21 Q Okay. And I wanted to make sure that you
22 had heard the whole question because the question
23 is, is that a -- whether a data file is a
24 compilation of information that's brought under
1 certain indicative information in the form of a
3 A I'm sorry. Can you repeat that?
4 Q Well, let me ask you. What is indicative
6 A I use the term "indicative information" to
7 refer to the consumer's name, address, Social
8 Security number, date of birth.
9 Q Is it accurate to say that data files exist
10 in TransUnion's CRONUS system and are separated by
11 the indicative information that is reported in
12 connection with a certain pool of data?
13 A I'm not -- I'm sorry. I'm not sure I'm
14 following what you're asking.
15 Q Well, let me ask you. How are different
16 data files separated in the TransUnion CRONUS
18 A The files exist individually within the
19 CRONUS database.
20 Q How are they separated? How do you
21 determine when certain pieces of information should
22 be joined together to form a particular data file
23 and when they should not?
24 A The information is all contained together
1 as a single record.
2 Q Globally?
3 A I'm sorry. I'm not sure I understand what
4 you mean.
5 Q What I'm asking you is . . . (sic) place
6 that information into the same data file?
7 MR. CENTO: David, we're -- we're not
8 hearing you.
9 THE WITNESS: It's cutting out, I think,
10 when --
11 MR. CENTO: You're cutting out --
12 THE WITNESS: -- trains are going by.
13 MR. CENTO: And I don't know. Could you
14 repeat what you just said. We didn't get any of
16 MR. Szwak: Okay. Madam Court Reporter,
17 can you hear me okay?
18 THE COURT REPORTER: Well, there was just a
19 pause. There was nothing. The train was going
20 by, and we didn't hear -- we heard the end of
21 it, like four words.
22 MR. Szwak: I was wondering what that loud
23 humming was. The train.
24 MR. CENTO: You got it.
1 BY MR. Szwak:
2 Q What I want to ask you, Ms. Romanowski, is,
3 when information is being reported under
4 TransUnion's CRONUS database system, is it true that
5 TransUnion will place information into certain data
6 files depending upon the indicative information
7 reported with that item?
8 A I'm sorry. I'm not understanding -- I'm
9 not following what you're saying.
10 Q Well, let me ask you to explain to me, how
11 is it that information comes to be in different data
13 A Information is reported to TransUnion. And
14 then based upon a series of different rules, the
15 information is applied to a consumer's file on the
17 Q Do those rules pertain to the indicative
18 information reported in connection with the item?
19 A Yes, I believe they do.
20 Q Well, in essence, if there are a lot
21 of different people with the name Wendy Porter
22 (sic) . . .
23 THE COURT REPORTER: We cannot hear you.
24 MR. CENTO: David, we can't hear you.
2 MR. Szwak: Yes. I was waiting for the
3 train to pass.
4 MR. CENTO: Oh.
5 BY MR. Szwak:
6 Q If there are multiple reports coming into
7 TransUnion of account information pertaining to, for
8 example, Wendy Porter --
9 A I'm sorry. "If there are multiple" -- can
10 you repeat that again? "If there are multiple
12 Q Right. You're familiar with the fact that
13 you may have a number of subscribers reporting
14 account information about a person, one or more
15 persons named Wendy Porter, right?
16 A Yes.
17 Q I mean, there's lots of Wendy Porters in
18 the United States presumably, right?
19 A There may be.
20 Q And each of those persons would have
21 different addresses and different Social Security
22 numbers presumably, right?
23 A Yes.
24 Q And they would have different dates of
1 birth, right?
2 A Possibly, yes.
3 Q Quite possibly. But based upon the
4 personal identification information that is attached
5 to a specific account, that is how TransUnion
6 determines whether to place that information
7 together with other pre-existing information, right?
8 A Yes.
9 Q Now, there's a set of business rules that
10 determine how data is placed into pre-existing data
11 files in the CRONUS system, right?
12 A Yes.
13 Q Or in some cases a new credit file might be
14 created, say, if there's no pre-existing information
15 about that particular consumer, right?
16 A Yes.
17 Q Now, in this case were you able to identify
18 more than one data file that was being brought
19 together and -- and being compiled for the purpose
20 of producing a report in response to an inquiry
21 about the plaintiff?
22 MR. CENTO: Object to the form.
23 A Are you asking if -- again, I'm -- I'm
24 sorry. I'm not following what you're saying.
1 BY MR. Szwak:
2 Q Ms. Romanowski, this -- you -- you are in
3 charge of writing business rules for TransUnion?
4 A Yes.
5 Q Okay. You understand that -- that there
6 are multiple data files that will exist in
7 TransUnion's system that might have the name Wendy
8 Porter, right?
9 A Yes.
10 Q And there might be more than one Wendy
11 Porter in the state of Michigan, correct?
12 A Yes.
13 Q And there might even be more than one Wendy
14 Porter that lives in the same ZIP Code as the
15 plaintiff in this case, correct?
16 A It's possible, yes.
17 Q Did you find any other data files in your
18 review of the records that have been presented to
19 you that show a second data file coming together
20 with the data file of the plaintiff in order to
21 produce a report?
22 A There was a second data file that was
23 reported, but it didn't -- when you say come
24 together, I'm understanding that as combining. And
1 they did not combine. They were reported as
2 separate files.
3 Q Okay. Now, you -- you've indicated that
4 there's a second data file. Let's first identify
5 that data file. Is that the William Porter file
6 that is shown on Exhibit No. 3, actually beginning
7 on Exhibit No. 2, going onto Exhibit No. 3?
8 A There's a William Porter file on Exhibit
9 No. 3.
10 Q Okay. And is that the data file that
11 you're referring to?
12 A Yes.
13 Q Now, when you reviewed that particular data
14 file on William Porter, does it have a different
15 "infile" date than the file on Wendy Porter?
16 A Yes, it does.
17 Q Now, when you review Exhibits 2 and 3
18 together -- and I'll represent to you we've
19 identified that as a subscriber version credit
20 report that was issued to Brighton Ford on the date
21 that's referenced, being November 30th, 2000 -- does
22 that appear to be -- I mean, assuming it was issued
23 to Brighton Ford, does that appear to be a
24 subscriber version format?
1 A Yes, it does.
2 Q Now, when you review the inquiries that are
3 listed in connection with each of those data files,
4 meaning the Wendy Porter file and the William Porter
5 file, did you find consistencies between the
6 inquiries that are posted?
7 A Yes. There are inquiries that are in
8 common between the two files.
9 Q Would it be fair to say that, when these
10 inquiries were being made by these particular
11 subscribers, that TransUnion was producing to those
12 subscribers a report which contained both of the
13 data files, the Wendy Porter data file and the
14 William Porter data file?
15 MR. CENTO: Objection, lack of foundation.
16 A Not necessarily.
17 BY MR. Szwak:
18 Q Do you know that to be a fact or not?
19 A I'm sorry. For what to be a fact?
20 Q That the two files were either being
21 produced or were not being produced.
22 A Each of the files were produced, but I
23 don't know that they were necessarily produced in
24 response to the same inquiry.
1 Q You believe that there would have been one
2 inquiry made on each of those days in the name of
3 Wendy Porter and then a second inquiry for the name
4 William Porter?
5 A It's possible. I don't know what the
6 inquiry input information is.
7 Q Define the inquiry input information or
8 what we call the terminal audit trail.
9 A I -- I'm not familiar with the term
10 "terminal audit trail," but inquiry input
11 information is the information that's supplied to
12 TransUnion that -- on behalf of the consumer, the
13 consumer's name, address, Social Security number,
14 date of birth.
15 Q Now, when a subscriber makes an inquiry,
16 they're not necessarily required to input complete
17 consumer identification; is that true?
18 MR. CENTO: Objection to form.
19 A They're required to input the consumer's
20 first name, last name, and current address.
21 BY MR. Szwak:
22 Q Okay. Can they make an inquiry without
23 putting the consumer's address in?
24 A No.
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