Proof posture
The complaint and later proof should connect the named plaintiff, the account, and the claimed balance with specific facts.
Virginia debt buyers must prove an unbroken chain of title that SPECIFICALLY identifies your account, not a generic portfolio bill of sale — Green v. Portfolio Recovery Assocs., 909 S.E.2d (Va. Ct. App. en banc Dec. 17, 2024). Frame the attack as evidentiary sufficiency at trial, not pleading-stage standing. Va. Code § 8.01-380(D) is the killer move: once you file a counterclaim arising from the same transaction (FDCPA, etc.), the debt buyer CANNOT voluntarily dismiss and refile — the case is locked in.