Consumer complaint received 2025-12-16 00:00:00
Product: Debt collection — Credit card debt
Issue: Took or threatened to take negative or legal action — Sued you without properly notifying you of lawsuit
Company: ENCORE CAPITAL GROUP INC.
State: NJ

Complaint narrative:
MIDLAND FUNDING LLC RE : FORMAL DISPUTE, DEMAND FOR VALIDATION, PROOF OF CLAIM & NOTICE OF LEGAL VIOLATIONS To Whom It May Concern : This letter constitutes my formal and lawful demand for validation of the above-referenced alleged debt. I dispute this account in its entirety. This is not a refusal to pay ; this is a demand for strict proof pursuant to federal and New Jersey law.

You are hereby notified that you must CEASE ALL COLLECTION ACTIVITY until the following validation is provided pursuant to the Fair Debt Collection Practices Act ( FDCPA ), 15 U.S.C. 1692g.

PROVIDE THE FOLLOWING WITHIN 30 DAYS OF RECEIPT : 1. A copy of the original signed agreement or contract bearing my signature.

2. A complete and itemized accounting of the alleged debt, including original balance, interest, fees, penalties, and dates of all charges.

3. The name and full address of the original creditor.

4. Full chain of title showing each assignment, transfer, or sale of the alleged debt from the original creditor to present holder.

5. Proof that your agency is licensed and bonded to collect debts in the State of New Jersey pursuant to the New Jersey Collection Agency Licensing Act ( N.J.A.C. 13:45D et seq. ).

6. Proof that the statute of limitations has NOT expired pursuant to N.J.S.A. 2A:14-1 ( six-year statute of limitations on contractual claims ).

7. Proof you are a holder in due course with legal standing pursuant to UCC 3-301 and 9-203.

NOTICE REGARDING SECURITIZATION STRICT PROOF REQUIRED Due to the documented and widespread practice of securitization of consumer accounts, you are hereby required to provide sworn proof that this alleged account has not been : Securitized Bundled into an asset-backed security Sold to a trust or special purpose vehicle ( SPV ) Written off or insured Claimed as a tax loss Paid through credit default swaps You must provide : 1. A sworn affidavit under penalty of perjury confirming whether or not the alleged account has ever been securitized.

2. The name of any trust, pool, asset-backed security, or SPV in which this account may have been included.

3. Copies of Pooling & Servicing Agreements ( PSAs ), assignments, all bills of sale or transfer, and trust documentation.

4. Copies of any IRS Form 1099-C issued in reference to this alleged account.

5. Proof the alleged debt was NOT paid through any insurance, derivative, or third-party compensation mechanisms.

If securitized, written off, or insured, then this debt has been satisfied and you have NO legal claim.

NEW JERSEY STATE LAW VIOLATIONS ( NOTICE ) Any deceptive or misleading attempts to collect will constitute violations of : New Jersey Consumer Fraud Act N.J.S.A. 56:8-2 ( prohibits deception, fraud, misrepresentation ) New Jersey Administrative Code N.J.A.C. 13:45D ( collection agency licensing requirements and practices ) New Jersey Fair Credit Reporting practices incorporated under FCRA 15 U.S.C. 1681 Federal FDCPA 15 U.S.C. 1692e and 1692f false representation and unfair practices Be advised that any continued collection, reporting or phone contact without proper validation will result in : Formal complaints to the New Jersey Attorney General Complaints to the Consumer Financial Protection Bureau ( CFPB ) Complaints to the Federal Trade Commission ( FTC ) Civil litigation in New Jersey Superior Court seeking : Statutory damages Actual damages Attorneys fees Injunctive relief Credit report deletion You are also hereby instructed under FDCPA 1692c ( c ) to CEASE AND DESIST from : Telephone calls to my home, cell, or workplace Contacting third parties Reporting this account to any credit bureau Selling, transferring, or re-aging this account ALL COMMUNICATION MUST BE IN WRITING ONLY.

Failure to respond with full validation within 30 days will be considered your agreement that : The alleged debt is invalid You lack standing The account is closed Any credit reporting must be permanently deleted GOVERN YOURSELF ACCORDINGLY. 

Sincerely, XXXX XXXX XXXX ______________________________ All rights reserved without prejudice UCC 1-308 / UCC 1-103 My wages have been signicantly garnished without full validation of this debt. I have not signed any documents binding me to this collection agency. How am I suppose to survive in this economy!??

Also, there was invalid information on this suite .

Company response to consumer: Closed with non-monetary relief