show up in court with a Caesar’s loyalty card and a boarding pass, sit down at the defendant’s table, and say, “You want the money? Here’s my frequent loser badge.”

But until then, we’ll be here—covering the civil circus, one petty lawsuit at a time. Remember: we’re entertainers, not lawyers. But if we were, we’d suggest everyone involved take a long, hard look at their life choices—especially the ones involving mileage rewards and slot machines.

Case Overview

$34,655 Demand Petition

Jurisdiction

District Court, Oklahoma

Filing Attorney

William L. Nixon, Jr.

LOVE, BEAL & NIXON, P.C.

Relief Sought

$34,655 Monetary

Plaintiffs

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

Defendants

Celia Deleon individual

Claims

#	Cause of Action	Description
1	Petition for Indebtedness	Defaulted debts to Comenity Bank and Citibank, N.A.
2	Petition for Indebtedness	Defaulted debt to Citibank, N.A.

Petition Text

1,190 words

IN THE DISTRICT COURT OF TULSA COUNTY STATE OF OKLAHOMA Midland Credit Management, Inc. Plaintiff, vs. Celia Deleon, 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 1 1. COMENITY BANK, provided credit to the defendant on account number XXXXXXXXXXXXXXXX5006. Defendant defaulted on the obligation. The account has been assigned to Plaintiff. 2. Defendant owes Plaintiff $10,371.03. An Affidavit of Account is attached hereto and incorporated by reference. COUNT 2 1. CITIBANK, N.A., provided credit to the defendant on account number XXXXXXXXXXXXXXX3222. Defendant defaulted on the obligation. The account has been assigned to Plaintiff. 2. Defendant owes Plaintiff $24,284.25. An Affidavit of Account is attached hereto and incorporated by reference. WHEREFORE, Plaintiff prays for Judgment against the Defendant in the sum of $34,655.28, 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- Deleon, Celia, Defendant(s). AFFIDAVIT OF ISAAC BUSE Isaac Buse, 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/CAESARS REWARDS account xxxxxxxxxxxxxxxx5006 (MCM Number 326477424) (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 $10,371.03 as of 2025-08-20. 5. On or about 2024-03-25, Midland Credit Management, Inc became the successor in interest to this Account. 6. MCM's records show that: 1) the Account was opened on 2022-01-09; 2) the last payment posted to the Account on 2023-07-20; and 3) the Account was charged off on 2024-02-29. 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. AUG 29 2025 Date STATE OF MINNESOTA COUNTY OF STEARNS Isaac Buse Signed and sworn to (or affirmed) before me on AUG 29 2025 by Isaac Buse. Amanda K Larson-Johnson Notary Public - Minnesota My Commission Expires 01/31/2027 Notary Public OK038 STATE OF OKLAHOMA Midland Credit Management, Inc, Plaintiff -vs- AFFIDAVIT OF ISAAC BUSE Deleon, Celia T, Defendant(s). Isaac Buse, 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./AADVANTAGE MILEUP account XXXXXXXXXXXXX3222 (MCM Number 327254400) (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 $24,284.25 as of 2025-08-20. 5. On or about 2024-05-20, Midland Credit Management, Inc became the successor in interest to this Account. 6. MCM's records show that: 1) the Account was opened on 2019-12-02; 2) the last payment posted to the Account on 2023-08-01; and 3) the Account was charged off on 2024-03-20. 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. AUG 29 2025 Date STATE OF MINNESOTA COUNTY OF STEARNS Signed and sworn to (or affirmed) before me on AUG 29 2025 by Isaac Buse. Amanda K Larson-Johnson Notary Public • Minnesota My Commission Expires 01/31/2027 OK038