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DELAWARE COUNTY • CS-2026-00138

Midland Credit Management, Inc. v. Heather Clark

Filed: Feb 27, 2026
Type: CS

What's This Case About?

Let’s be honest: we’ve all been there—staring at a credit card bill, wondering how a single Amazon splurge turned into a $4,667.09 debt monster. But for Heather Clark, that monster didn’t just grow teeth—it got a lawyer. And not just any lawyer. A whole army of them, with names so perfectly stacked on the court filing it looks like a law firm’s LinkedIn page exploded. William L. Nixon, Jr., Harley L. Homjak, Daniela Westfahl, Gracelyn Porras Dillingham, Jenifer A Gani, Mariah S. Ellicott, and Benjamin F. Brackett—all descending from Oklahoma City like debt-collecting avengers—to sue Heather Clark for… wait for it… $4,667.09. Yes, that’s right. Seven attorneys (or at least seven names on the letterhead) for a case that wouldn’t even cover the down payment on a used Subaru. Welcome to the wild, wild world of debt collection lawsuits, where the stakes are low, the paperwork is high, and someone in Minnesota is notarizing affidavits about your PayPal credit history like it’s the Zapruder film.

So who is Heather Clark? Honestly, we don’t know much. She’s not represented by a lawyer—at least not yet—and her only known crime, according to the court documents, was opening a PayPal Credit account tied to Synchrony Bank back on October 22, 2023. That’s it. That’s the whole origin story. No dramatic shopping spree, no mysterious midnight charges for rare orchids or a fleet of Segways—just a regular ol’ digital credit line that people use to buy stuff online and pay for it later. Maybe she bought a laptop. Maybe she upgraded her gaming setup. Maybe she finally treated herself to that Peloton after two years of passive-aggressive ads following her across the internet. We’ll never know. What we do know is that she made her last payment on June 15, 2024, and then—poof—radio silence. By January 22, 2025, the account was officially “charged off,” which is banker-speak for “we’ve given up on getting paid, but we’re still gonna come after you anyway.”

Enter Midland Credit Management, Inc.—the financial equivalent of a vulture that waits for banks to declare defeat before swooping in and buying up the debt for pennies on the dollar. These guys don’t create credit cards. They don’t lend money to people buying concert tickets or last-minute luggage. No, Midland’s business model is built on the quiet desperation of overdue accounts. They purchase defaulted debt, slap their name on it, and then—like clockwork—file lawsuits to collect. And collect they do. In this case, they claim Heather owes them $4,667.09, a number so precise it makes you wonder if they added a nickel for emotional distress and seven cents for paperwork trauma.

The legal claim? A “Petition for Indebtedness,” which sounds way more dramatic than it is. In plain English: “Hey, Heather, you didn’t pay your bill. Now we own that debt. Pay us.” There’s no accusation of fraud, no dispute over identity theft, no claim that she maxed out the card buying solid gold cat food. It’s not a breach of contract case. It’s not even a slander suit because she called the credit card company “a soulless algorithm.” Nope. This is as straightforward as civil litigation gets: you borrowed money, you didn’t pay it back, we bought the right to collect it, and now we want our cash. The whole case hinges on an affidavit from Jennifer Dittberner, a Legal Specialist in St. Cloud, Minnesota, who swears—under penalty of perjury—that Midland owns the debt and that the records show Heather owes every penny of that $4,667.09. She didn’t talk to Heather. She didn’t see a contract. She just looked at Midland’s internal records, which include data from Synchrony Bank and Midland’s own collection efforts, and said, “Yep, this looks real.” And in the eyes of the court? That’s enough to file a lawsuit.

Now, let’s talk about the money. $4,667.09. Is that a lot? Well, it’s not nothing. It’s about the cost of a mid-range engagement ring, a year of Netflix subscriptions (if you never left the house), or a single month of rent in certain parts of Manhattan. But in the world of debt collection, it’s not exactly a jackpot either. For Midland, this is just one file in a warehouse full of them. For Heather, it could be devastating—especially if she’s already struggling. But here’s the real kicker: Midland didn’t just send a bill. They didn’t call. They didn’t offer a payment plan. They didn’t even send a strongly worded email. They went straight to court, in Delaware County, Oklahoma, with a seven-lawyer tag team and a notarized affidavit from Minnesota. All for a debt that likely cost them less than $1,000 when they bought it in bulk from Synchrony Bank. That’s the absurd engine of the debt collection industry: scale. One lawsuit might not make much, but when you file thousands of them—each with the same template, the same affidavit, the same robotic precision—the profits add up. And if even half the people settle out of court just to avoid the hassle? Jackpot.

So what do they want? Judgment. That’s the legal term for “we want the court to officially say Heather owes us this money.” If they win, they can garnish wages, freeze bank accounts, or just keep calling until she pays. They’re also asking for “interest at the statutory rate” and “all court costs,” which means Heather could end up owing even more if she loses. And since she’s not represented by a lawyer, the odds are not in her favor. Most people don’t show up to these hearings, either because they don’t understand the system or they’re too embarrassed. And when you don’t show up? The judge usually just says, “Sure, Midland, here’s your judgment.” It’s less a trial and more a paperwork formality.

Now, here’s our take: the most absurd part isn’t the seven attorneys. It’s not even the fact that a woman in Minnesota is swearing under oath about a PayPal debt in Oklahoma. It’s that this entire system runs on automated bureaucracy. No human ever looked Heather in the eye and said, “Hey, you missed a payment.” No one asked if she lost her job, got sick, or just plain forgot. The moment she missed that last payment, her account was digitized, packaged, sold, and eventually handed to a company whose entire business model is suing people for money they probably can’t pay. And the affidavit? It’s not a smoking gun. It’s not even a witness. It’s a Legal Specialist saying, “I looked at the computer, and the computer says she owes money.” And somehow, that’s enough to drag someone into court.

We’re not rooting for anyone to dodge their bills. But we are rooting for a system that doesn’t treat debt like a game of financial hot potato, where companies pass it around until someone sues. We’re rooting for Heather to at least know she’s being sued. We’re rooting for a world where seven lawyers aren’t needed to collect four grand and change. And honestly? We’re rooting for the day when “Petition for Indebtedness” doesn’t sound like a medieval curse, but just a conversation. Until then, grab your popcorn—because in Delaware County, Oklahoma, the debt circus is open for business.

Case Overview

$4,667 Demand Petition
Jurisdiction
District Court of Delaware County, Oklahoma
Relief Sought
$4,667 Monetary
Plaintiffs
Defendants
Claims
# Cause of Action Description
1 Petition for Indebtedness The plaintiff is seeking judgment against the defendant for a debt of $4,667.09.

Petition Text

663 words
25-57982-0 YE1 008 IN THE DISTRICT COURT OF DELAWARE COUNTY STATE OF OKLAHOMA Midland Credit Management, Inc., ) ) ) ) ) No. CS-2026-138 Plaintiff, vs. Heather Clark, ) ) ) ) ) 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 SYNCHRONY BANK obligation with account number XXXXXXXXXXXXXX1173. Defendant defaulted on the obligation. The account has been assigned to Plaintiff. 2. Defendant owes Plaintiff $4,667.09. 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 $4,667.09, 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 Daniela Westfahl, #36242 Gracelyn Porras Dillingham, #35852 Jenifer A Gani, #021876 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 Fax: 405/720-9570 E-Mail: [email protected] STATE OF OKLAHOMA Midland Credit Management, Inc, Plaintiff -vs- Clark, Heather, 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 SYNCHRONY BANK/PAYPAL CREDIT account XXXXXXXXXXXXX1173 (MCM Number 331562808) (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 $4,667.09 as of 2025-12-05. 5. On or about 2025-02-18, Midland Credit Management, Inc became the successor in interest to this Account. 6. MCM's records show that: 1) the Account was opened on 2023-10-22; 2) the last payment posted to the Account on 2024-06-15; and 3) the Account was charged off on 2025-01-22. 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 23 2025 Date STATE OF MINNESOTA COUNTY OF STEARNS Signed and sworn to (or affirmed) before me on DEC 23 2025 by Jennifer Dittberner. 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.