CS-2026-00059 - CAVALRY SPV I, LLC, AS ASSIGNEE OF CITIBANK, N.A. v. CURTIS W HAMILTON

What's This Case About?

Let’s be honest: nobody tunes into a civil court drama expecting Shakespeare. But sometimes, the sheer bureaucratic audacity of a debt collection lawsuit makes you wonder if the whole thing was written by a robot that only knows two emotions—demand payment and file motion. And in Garvin County, Oklahoma, we have just such a case: a corporate entity named Cavalry SPV I, LLC—which sounds less like a company and more like a rejected boy band from the early 2000s—is suing a man named Curtis W. Hamilton for $2,573.69, a sum so specific it feels like they added the 69 cents just to prove they did the math. This isn’t a murder mystery. There’s no missing body. No secret affair. Just a credit card bill, a chain of corporate handoffs longer than a Game of Thrones family tree, and a DMDC military status check so thorough it could double as a background check for a presidential pardon.

So who are these people? On one side, we’ve got Cavalry SPV I, LLC, a debt-buying firm based in Connecticut—Greenwich, to be exact, which is basically the Hamptons of hedge funds. These guys don’t lend money. They buy debt. Like vultures at a financial carcass, they swoop in after banks write off unpaid balances, purchase them for pennies on the dollar, and then sue to collect the full amount. It’s not illegal. It’s not even particularly shady by industry standards. But it is cold. And impersonal. And their entire business model runs on the fact that most people either ignore the lawsuit or can’t afford a lawyer. On the other side? Curtis W. Hamilton, a man living in a rental unit in Maysville, Oklahoma—a town so small it makes a Walmart the size of a football field feel like a skyline. We don’t know much about Curtis, except that he once opened a Home Depot credit card through Citibank, presumably to buy a power washer or a $400 drill he swore he’d use “all the time.” Somewhere along the way, the payments stopped. And now, years later, the paper trail has led to this: a lawsuit filed by a company that didn’t lend him a dime, suing him for money he may or may not remember borrowing.

Here’s how we got here. At some point—probably years ago—Curtis Hamilton used a Citibank-issued Home Depot credit card. He charged stuff. He made some payments. Then, either due to hard times, forgetfulness, or the universal human flaw of “I’ll deal with it later,” the account went south. Citibank, like any bank, has a process for delinquent accounts: first, they hound you with calls. Then they charge off the debt—meaning they write it off as a loss for tax purposes. But that doesn’t mean the debt disappears. Oh no. It gets sold. And that’s where Cavalry SPV I, LLC comes in. They bought the debt—likely for a few hundred bucks—and now they’re stepping into Citibank’s shoes, legally speaking, to sue Curtis for the full balance: $2,573.69. That’s the number. That’s the grail. That’s what this entire legal drama hinges on.

But here’s where it gets weirdly dramatic: before they could even file the lawsuit, Cavalry’s lawyers had to prove Curtis isn’t in the military. Why? Because of the Servicemembers Civil Relief Act (SCRA)—a federal law designed to protect active-duty troops from being sued while defending the country. Under the SCRA, courts can delay or even dismiss cases against service members, and creditors who violate the law can face serious penalties. So to cover their bases, Cavalry’s attorney, Dan G. Young of Jenkins & Young, P.C., ran Curtis’s name, Social Security number, and birthdate through the Defense Manpower Data Center (DMDC)—basically the Pentagon’s official military database. And what did they find? A big, bold “No” across the board. Curtis W. Hamilton is not on active duty. Hasn’t been in the last 367 days. Wasn’t notified of a future call-up. The certificate even comes with a little disclaimer that reads like a legal fortune cookie: “If you have evidence the person was on active duty… punitive provisions of the SCRA may be invoked against you.” It’s like they’re saying, “We checked. But if he secretly joined the Space Force last week, we’re not liable.” The whole thing is so meticulously paranoid it feels like overkill—until you remember that one misstep could cost the plaintiff way more than $2,500.

So why are they in court? Legally, this is a “Petition on Account and Money Lent”—a fancy way of saying, “You owe us money, and we have paperwork to prove it.” Cavalry isn’t accusing Curtis of fraud. They’re not claiming he burned down a shed full of appliances. They’re just saying: the debt exists, it was assigned to us, and you never paid it. In plain English? This is a debt collection lawsuit. The kind that clogs up county courts across America every single day. No witnesses. No drama. Just a plaintiff with an assignment agreement and a defendant who probably didn’t even know he was being sued until the papers showed up.

And what do they want? $2,573.69—plus interest, court costs, and attorney’s fees. Is that a lot? In the grand scheme of civil lawsuits, it’s barely a blip. It’s less than the average American spends on coffee in a year. It’s the cost of a decent used car down payment. Or a really nice mattress. But for someone living in a rental unit in Maysville, it could be everything. And here’s the kicker: Cavalry probably paid way less than that to buy the debt. Maybe $500. Maybe less. So even if they win, this isn’t about justice. It’s about margins. It’s about volume. It’s about filing hundreds of these cases a month and banking on the fact that most people won’t show up to court.

Our take? The most absurd part isn’t the amount. It’s the theater of it all. We’ve got a Connecticut-based debt buyer using a Texas law firm to sue an Oklahoma man over a Home Depot credit card, and the whole thing kicks off with a military status certificate from the Department of Defense that reads like a classified Pentagon memo. It’s Wild West capitalism meets federal bureaucracy in a county courthouse that probably has a soda machine that still takes pennies. And yet, at the center of it all is a real person—Curtis Hamilton—who may have no idea this is happening, or worse, knows exactly what it means and just can’t afford to fight it. We’re not rooting for debt collectors. We’re not rooting for deadbeat spenders. But if Curtis shows up in court with a receipt from 2019 proving he paid the balance in full and the paper trail got lost in some Citibank server farm, we’ll be screaming from the cheap seats. Because sometimes, the most satisfying courtroom moment isn’t a guilty verdict—it’s a judge saying, “Case dismissed,” and watching a corporate debt collector quietly pack up their briefcase, defeated by a single piece of paper.

Case Overview

$2,574 Demand Petition

Jurisdiction

District Court, Oklahoma

Filing Attorney

Dan G. Young

JENKINS & YOUNG, P.C.

Relief Sought

$2,574 Monetary

Plaintiffs

CAVALRY SPV I, LLC, AS ASSIGNEE OF CITIBANK, N.A. business
Rep: JENKINS & YOUNG, P.C.

Defendants

CURTIS W HAMILTON individual

Claims

#	Cause of Action	Description
1	Petition on Account and Money Lent	Defendant owes Plaintiff the sum of $2,573.69 according to a credit agreement assigned to Plaintiff by Citibank, N.A./The Home Depot.

Petition Text

1,401 words

IN THE DISTRICT COURT OF GARVIN COUNTY STATE OF OKLAHOMA CAVALRY SPV I, LLC, AS ASSIGNEE OF CITIBANK, N.A. Plaintiff v. CURTIS W HAMILTON Defendant PETITION ON AN ACCOUNT AND MONEY LENT TO THE HONORABLE JUDGE OF SAID COURT: Plaintiff, CAVALRY SPV I, LLC, AS ASSIGNEE OF CITIBANK, N.A. files this Petition on Account and Money Lent, and in support thereof will show the Court as follows: I. Plaintiff is CAVALRY SPV I, LLC, AS ASSIGNEE OF CITIBANK, N.A., whose business address is 1 American Lane, Suite 220, Greenwich CT 06831. Defendant is Curtis W Hamilton, who may be served with process at 910 N Mays Unit 294, Maysville OK 73057. II. Defendant owes Plaintiff the sum of $2,573.69 according to a credit agreement assigned to Plaintiff by Citibank, N.A./The Home Depot. Defendant promised to pay, but failed to do so. WHEREFORE, Plaintiff demands judgment against Defendant for the sum of $2,573.69, plus interest and costs including reasonable attorney's fees. Respectfully submitted, JENKINS & YOUNG, P.C. P.O. Box 420 Lubbock, Texas 79408-0420 Telephone: (806) 687-9172 Facsimile: (806) 771-8755 Email: [email protected] By: _______________________ Dan G. Young Oklahoma State Bar No. 20915 ATTORNEYS FOR PLAINTIFF IN THE DISTRICT COURT OF GARVIN COUNTY STATE OF OKLAHOMA CAVALRY SPV I, LLC, AS ASSIGNEE OF CITIBANK, N.A. Plaintiff v. CURTIS W HAMILTON Defendant STATE OF OKLAHOMA GARVIN COUNTY SS. FILED MAR 12 2026 AT 531 O'CLOCK M. LAURA LEE, Court Clerk BY DEPUTY NO. CS-246-59 SWORN DECLARATION AS TO MILITARY SERVICE In compliance with the Service Members Civil Relief Act, 50 App. U.S.C. § 521 et seq., I, the undersigned Plaintiff, state that the following facts are true: ☐ Defendant, Curtis W Hamilton, is in military service. I have attached all relevant documentation and information to support this declaration. ☑ Defendant, Curtis W Hamilton, is not in military service. I have attached all relevant documentation and information to support this declaration. ☐ I am unable to determine whether or not the Defendant Curtis W Hamilton, is in military service. I state under penalty of perjury under the laws of Oklahoma that the foregoing is true and correct. Dated this ___6___ day of March, 2026. CAVALRY SPV I, LLC, AS ASSIGNEE OF CITIBANK, N.A. PLAINTIFF Dan G. Young Oklahoma State Bar No. 20915 ATTORNEYS FOR PLAINTIFF Status Report Pursuant to Servicemembers Civil Relief Act SSN: XXX-XX-5884 Birth Date: Aug-XX-1975 Last Name: HAMILTON First Name: CURTIS Middle Name: W Status As Of: Mar-02-2026 Certificate ID: JN3RNS7Z5PWLNWV <table> <tr> <th colspan="3">On Active Duty On Active Duty Status Date</th> <th>Service Component</th> </tr> <tr> <td>Active Duty Start Date</td> <td>Active Duty End Date</td> <td>Status</td> <td></td> </tr> <tr> <td>NA</td> <td>NA</td> <td>No</td> <td>NA</td> </tr> <tr> <td colspan="4">This response reflects the individuals' active duty status based on the Active Duty Status Date</td> </tr> </table> <table> <tr> <th colspan="3">Left Active Duty Within 367 Days Of Active Duty Status Date</th> <th>Service Component</th> </tr> <tr> <td>Active Duty Start Date</td> <td>Active Duty End Date</td> <td>Status</td> <td></td> </tr> <tr> <td>NA</td> <td>NA</td> <td>No</td> <td>NA</td> </tr> <tr> <td colspan="4">This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date</td> </tr> </table> <table> <tr> <th colspan="3">The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date</th> <th>Service Component</th> </tr> <tr> <td>Order Notification Start Date</td> <td>Order Notification End Date</td> <td>Status</td> <td></td> </tr> <tr> <td>NA</td> <td>NA</td> <td>No</td> <td>NA</td> </tr> <tr> <td colspan="4">This response reflects whether the individual or his/her unit has received early notification to report for active duty</td> </tr> </table> Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, Space Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 3901 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service. Service contact information can be found on the SCRA website's FAQ page (Q35) via this URL: https://scra.dmdc.osd.mil/scra/#/faqs. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 3921(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided.