Proof posture
The complaint and later proof should connect the named plaintiff, the account, and the claimed balance with specific facts.
NC has a unique 30-day pre-suit notice requirement for debt buyers under N.C. Gen. Stat. § 58-70-115(6). The notice must include the debt buyer's name/address/phone, original creditor name, original account number, a copy of the contract, and an itemized accounting. The COMPLAINT must allege the notice was sent and incorporate the documents. § 58-70-115 mandates dismissal upon debtor motion OR sua sponte where the complaint fails to comply. The Pounds v. PRA NC class settlement (2024 — 18,000+ class members, $5.75M settlement, ~$35M judgment debt cancelled) arose from PRA's documented practice of filing without § 58-70-115(6) compliance.