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CHEROKEE COUNTY • CS-2026-00134

LVNV Funding LLC v. Tomasine Moore

Filed: Mar 9, 2026
Type: CS

What's This Case About?

Let’s cut straight to the drama: a debt collection company is suing a woman in rural Oklahoma for just over a thousand bucks—$1,042.76 to be exactly annoying—and has dispatched a legal army of seven attorneys to make sure the court knows how very serious this is. Seven. For a case that likely involves a maxed-out credit card used to buy, let’s say, an air fryer, some bath bombs, and maybe a questionable Amazon impulse buy or two. This isn’t just a lawsuit. This is corporate overkill set to a soundtrack of overdue interest rates and passive-aggressive affidavits.

Now, meet the players. On one side, we have Tomasine Moore—real person, real life, presumably just trying to survive in Cherokee County, Oklahoma, where the cost of living is low but apparently the legal scrutiny on minor debt is very high. We don’t know much about her, and that’s the point. She’s a name on an account, a Social Security number in a spreadsheet, a defaulted balance in a portfolio. On the other side? LVNV Funding LLC. Sounds like a tech startup, right? Nope. It’s a debt buyer—a company that doesn’t lend money but instead buys up delinquent accounts for pennies on the dollar from original creditors, then sues people to collect the full amount. Think of them as financial vultures with a law degree on retainer. In this case, LVNV claims it now owns Tomasine’s debt, which originally came from Credit One Bank, N.A.—the same bank that aggressively markets credit cards to people with shaky credit, often with sky-high interest rates and fees that balloon faster than a Fourth of July balloon at a fireworks show.

So how did we get here? Picture this: back in March 2020—yes, that March, the one when the world shut down and everyone was panic-buying toilet paper—Tomasine Moore allegedly opened a credit card account with Credit One Bank. Maybe it was for groceries. Maybe it was for car repairs. Maybe it was for emotional support during a global pandemic. We don’t know. What we do know is that at some point, she stopped making payments. Defaulted. Life happened. Job loss, medical bill, flat tire that turned into a financial avalanche—whatever it was, the account went south. Credit One, like most banks, eventually wrote off the debt as a loss. But instead of just forgetting about it, they sold it—along with thousands of other delinquent accounts—to a debt portfolio managed by Credit Asset Sales LLC. Then, in March 2024, that entire portfolio—including Tomasine’s $1,042.76 balance—was sold again, this time to LVNV Funding LLC, or one of its predecessors. And now, two years later, LVNV is back with receipts, affidavits, and a legal team that looks like it’s prepping for a Supreme Court case, not a sub-$1,100 debt claim.

Why are they in court? Because LVNV wants a judgment. And no, we’re not talking about moral judgment—though let’s be honest, there’s a lot to judge here. In legal terms, a judgment means the court officially says, “Yes, Tomasine Moore owes this money,” which then gives LVNV the power to potentially garnish wages, freeze bank accounts, or place liens on property. It’s not just about getting paid—it’s about getting a court stamp of approval so they can get aggressive with collection. The claim? Simple: debt collection. LVNV says Tomasine owes them $1,042.76, plus interest from the date of judgment, court costs, and—get this—a “reasonable attorney’s fee.” So not only might she have to pay over a grand, but she might also have to help pay for the seven-lawyer legal squad that showed up to sue her for it. The audacity is chef’s kiss.

Now, let’s talk about the money. $1,042.76. Is that a lot? In the grand scheme of civil lawsuits, it’s chump change. You could buy a decent used car for ten times that. You could cover a month’s rent in most parts of Oklahoma. But for someone already struggling—someone who likely got a subprime credit card in the first place because they were financially vulnerable—that amount can feel like a boulder on the chest. And here’s the kicker: LVNV probably paid way less than that to acquire the debt. These debt buyers often pay just 3 to 10 cents on the dollar. So LVNV might have paid less than $100 for the right to sue Tomasine for over a thousand. That’s a potential 1,000% return—if they win. This isn’t just debt collection. This is financial speculation dressed up as justice.

And who’s handling this high-stakes financial thriller? LOVE, BEAL & NIXON, P.C.—a debt collection law firm with a name that sounds like a 1950s law firm from a noir film, but with the moral compass of a payday lender. The petition was filed by Gracelyn Dillingham, but listed alongside her? Six other attorneys. Six. For a case that likely hinges on a single affidavit and a credit card statement. Are they all billing hours? Did they draw straws to see who’d handle the “Tomasine Moore vs. The Mountain of Paperwork” case? Or is this just how you roll when you’re a firm that sues thousands of people a year and treats due process like a conveyor belt? The affidavit itself is signed by Janet Cortez, an “Authorized Representative” of LVNV, who swears under penalty of perjury that yes, the records show Tomasine owes this money, and yes, they’ve allowed for all “just and lawful offsets.” But here’s the thing: these affidavits are often boilerplate, signed by people who’ve never met the defendant, never seen the original contract, and are relying entirely on data that’s been sold, resold, and possibly corrupted along the way. In other debt cases across the country, courts have thrown out claims because the debt buyer couldn’t actually prove they owned the debt or that the amount was accurate. But in Cherokee County, Oklahoma, on January 28, 2026, none of that mattered yet. The suit was filed. The machine was activated.

So what do they want? Judgment for $1,042.76. Plus interest. Plus court costs. Plus attorney’s fees. All because Tomasine Moore allegedly didn’t pay off a credit card during, or after, a pandemic. And while that might sound like “she should’ve paid her bill,” let’s not pretend this is about personal responsibility alone. This is about a system that allows banks to issue high-interest credit to vulnerable people, then sell that debt to third parties who use the court system to squeeze every penny they can—often without ever producing the original contract or proving the math adds up. It’s about a legal process that treats a thousand-dollar debt like a felony, with armies of lawyers and stacks of paperwork, while actual crimes go under-prosecuted for lack of resources.

Our take? The most absurd part isn’t that someone owes money. It’s that a company can buy debt for pennies, slap a lawsuit on it, and deploy seven lawyers to chase down a little over a grand—while calling it justice. We’re not rooting for debt evasion. We’re rooting for proportionality. For a system that doesn’t weaponize the courts against the poor. For a world where you don’t need a legal dream team to collect a bill that probably started with a $20 late fee and snowballed into a court case. And honestly? We’re rooting for Tomasine Moore—because if she shows up in court with a single notarized receipt, a solid argument, and the courage to ask, “Prove it,” she might just become the accidental folk hero of the anti-debt-collector resistance. Either way, grab popcorn. This one’s going to be petty. And possibly, just possibly, kind of beautiful.

Case Overview

$1,043 Demand Petition
Jurisdiction
District Court, Oklahoma
Filing Attorney
Gracelyn Dillingham
Relief Sought
$1,043 Monetary
Plaintiffs
Defendants
Claims
# Cause of Action Description
1 Debt Collection Plaintiff seeks judgment against Defendant for debt of $1,042.76

Petition Text

558 words
IN THE DISTRICT COURT OF CHEROKEE COUNTY STATE OF OKLAHOMA LVNV Funding LLC, ) ) ) ) ) ) ) ) Plaintiff, ) No. CS-2026-134 vs. ) Tomasine Moore, ) Defendant. ) PETITION FOR INDEBTEDNESS COMES NOW the Plaintiff, by and through its undersigned attorneys who hereby enter their appearance herein, and for its cause of action against the defendants alleges and states as follows: 1. Credit One Bank, N.A., provided credit to the defendant on account number XXXXXXXXXXXXXXXX4812. The Defendant defaulted on the obligation. The account has been assigned to Plaintiff. 2. Defendant owes Plaintiff $1,042.76. 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 $1,042.76, with interest at the statutory rate from the date of judgment, all court costs and a reasonable attorney's fee, and for such other relief as the Court may deem just and proper. Gracelyn Dillingham William L. Nixon, Jr., #022804 Harley L. Homjak, #019736 Gracelyn Porras Dillingham, #35852 Jenifer A. Gani, #021876 Daniela Westfahl, #36242 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] IN THE DISTRICT COURT IN THE DISTRICT IN AND FOR CHEROKEE COUNTY, OK LVNV Funding LLC Plaintiff vs. Tomasine Moore Defendant(s) PLAINTIFF'S AFFIDAVIT OF INDEBTEDNESS AND OWNERSHIP OF ACCOUNT I am an Authorized Representative for LVNV Funding LLC (hereafter the "Plaintiff"), and hereby certify as follows: 1. I have personal knowledge regarding Plaintiff's creation and maintenance of its normal business records, including computer records of its accounts receivable. This information is regularly and contemporaneously maintained during the course of Plaintiff's business. I am authorized to execute this affidavit on behalf of Plaintiff and the information below is true and correct based on the Plaintiff's business records. 2. In the regular course of business, Plaintiff regularly acquires revolving credit accounts, installment accounts, service accounts, and/or other credit lines or obligations. The records provided to Plaintiff at the time of acquisition are represented to include information provided by the original creditor and/or its successors-in-interest. Such information includes the debtor's name and social security number, the account balance, the identity of the original creditor and the account number. 3. Based on the business records maintained on account XXXXXXXXXXXX4812 (hereafter, the "Account"), which are a compilation of the information provided to Plaintiff upon acquisition and information obtained since acquisition, the Account is the result of the extension of credit to Tomasine Moore by Credit One Bank, N.A. on or about 03/24/2020. Said business records further indicate that the Account was then owned by Credit Asset Sales LLC. Credit Asset Sales LLC later sold and/or assigned Portfolio 43322, which included the Defendant's Account, to Plaintiff or Plaintiff's predecessor(s)-in-interest on 03/21/2024. Thereafter, all ownership rights were assigned to, transferred to and became vested in Plaintiff, including the right to collect the balance owing of $1,042.76 plus any legally permissible interest. 4. Based on the business records maintained in regard to the Account, the above stated amount is justly and duly owed by the Defendant to the Plaintiff and all just and lawful offsets, payments and credits to the Account have been allowed. Demand for payment was made more than thirty days ago. [Signature] Janet Cortez January 28, 2026 The foregoing instrument was acknowledged before me by the above-signed on Wednesday, January 28, 2026. (Notary Public) PLAINTIFF'S AFFIDAVIT OF INDEBTEDNESS AND OWNERSHIP OF ACCOUNT
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