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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. 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
• 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.
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