CJ-2026-00074 - Midland Credit Management, Inc. v. Kimberly Hibler

What's This Case About?

Let’s get one thing straight: in the world of civil court drama, we usually expect cheating spouses, backyard feuds, or at least someone suing over a squirrel infestation. But no. The wildest part of this Oklahoma case? A woman is being sued for $16,792… over two old credit cards she hasn’t paid in years — one of which dates back to 1997. Yes, that’s before Facebook, before the iPhone, and way before “buy now, pay never” became a Gen Z financial strategy. And now, decades later, the bill collector is here, with lawyers, affidavits, and a very serious tone.

So who are we even talking about? On one side: Kimberly Hibler, a regular Oklahoma resident who, according to the court filing, once had two Citibank credit cards — one linked to My Best Buy (because nothing says financial responsibility like a retail credit card), and another under the “Double Cash” brand, which sounds like a gym membership for money. On the other side: Midland Credit Management, Inc., a debt collection company based in Minnesota that doesn’t care about your life story — only your unpaid balance. Midland isn’t the original lender. They didn’t hand Kimberly a card at a kiosk in 1997. No, they’re the secondhand debt store — the kind of company that buys up defaulted accounts for pennies on the dollar and then sues to collect the full amount. Think of them as the eBay flipper of financial misery.

Now, let’s walk through the timeline, because it’s wild. The first card, the Best Buy one, was opened in November 2016. That’s recent enough — maybe she needed a new fridge, a soundbar, or finally upgraded her DVD collection to Blu-ray. She made payments until October 2023, then stopped. Citibank charged it off in May 2024 — meaning they wrote it off as a loss, emotionally detached, and moved on with their corporate life. But then, like a zombie rising from a financial grave, Midland Credit Management bought the debt in September 2024 and now wants $10,829.79. For a Best Buy card. From 2016. That’s not just collecting debt — that’s archaeology.

The second account is where things get bizarre. This Double Cash card? Opened in August 1997. Let that sink in. That’s the same year Titanic came out. Bill Clinton was president. The average price of a gallon of gas was $1.23. And Kimberly Hibler had a Citibank credit card. She apparently kept it active — or at least, someone did — until April 2024, when the last payment was made. The account was charged off in November 2024, and Midland picked it up in December. Now they want $5,962.28. For a credit card that predates social media, streaming, and possibly her current phone. This isn’t debt collection. This is a financial time machine.

So why are we in court? Because Midland filed a petition claiming Hibler still owes them money — two separate debts, technically — and they want a judge to officially say, “Yep, she owes it.” Legally, this is called “indebtedness,” which is lawyer-speak for “you borrowed money and didn’t pay it back.” Midland isn’t asking for punitive damages, they’re not demanding an apology, and they’re not trying to take her car or her cat. They just want a judgment — a court stamp that says the debt is valid and enforceable. Once they have that, they can garnish wages, freeze bank accounts, or just keep calling until she pays. And yes, they’re also asking for interest and court costs, because nothing says “we’re doing this by the book” like charging you extra for the privilege of being sued.

Now, what do they actually want? $16,792.07. Is that a lot? Well, it depends. If you’re a debt collection firm that bought these accounts for maybe $1,700 total, then yes — that’s a 900% return if they win. If you’re Kimberly Hibler, living in Pottawatomie County, Oklahoma, where the median household income is around $60,000, $16k is over a quarter of your annual take-home. That’s a car, a year of rent, or a very ambitious vacation. It’s not chump change. But here’s the kicker: Midland didn’t lend her a dime. They didn’t assess her credit. They didn’t send her a single statement. They bought defaulted debt — likely for pennies — and now they’re suing for the full balance, plus interest, like they’ve been patiently waiting all these years with a ledger and a frown.

And here’s what makes this whole thing feel like a glitch in the Matrix: the affidavits. They’re signed by Jennifer Dittberner, a “Legal Specialist” in St. Cloud, Minnesota, who swears under penalty of perjury that she has “personal knowledge” of Kimberly Hibler’s account records… despite never having met her. She’s never reviewed the original application, never spoke to Citibank, never saw a signature. Her entire testimony is based on electronic records that were “incorporated” into Midland’s system — a chain of data that could stretch back through multiple debt buyers, servicers, and corporate rebrands. It’s like proving you own a baseball card by showing a photo of someone else’s photo of a photo. And yet, in court, this is often enough.

Our take? Look, nobody expects you to pay for a 1997 credit card forever. Life happens. Jobs disappear. Medical bills pile up. Retail therapy turns into long-term debt therapy. But the real absurdity here isn’t that Kimberly Hibler hasn’t paid her bills — it’s that a company in Minnesota is now suing her over two Citibank accounts, one nearly three decades old, using affidavits signed in December 2025… on a document filed in 2025. Wait — December 2025? That’s next year. Either we’ve stumbled into a time-traveling debt collection scheme, or someone really needs to check their calendar. Because if the affidavit is dated in the future, then either Jennifer Dittberner is a prophet… or this whole thing is built on paperwork that hasn’t technically happened yet.

We’re not rooting for the debt collector. We’re not even really rooting against Kimberly — unless she’s been using that Double Cash card to fund a secret life as a 90s nostalgia influencer. But we are rooting for the truth. For actual proof. For someone to explain how a credit card from the Clinton era is still an active legal obligation in 2025. And for the court system to maybe, just maybe, ask whether it’s fair to let companies buy old debt, file future-dated affidavits, and sue people without ever proving they actually owe what’s claimed. Because if we’re going to enforce 30-year-old credit lines, we should at least make sure the paperwork isn’t from the future. We’re entertainers, not lawyers — but even we know you can’t sue someone using a time machine. Or can you?

Case Overview

$16,792 Demand Petition

Jurisdiction

District Court, Oklahoma

Relief Sought

$16,792 Monetary

Plaintiffs

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

Defendants

Kimberly Hibler individual

Claims

#	Cause of Action	Description
1	indebtedness
2	indebtedness

Petition Text

1,193 words

IN THE DISTRICT COURT OF POTTAWATOMIE COUNTY STATE OF OKLAHOMA Midland Credit Management, Inc. Plaintiff, vs. Kimberly Hibler, 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. CITIBANK, N.A., provided credit to the defendant on account number XXXXXXXXXXXXXX6655. Defendant defaulted on the obligation. The account has been assigned to Plaintiff. 2. Defendant owes Plaintiff $10,829.79. 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 XXXXXXXXXXXXXX9371. Defendant defaulted on the obligation. The account has been assigned to Plaintiff. 2. Defendant owes Plaintiff $5,962.28. An Affidavit of Account is attached hereto and incorporated by reference. WHEREFORE, Plaintiff prays for Judgment against the Defendant in the sum of $16,792.07, 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- AFFIDAVIT OF JENNIFER DITTBERNER Hibler, Kimberly, Defendant(s). Jennifer Dittberner, 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./MY BEST BUY account XXXXXXXXXXXXX6655 (MCM Number 329299905) (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 $10,829.79 as of 2025-12-05. 5. On or about 2024-09-25, Midland Credit Management, Inc became the successor in interest to this Account. 6. MCM's records show that: 1) the Account was opened on 2016-11-07; 2) the last payment posted to the Account on 2023-10-09; and 3) the Account was charged off on 2024-05-16. 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. DEC 29 2025 Date STATE OF MINNESOTA COUNTY OF STEARNS Signed and sworn to (or affirmed) before me on DEC 29 2025 by Jennifer Dittberner. Christy Lynn Biss Notary Public - Minnesota My Commission Expires 01/31/2029 Notary Public STATE OF OKLAHOMA Midland Credit Management, Inc, Plaintiff -vs- Hibler, Kimberly, Defendant(s). AFFIDAVIT OF JENNIFER DITTBERNER Jennifer Dittberner, 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./DOUBLE CASH account XXXXXXXXXXXXX9371 (MCM Number 330956070) (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 $5,962.28 as of 2025-12-05. 5. On or about 2024-12-27, Midland Credit Management, Inc became the successor in interest to this Account. 6. MCM's records show that: 1) the Account was opened on 1997-08-01; 2) the last payment posted to the Account on 2024-04-01; and 3) the Account was charged off on 2024-11-05. 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 DEC 2 9 2025 STATE OF MINNESOTA COUNTY OF STEARNS Signed and sworn to (or affirmed) before me on DEC 2 9 2025 by Jennifer Dittberner. Christy Lynn Biss Notary Public - Minnesota My Commission Expires 01/31/2029 Notary Public OK038