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letter to judge brown portfolio recovery case (1)

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PDF page 1

Reina M. Cornelio Martinez 
41 Mary Street 
Carteret, NJ 07008 
Reina-Martha809@Hotmail.com 
March 9, 2026 
The Honorable Jeffrey R. Brown 
Superior Court of New Jersey 
Special Civil Part, Middlesex County 
56 Paterson Street 
New Brunswick, NJ 08903 
RE: Portfolio Recovery Associates, LLC v. Reina M. Cornelio Martinez 
Docket No. MID-DC-015914-25 
Dear Judge Brown: 
I respectfully submit this letter to the Court prior to trial on March 9, 2026, to bring 
three critical factual and legal issues to Your Honor's attention. These issues form the 
foundation of my defense and demonstrate that Portfolio Recovery Associates, LLC ("PRA") 
cannot establish its case by a preponderance of the evidence. 
1. FAILURE TO VALIDATE THE DEBT UNDER FEDERAL LAW 
On November 13, 2025, I sent Portfolio Recovery a formal notice of insufficient 
validation pursuant to the Fair Debt Collection Practices Act, 15 U.S.C. § 1692g. In that 
notice, I specifically demanded: (1) the original signed credit card agreement, (2) a complete 
chain of title from Credit One Bank to Portfolio Recovery, and (3) a full itemized accounting 
of the claimed balance. 

PDF page 2

Portfolio Recovery responded on November 5, 2025, with account statements only. It 
provided no original contract, no bills of sale, and no itemized accounting. The response was 
facially insufficient. 
On February 25, 2026, I sent a second validation demand requiring a response within 
thirty days. That demand remains unanswered as of today, March 9, 2026. Under federal law, 
Portfolio Recovery is prohibited from collecting on an unvalidated debt. By filing suit 
without responding to my validation demands, Portfolio Recovery has committed a willful 
violation of 15 U.S.C. § 1692g. 
2. FAILURE TO PRODUCE CHAIN OF TITLE DESPITE DISCOVERY DEMAND 
On September 17, 2025, I filed a Motion to Compel Discovery requesting that 
Portfolio Recovery produce the complete chain of title from Credit One Bank, N.A. to Credit 
Asset Sales LLC to Portfolio Recovery Associates, LLC, including all bills of sale and 
assignment agreements. 
On October 3, 2025, Portfolio Recovery's attorney responded not by producing 
documents, but by arguing the motion was procedurally untimely. Rather than stating, 'We 
will produce the documents by October 17,' Portfolio Recovery's counsel instead sought to 
delay and avoid production. 
It is now March 9, 2026 — nearly six months after my discovery demand. Portfolio 
Recovery has not produced: 
• The bill of sale from Credit One to Credit Asset Sales 
• The bill of sale from Credit Asset Sales to Portfolio Recovery 

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• The account schedule from the "CreditOne_Fresh_PRA_102024" computer file 
proving my specific account was included in the sale 
Without proof of a complete and unbroken chain of title, Portfolio Recovery lacks 
standing to enforce this debt. A debt collector cannot prove ownership through conclusory 
allegations alone. It must produce actual documentation. Portfolio Recovery has failed to do 
so. 
3. INABILITY TO EXPLAIN A $493.55 UNITEMIZED BALANCE INCREASE 
According to Credit One Bank's September 2024 statement (provided by Portfolio 
Recovery in discovery), my account balance was $792.48. The amount Portfolio Recovery 
now claims is $1,286.03. This represents a $493.55 increase. 
Portfolio Recovery has provided no itemized accounting explaining this $493.55 
increase. The November 5, 2025 validation response contained only statements, with no 
breakdown of which charges, fees, interest, or other amounts compose the disputed $493.55. 
Under New Jersey law and general contract principles, a creditor seeking to enforce a 
debt obligation must prove the amount owed with specificity and itemization. A party cannot 
be held liable for unexamined, unitemized charges. Portfolio Recovery's failure to provide 
this basic accounting is a fatal defect in their case. 
CONCLUSION 
Portfolio Recovery bears the burden of proof in this matter. It must prove, by a 
preponderance of the evidence, that: (1) it owns the debt, (2) the debt is valid and accurate, 
and (3) I am legally obligated to pay it. Portfolio Recovery has failed on all three counts. 

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I respectfully request that Your Honor consider these three critical defects when 
evaluating Portfolio Recovery's case. I stand ready to present evidence at trial supporting 
each of these issues. 
Respectfully submitted, 
_________________________________ 
Reina M. Cornelio Martinez 
Pro Se Defendant 
41 Mary Street 
Carteret, NJ 07008 
Reina-Martha809@Hotmail.com 
Dated: March 9, 2026 
Defendant's Motion to Dismiss is APPROVED WITH PREJUDICE. The Court finds 
that Defendant's moving papers are persuasive. 
Additionally, the Court notes that Plaintiff's "Has NOT demonstrate Proof of debt" 
Plaintiff's Evidence" is without merit.
Hon. Jeffrey R. Brown, J.S.C.
Date_________
March 9, 2026