Consumer complaint received 2025-12-09 00:00:00
Product: Debt collection — I do not know
Issue: Written notification about debt — Didn't receive enough information to verify debt
Company: ENCORE CAPITAL GROUP INC.
State: NY

Complaint narrative:
I am writing in response to your summons and complaint dated XX/XX/XXXX, filed in the XXXX XXXX XXXX XXXX XXXXXXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX, under Index No. XXXX, regarding alleged debts you claim I owe originating from XXXX XXXXXXXX XXXX XXXXXXXX XXXX XXXX XXXX and XXXX. This is a formal, unequivocal demand for debt validation under the Fair Debt Collection Practices Act ( FDCPA ), 15 U.S.C. 1692g, the Fair Credit Reporting Act ( FCRA ), 15 U.S.C. 1681 et seq., New York General Business Law ( GBL ) 349 and 601, the New York Consumer Credit Fairness Act ( CCFA, CPLR 213-a ), New York City Administrative Code 20-490 et seq. ( requiring licensing by the NYC Department of Consumer Affairs ), and Title 23 NYCRR Part 1 ( New York State Department of Financial Services regulations governing debt collection practices ). I invoke every single one of my rights under these federal and state laws, including but not limited to the right to dispute, validate, and cease all abusive or deceptive collection activities.

I dispute the validity, amount, and your legal right to collect these alleged debts in their entirety. I do not recognize these debts, and I demand that you IMMEDIATELY CEASE AND DESIST ALL COLLECTION ACTIVITIES, including but not limited to the pending lawsuit, any further court filings, phone calls ( harassing, compulsive, or otherwise ), emails, letters, texts, in-person contacts, third-party communications, credit reporting, or any other form of harassment or intimidation. Under FDCPA 1692c ( c ), this letter serves as my formal notice to cease all communications except as explicitly permitted by law ( e.g., to provide validation or notify of specific actions ). Failure to comply will constitute willful violations, exposing you to statutory damages of up to {$1000.00} per violation ( plus actual damages, punitive damages, and attorney fees under FDCPA 1692k ), civil penalties of up to {$5000.00} per offense under NY GBL Article 29-H and Title 23 NYCRR Part 1, and additional remedies under FCRA for inaccurate reporting ( up to {$1000.00} statutory damages per violation, plus actual and punitive damages under 15 U.S.C. 1681n ). I will report all violations to the Consumer Financial Protection Bureau ( CFPB ), Federal Trade Commission ( FTC ), New York Attorney General, New York Department of Financial Services ( DFS ), and NYC Department of Consumer and Worker Protection ( DCWP ), and I will pursue private lawsuits, including class actions if applicable, for maximum damages, costs, and fees.

You must provide, WITHOUT DELAY AND IN FULL, EVERY SINGLE PIECE of the following information and documentation to validate these alleged debts. Do not withhold, redact, or provide partial, incomplete, or evasive responsesanything less than 100 % compliance will be deemed a refusal to validate, a deceptive practice under NY GBL 349, and a direct violation of federal and state law, triggering immediate legal action against Midland Credit Management , Inc., its agents, and attorneys ( Pressler, Felt & Warshaw, LLP ) : The full name, physical address ( XXXX XXXX XXXX XXXX XXXX  phone number, email, website, and any alternative names, DBAs, or affiliates of the current creditor ( Midland Credit Management , Inc. ) to whom the debts are allegedly owed, along with the exact account numbers you use, the precise current amounts owed for each account ( broken down item by item into principal, interest, fees, penalties, and any other charges ), and proof of your active licensure as a debt collector in New York State and New York City ( including NYC DCA License XXXX XXXXXXXX or XXXX updates, with confirmation from XXXX that it is current and in good standing ). 
For each alleged debt, the full name, physical address, phone number, and any alternative names or DBAs of the original creditor ( XXXX XXXX XXXX  ), the original account numbers, the exact amounts owed at the time of any transfer or assignment, the precise dates of each transfer/assignment, and irrefutable proof of the complete chain of title, including all bills of sale, assignment agreements, dates, amounts paid/received, parties involved ( with signatures and notarizations ), and any bulk sale documentation showing these specific accounts were included. Under the CCFA, you must prove valid assignment beyond mere affidavits. 
Complete, unredacted copies of the original written credit agreements or contracts for each account that allegedly created my obligation to pay, personally signed by me, including all terms, conditions, interest rates, fee schedules, privacy notices, and any amendments, addendums, or modifications. If no signed agreements exist, provide a sworn explanation detailing why, along with alternative ironclad proof of the debts ' origins, such as application forms, approval letters, and initial transaction records. 
If either debt is based on identity theft, error, fraud, co-signer liability, or any third-party obligation, fully identify that person or entity ( name, address, XXXX last XXXX digits if applicable, relationship to me ) and provide exhaustive documentation proving why I am legally responsible, including any investigations, police reports, or affidavits related to disputes. 
A hyper-detailed, chronological breakdown of the amounts and ages of each debt, including : Copies of the last billing statements from the original creditor ( XXXX XXXX XXXX  XXXX for each account. 
The exact amounts of the debts when you acquired them, the acquisition dates ( allegedly XX/XX/XXXX ), and a full, itemized ledger history from account opening to present, listing every single charge, payment, credit, interest accrual ( with APR calculations ), fee ( with explanations ), and adjustment, with exact dates, amounts, and supporting receipts or records. 
The precise dates of alleged defaults ( not just last payments on XX/XX/XXXX ), the applicable statute of limitations under New York law ( 3 years for consumer credit debts per CCFA/CPLR 213-a, not XXXX XXXXears as falsely claimed in your complaint ), and concrete proof that these claims are not time-barred, including any tolling arguments with legal citations. 

Verification and documentation proving a valid legal basis for your claims, including but not limited to : Proof of your legal authority to collect these debts in New York, including compliance with Title 23 NYCRR Part 1 ( e.g., required disclosures, no abusive practices ) and any DFS registrations.

All prior correspondence, notices, validation letters, dunning notices, or communications related to these debts from the original creditor or any prior assignees to me, including dates sent and proof of receipt. 
Any judgments, court orders, arbitration awards, or legal filings related to these debts, including proof none exist.

Proof that these debts have not been discharged in bankruptcy, settled, paid off, disputed successfully, or otherwise resolved, with searches from relevant courts and credit bureaus.

If reported to credit bureaus, copies of all reports furnished under FCRA, with proof of accuracy and investigations of any prior disputes.

Sworn affidavits from persons with direct, personal knowledge ( not robo-signed or from hearsay ) attesting to the accuracy, completeness, and authenticity of ALL provided information and documentation, including their full names, titles, employer, contact information, and how they acquired said knowledge. Under CCFA, affidavits must meet strict evidentiary standards for court use. 
Any and all other records, logs, notes, audio/video recordings ( including call recordings ), internal memos, emails, system data, payment histories, dispute logs, or electronic files related to these accounts, from inception to present, without redaction. 
Proof of compliance with all pre-suit requirements under the CCFA, including the mandatory XXXX notice for out-of-statute debts ( if applicable ), itemized affidavits of facts, and certification that the action is not time-barred. 

Until you provide EVERY ITEM listed above in full, without exception or delay, you are STRICTLY PROHIBITED from any further contact or collection efforts, including advancing the lawsuit ( I demand you file a stipulation of discontinuance immediately if validation fails ). This includes NO reporting or updating to credit bureaus ( XXXX XXXX XXXXn ) under FCRA 1681s-2, as any inaccurate or unvalidated reporting will trigger disputes and deletion demands, with liability for willful noncompliance. Any violation will be documented and used as evidence in complaints and lawsuits. 
Send all validation materials to my address above via certified mail with return receipt requested, and provide tracking numbers in advance. I expect full compliance within 30 days ( or sooner if required by law ). Failure will result in my filing motions to dismiss your lawsuit for lack of standing and evidence, demanding immediate deletion from credit reports under FCRA 1681i, and pursuing all damages, including emotional distress, credit harm, and legal fees.

Company response to consumer: Closed with explanation