7 Q. Based upon the notes that you made regarding a
8 possible mixed file, is it your belief that you would have
9 reviewed the credit report to make that determination?
10 MR. McLOON: Same two objections.
11 A. I'm sorry, could you restate that question?
12 MR. Szwak: Could you read it back, please?
13 (Record read.)
14 A. Yes.
15 Q. Now, when you review a credit file to try to
16 determine whether there's perhaps identity theft or a mixed
17 file scenario or maybe some other scenario causing the disputed
18 data to appear in the file, do you have some guidelines that
19 you follow in reviewing the credit report to make that
21 A. There are certain things you look for in the
22 consumer's credit report.
23 Q. What type of things do you personally look for when
24 you're trying to determine whether it's a mixed file or a
25 possible mixed file?
1 A. DNC, do not combine, or a Social variation.
2 Q. If the credit file contained more than one Social
3 Security number recorded in it, would that be an indication to
4 you that maybe it was mixed together with a different consumer?
5 MR. McLOON: Objection, incomplete
6 hypothetical. You may answer.
7 A. That is possible.
8 Q. Now, a do not combine statement would be an
9 indication that a prior Experian representative before you saw
10 the file, had made some determination of a possible mixed file
11 scenario, and had marked the file not to be combined with other
12 files; is that correct?
13 A. I do not know about how they add the DNC in the log.
14 Q. Are you able to add a do not combine statement to a
15 credit file?
16 A. No, I am not.
17 Q. What do you do with a file once you determine that
18 it's a possible mixed file?
19 A. I would transfer it to the appropriate department.
20 Q. Now, you say transfer it to an appropriate
21 department, what department would that be?
22 A. It would be our mixed file team.
23 Q. It's a mixed file team or is that a department?
24 A. I just put it in mixed, and they get transferred by
25 our -- the appropriate individuals.
1 Q. Do you know any of the people in the mixed file
3 A. I do not know them personally, no.
4 Q. So you would just mark the file as a possible mixed
5 file and transfer it to the other division to be handled?
6 A. Yes.
7 Q. Just from the notes that you have recorded there, as
8 you sit here today, you don't know whether you saw a do not
9 combine or whether you saw a Social Security variation; is that
11 A. I would not be able to tell by looking at these
13 Q. Yes, sir. In your job at Experian, when you form an
14 opinion that possibly there's a mixed file, do you have the
15 ability to pull a 7X report?
16 A. That is the report we would look at.
17 Q. Are you able to look at the specific personal
18 identification data that is reported with each separate trade
19 line or public record item?
20 A. I can see their complete report as of the date that
21 I pulled it.
22 Q. Yes, sir. What I'm asking you is: If you have an
23 opinion that you possibly have a mixed credit file, maybe the
24 consumer's letter hints that there's information in this credit
25 file that doesn't pertain to him, and you review the 7X report,
1 do you look at the specific name and address row tables to
2 determine how the different data is being reported?
3 A. We look at the entire report.
4 Q. Is there -- are there any guidelines provided to
5 you, any rules by Experian, as to what you should do if you
6 find that the name and address row tables have different
7 identities listed in them?
8 MR. McLOON: Objection, vague, incomplete
10 A. Can you be specific in your question?
11 Q. Well, do you know what the name and address rows are
12 on a 7X report?
13 A. Yes.
14 Q. Is it accurate to say that a 7X report is
15 essentially a consumer's credit file, but it's expanded to
16 provide more information about how each trade log, each inquiry
17 and each public record are reported in to Experian; is that
19 A. Yes.
20 Q. Now, if you thought that perhaps there was a mixed
21 file scenario such as Mr. Carriere, do you have the ability to
22 go in and look at each of the trade lines or each of the public
23 record items and even the inquiries to see how they were
24 presented to Experian?
25 MR. McLOON: Objection, no foundation. You
1 may answer.
2 A. I'm still not understanding your question, what you
3 mean by that, sir.
4 Q. Okay. Well, let me ask you again. I think we agree
5 that a 7X report has more detail in it than a disclosure, in
6 essence, you can see behind the data and see, for example, how
7 a bankruptcy was reported to Experian in terms of the name,
8 address and/or Social Security number; is that true?
9 MR. McLOON: Objection, that assumes facts not
10 in evidence, and there's no foundation for this witness to
11 testify about how data is reported to Experian.
12 You may answer.
13 A. Like I say, I can see the whole report.
14 MR. Szwak: Ms. Court Reporter, can you please
15 read back my question?
16 (Record read.)
17 MR. McLOON: You did get the answer, right?
18 THE REPORTER: I have an answer.
19 MR. McLOON: Yeah. Okay. Let's pose another
21 MR. Szwak: I need to get an answer to that
22 one, I'm sorry.
23 MR. McLOON: I think he did answer it. You
24 don't like the answer, but he answered it, so let's just pose
25 another question.
1 Q. We have a disagreement, so what I'll do is try to
2 ask you the same question a little differently and see if we
3 can meet on common ground.
4 The 7X report contains the name and address
5 rows, which can then be reviewed, and you can decide how
6 certain trade lines were reported in to Experian; is that true?
7 MR. McLOON: That assumes a fact not in
8 evidence, and there's no foundation for the witness to testify
9 about how data is reported to Experian. You may answer.
10 A. I -- like I said, I can only see what information is
11 on the report. I do not know how it gets reported to Experian.
12 Q. You don't know the mechanics of how it got to be in
13 the credit file; is that true?
14 A. I do not know the mechanics of how it gets to the
Father-Son, Mother-Daughter, Junior-Senior-Trey [Generational Designators], Common Names, Variations on Social Security Numbers and Other Mixed File Issues
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- The Mechanics of Credit Reporting
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