Consumer complaint received 2025-11-28 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: Faloni Law Group
State: NJ

Complaint narrative:
* * * This is not a duplicate complaint * * * Because I have been sued, and there are active judgements and a writ of execution in regards to said judgement filed, I intend to record these matters through a CFPB complaint, to use as corroborative evidence should any further legal action be taken on my behalf. 

I also intend for all communications to be mediated by the CFPB, so I will not contact Faloni Law Group LLC Directly unless through counsel. 

Treat this complaint as my rebuttal and response to the information furnished in response to the CFPB complaint XXXX, XXXX XXXX XXXX XXXX XXXX XXXX, NJ XXXX Faloni Law Group XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX, NJ XXXX Date : XX/XX/XXXX Re : XXXX XXXX XXXX XXXX XXXX XXXX Bank Defective Chain of Assignment , False Reporting, Procedural Violations, and Immediate Demand for Remedial Action To Whom It May Concern : I am writing regarding the alleged XXXX XXXX XXXX XXXXXXXX XXXX account that your office ( Faloni Law Group LLC ) , on behalf of XXXX XXXX XXXX XXXX claims to be collecting and enforcing. After reviewing the documents provided by your office, the credit reporting furnished by XXXX, and all related information already submitted under CFPB Complaint XXXX, it is clear that multiple violations have occurred involving : Improper and defective assignment ( Attached ) Material inconsistencies in dates and ownership ( Attached ) Furnishing of inaccurate information to XXXX, XXXX, and XXXX  ( Attached ) FCRA, FDCPA, and CDIA Metro 2 violations * * * False representations made in collection and litigation communications ( corroborated by response. ) These violations are significant, and unless immediately remedied, I am compelled to file a Motion to Vacate, Motion to Stay the Writ of Execution, and initiate a counterclaim for damages to the fullest extent possible including sanctions for the alleged violations.

1. Defective Chain of Title & Conflicting Dates Your office provided a Bill of Sale dated XX/XX/XXXX, allegedly transferring ownership of the account from XXXX XXXX XXXX  to XXXX XXXX XXXX. 

However : a. XXXX Is Reporting Ownership Before the Bill of Sale Even Exists * My credit reportfurnished by XXXXlists the XXXX  account as opened around XX/XX/XXXX, three days before the Bill of Sale date of XX/XX/XXXX. 

Therefore, XXXX could not have legally owned, reported, or collected on the debt prior to the date of assignment. 

b. Your Correspondence States an Entirely Different Original Account Opening Date In addition, your letter from Faloni Law Group states that the original account was opened on XX/XX/XXXX. 

These XXXX conflicting timelines can not all be true : XX/XX/XXXX Your offices claimed original account opening date XX/XX/XXXX XXXX 's reported account opening date XX/XX/XXXX LVNVs own Bill of Sale acquisition date This conflict creates a clear break in assignment and constitutes a material defect. 

2. Credit Reporting Violations & Inaccurate Furnishing XXXX XXXX and the credit reporting agencies continue to furnish information that is : Inaccurate Incomplete Contradictory Not supported by documented ownership at the time of reporting Under the FCRA and CDIA Metro 2 guidelines, a data furnisher is required to ensure accuracy and consistency. XXXX reported ownership of an account prior to the documented transfer date, and these inconsistencies remain unresolved despite active disputes already on file. 
This constitutes : FCRA 1681s-2 ( a ) inaccurate furnishing FCRA 1681i failure to properly reinvestigate FDCPA 807 ( 2 ) ( A ) false representation of character or legal status of a debt FDCPA 807 ( 8 ) communicating false credit information 3. FDCPA Violations by Faloni Law Group Your office is now actively enforcing, collecting, and executing on a debt : Whose ownership is not properly established Whose assignment and dates are materially defective Whose reporting contains unresolved inconsistencies Whose transfer documentation contradicts your own claims Attempting to enforce a debt with a defective chain of title and conflicting account information constitutes : False representation of the legal status of the debt ( FDCPA 807 ) Misleading and deceptive means to collect a debt ( FDCPA 807, 808 ) Attempting to collect amounts not legally owed 4. Demand for Immediate Remedy In light of the above, I demand that Faloni Law Group and XXXX XXXX XXXX take the following remedial actions : Cease collection and enforcement activities immediately. 

Withdraw and release any writ of execution currently in place. 

Correct and delete all inaccurate credit reporting by XXXX and affiliated entities. 

Provide accurate, complete, and legally valid documentation evidencing ownership from inception to present. 

Provide a written statement confirming cessation of enforcement and correction of reporting.

5. Notice of Legal Action if Violations Are Not Remedied If these violations are not corrected immediately, I will proceed with : Motion to Vacate Judgment based on defective assignment, improper service, and materially inaccurate representations Motion to Stay and Set Aside the Writ of Execution Formal counterclaim against Faloni Law Group XXXX XXXX XXXX All participating credit reporting agencies Additional complaints filed with the CFPB referencing the already-open complaint XXXX, including updated violations I am prepared to submit all corroborating evidence demonstrating the inconsistencies referenced in this letter. 

Conclusion The defects in assignment, the conflicting dates, and the knowingly inaccurate credit reporting make continued collection or enforcement unlawful. I expect an immediate response confirming that the above issues are being addressed without delay. 

Please govern yourselves accordingly. 

Sincerely, XXXX XXXX

Company response to consumer: Closed with explanation