Midland Credit Management, Inc. v. Marie Rangel

25-58056-0 YE1 008 IN THE DISTRICT COURT OF BECKHAM COUNTY STATE OF OKLAHOMA Midland Credit Management, Inc., ) ) vs. ) No CS-24-347 Marie Rangel, ) 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 THE BANK OF MISSOURI obligation with account number XXXXXXXXXXXXX8751. Defendant defaulted on the obligation. The account has been assigned to Plaintiff. 2. Defendant owes Plaintiff $1,614.54. 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 $1,614.54, 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- AFFIDAVIT OF LUCAS HOFFMAN Rangel, Marie, Defendant(s). Lucas Hoffman, 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 THE BANK OF MISSOURI/KAY JEWELERS account XXXXXXXXXXXXX8751 (MCM Number 331948312) (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 $1,614.54 as of 2025-12-05. 5. On or about 2025-02-25, Midland Credit Management, Inc became the successor in interest to this Account. 6. MCM's records show that: 1) the Account was opened on 2023-08-29; 2) the last payment posted to the Account on 2024-10-27; and 3) the Account was charged off on 2025-01-12. 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 Lucas Hoffman. Karia Ann Sutter Notary Public - Minnesota My Commission Expires 01/31/2029 Notary Public OK038