No, that statement, "Defendant’s breach has damaged Plaintiff in the amount of..." is NOT untrue on its face. Here's why:
1.) When a plaintiff makes a demand in damages, the prayer (request to the court) can be whatever figure they want it to be. What the court will actually grant the plaintiff as damages IF they win is another matter entirely.
2.) "Assumption of risk" notwithstanding, the law as it stands allows a successor in interest--the JDB here--the ability to collect the full amount of the alleged debt, no matter whether it was bought at a discount (for less than the face value of the debt) or not.