In Himes v. Client Services Inc., — F.Supp.2d —-, 2014 WL 24258 (D.N.H. 2014), Judge Barbadoro rejected the contention that the FDCPA requires production of sworn account ledgers during the validation process.
Finally, Himes alleges under § 1692g(b) that Schiff’s method of validation is insufficient because the defendants never produced a sworn accounting ledger, affidavit, or signed loan agreement to prove her legal obligation to pay the sums demanded, and because the “defendants[‘] letter … stated they would provide the creditor’s address and that is also missing from their validation.” Doc. No. 66. She also claims that Schiff violated § 1692g(b) by “not ceasing col-lections after being notified in writing within thirty days of the alleged debt being disputed.” Doc. No. 28. As an initial matter, Himes’s claim regarding a failure to provide the creditor’s address is simply in-correct; the statement that Schiff sent in response to her validation request clearly includes Target’s mail-ing address on the bill payment slip. Doc. No. 66–6. Furthermore, Himes’s belief that validation requires disclosure of the signed loan agreement, a sworn ac-counting ledger, and affidavits attesting to the current status and validity of the debt grossly overstates a debt collector’s obligations under the FDCPA. To sufficiently validate a debt, the debt collector need only demonstrate that the creditor has provided some evidence that the debtor owes the specific amount demanded; a credit card statement indicating the delinquent balance serves that purpose. See, e.g., Fassett v. Shermeta, Adams & Von Allmen, P.C., No. 1:12–CV–36, 2013 WL 2558279, at *6–7 (W.D.Mich. June 11, 2013); Gough v. Bernhardt & Strawser, PA, No. 1:05CV00398, 2006 WL 1875327, at *5 (M.D.N.C. June 30, 2006); Erickson v. Johnson, No. 05–427 (MJD/SRN), 2006 WL 453201, at *7 (D.Minn. Feb.22, 2006). Schiff’s June 4, 2012 letter and the enclosed statement “confirmed in writing the identity of the creditor and the amount which plaintiff owed as of the date of the letter. Nothing more is required under § 1692g.” Fassett, 2013 WL 2558279, at *8 (citing Chaudhry v. Gallerizzo, 174 F.3d 394, 406 (4th Cir.1999); Smith v. Transworld Sys., Inc., 953 F.2d 1025, 1031–32 (6th Cir.1992); Rudek v. Frederick J. Hanna & Assocs., P.C., No. 1:08–cv–288, 2009 WL 385804, at *2 (E.D.Tenn. Feb.17, 2009)). Because the defendants properly validated the debt in the amount demanded, they were free to continue their debt collection activities, including filing suit against Himes in state court.