Experian's Mixed File Procedures

Father-Son, Mother-Daughter, Junior-Senior-Trey [Generational Designators], Common Names, Variations on Social Security Numbers and Other Mixed File Issues
David A. Szwak

Experian's Mixed File Procedures

Postby David A. Szwak » Mon Nov 21, 2005 9:10 pm

1
1 IN THE UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF TEXAS
2 SHERMAN DIVISION
3 JAMES E. JENSEN, *
*
4 Plaintiff, *
* CIVIL ACTION
5 VS. * NO. 00-CV-0040
*
6 EXPERIAN INFORMATION SOLUTIONS, INC.*
*
7 Defendant. *
8
9 *********************************************************
10 ORAL AND VIDEOTAPED DEPOSITION OF CAROLYN HELM
11 AUGUST 16, 2000
12 VOLUME 1
13 *********************************************************
14
15
16 ANSWERS AND DEPOSITION OF CAROLYN HELM, produced as a
17 witness duly sworn by me at the instance of the Plaintiff,
18 taken in the above-styled and -numbered cause on the 16th
19 day of August, 2000, A.D., beginning at 9:54 a.m. to 2:29
20 p.m., before LISA C. HUNDT, a Certified Shorthand Reporter
21 in and for the State of Texas, reported by machine
22 shorthand, in the offices of Jones, Day, Reavis & Pogue,
23 located at 2727 North Harwood, Dallas, Texas, in accordance
24 with the Federal Rules of Civil Procedure and the
25 agreements hereinafter set forth.

87
21 Q. Okay. The -- I think where I had left off
22 earlier, before I had sort of digressed through this, I had
23 asked you about the assertion in the pleadings about the --
24 Experian's procedure to investigate fraud or identity theft
25 disputes. You told me this is not a fraud case; we don't

88
1 need to discuss that. Let's talk about what it is, a mixed
2 file case.
3 What are the procedures at Experian when you identify
4 something as a mixed file? Let's start with just an
5 incoming mail or incoming telephone call dispute that
6 appears to Experian to be a mixed file matter.
7 A. Well, there are typically clues that would
8 indicate that there is a possible mix on the file, and we
9 talked about variances in name; different addresses,
10 although that is not all-inclusive in that if that's the
11 only sign; different social security numbers. So based on
12 the expertise of the agent and the mixed file agent, they
13 can determine whether the file is mixed.
14 Q. Okay. Now, just because two names vary, that's
15 not as big an issue because people get married and people
16 change their names, right?
17 A. Yeah, and there are Jim and James.
18 Q. And people's addresses change because they move
19 around?
20 A. Yes.
21 Q. Social security number, ordinarily, with the
22 exception of unusual circumstances, does not change.
23 A. That's true.
24 Q. And date of birth doesn't change under any
25 circumstance.

89
1 A. That's true, although there are variances
2 sometimes in reporting.
3 Q. The -- I gather that, from time to time, you have
4 problems with people not using generational codes, maybe
5 junior, senior, the third, et cetera?
6 A. That's true.
7 Q. In this particular case, the variances that we're
8 able to see from the admin report involved differing
9 addresses and, you've indicated, some differing names?
10 A. That's true.
11 Q. And different social security numbers?
12 A. That's true.
13 Q. Now, once a variance is identified, in essence,
14 you've got a good idea it's not a fraud case because it's
15 not the same social security or a close permutation of the
16 same social being used, and you've identified it as being
17 mixed file, what procedures are used at that point to help
18 the consumer unwind the matter?
19 A. Well, based on what the consumer has provided to
20 us and the clues he, himself, has given us, we proceed to
21 match up, trade information and address information that
22 the consumer has indicated is not his, or social security
23 number that he's indicated is not his. And if we can
24 clearly see from the file that we can move or delete
25 certain trade information, we will do that.

90
1 If the consumer has been specific as far as accounts
2 and what's wrong with it, we'll go based on that as well.
3 If we are unable to determine -- if the consumer has been
4 explicit in saying, "This account, this account, this
5 account," are not his, and we are unable to determine
6 through the clues, the name and social security rolls, the
7 social security number, et cetera, then we will send out an
8 investigation through verification form.
9 Q. So if I understand correctly, before it triggers a
10 reinvestigation at Experian, there must be a consumer
11 dispute by someone who is affected?
12 A. Yes, consumers.
13 Q. Experian would not take it upon itself to
14 determine whether or not there are merged files within its
15 system?
16 A. That's true.
17 Q. So once a consumer determines that their file
18 contains inaccurate information, it is incumbent upon them
19 to contact Experian and raise some dispute about the
20 accuracy of the information?
21 A. Yes. We have --
22 Q. That's the policy and procedure and the position
23 of Experian?
24 A. Yes. We have, already, checks and balances in
25 place to try to prevent the mixed files. So if one does

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1 occur, we are relying on the consumer to give us that.
2 Q. Do you know whether it has ever been suggested
3 that the inquiry format provided to the subscribers
4 contributes to the mixed file problem?
5 A. Yes.
6 Q. Who have you heard that from?
7 A. Well, I believe that there has been changes over
8 the years to request that subscribers use full
9 identification information.
10 Q. To request?
11 A. Yes.
12 Q. But it is not required?
13 A. There are certain fields -- over the years, those
14 fields have grown from name and address to name and address
15 and social. And it's -- it's a field that we strongly
16 encourage but do not always require because creditors don't
17 always have all of the information. Consumers don't always
18 like to give all of their information.
19 Q. But you would agree with me that Experian solely
20 controls the requirements of the inquiry input fields?
21 A. I don't -- I don't know if I would agree with that
22 statement.
23 Q. Tell me what you would not agree with about that
24 statement.
25 A. I would agree that -- I would restate it. I would

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1 say that Experian requests and indicates to its subscribers
2 how important the information is -- the identification
3 information is in retrieving an accurate file. It's to the
4 best interest of both of us to make sure that the creditor
5 has the most accurate file as well.
6 In dealing with consumers, they are at times reluctant
7 to give their social security numbers when applying for
8 credit. And if they don't have it, then they'll go with
9 what they have.
10 Q. But would you agree with me -- my question was:
11 Would you agree with me that Experian has the sole control
12 over requiring -- in essence, forcing the creditor to use
13 complete information in the inquiry format?
14 A. We would have control over whether that subscriber
15 was a member of our system.
16 Q. You have control over who becomes a subscriber --
17 A. Yes.
18 Q. -- true, but you also have the sole control over
19 how the information is accessed by -- in terms of which
20 inquiry input fields are required to be entered before you
21 will return a file?
22 A. Yes. Well, I guess I would agree with that in
23 that we could -- if somebody just put name and address and
24 we refused to allow the file to be entered with just name
25 and address, we could put something in our system to do

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1 that.
2 Q. I guess what I'm getting to is: Experian decides
3 who they allow to become a subscriber?
4 A. Yes.
5 Q. And you have the sole control over who gains
6 access to your system?
7 A. Yes.
8 Q. You have security procedures and security programs
9 in place to prevent hackers, for example?
10 A. Yes. I'm sure we do.
11 Q. You have ability to keep businesses that you don't
12 want to do business with, maybe -- whether it be lawyers or
13 car dealerships or private investigators, you can keep them
14 out of your system?
15 A. Security risks, yes.
16 Q. Okay. And there are certain elements of the
17 business community that you really don't want as
18 subscribers, either because they're more prone to misuse
19 information or maybe report inaccurate information, right?
20 A. Well, there again, I'm not privy to all the
21 subscriber rules and regulations, but I would say yes.
22 Q. Okay. Now, if you can decide who reports
23 information to you as subscribers, and you can decide who
24 accesses your system, then the buck stops with Experian in
25 terms of who has access to your system and how they access

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1 it, right?
2 A. In a way, because I want to be sure that you're
3 clear on, for instance, Sears. Sears may know that the
4 best access is with all identifying information. But if
5 the consumer doesn't give it, they'll go with what they
6 need to have to access our database.
7 Q. But that is their choice?
8 A. Yes.
9 Q. And that is your choice to permit them to use less
10 than full information?
11 A. Yes. Okay.
12 Q. Okay. Now, you also, at Experian, have the sole
13 discretion about what information is required when
14 consumers -- when reports are made about consumers?
15 A. Yes.
16 Q. You have the ability to decide whether to accept
17 or reject data, depending upon the identifying information
18 associated with it, right?
19 A. There are checks and balances in the system, but
20 that's kind of all I know about the system area as far as
21 expertise.
22 Q. Well, I guess I'm asking in a more generic
23 fashion. If you had a subscriber who wanted to report to
24 you about consumers using only a name -- no address, no
25 social; they're just going to list a string of names with

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1 certain information in connection with the names --
2 Experian has the decision whether or not to accept that
3 data and post it to its database, right?
4 A. Yes.
5 Q. So there's no legal requirement that you know of
6 that says you must accept data from this subscriber?
7 A. That's true.
8 Q. And there's no legal requirement that says you
9 must permit this car dealership or this lawyer or this
10 private investigator to have access to your database?
11 A. That's true.
12 Q. So ultimately, the control over what goes into the
13 database and what comes out of the database lies solely
14 with Experian?
15 A. In that respect, I'd say yes.
16 Q. Okay. In connection with this lawsuit, one of the
17 allegations by Experian is that the information that
18 Experian reported to third persons about Mr. Jensen, the
19 plaintiff, was accurate and true. Do you agree with that
20 or disagree with that?
21 A. I believe that, per our database, we have now
22 found it through investigative procedures to find that the
23 information was not accurate.
24 Q. Would you agree that the information that was
25 inaccurate, the wrong information, also had a derogatory

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1 status and rating associated with it?
2 A. There were some accounts that did, yes.
3 Q. And did you find that any of Mr. Jensen's accurate
4 information -- the accounts that are truly associated with
5 him -- did you find that he failed to meet his commitments
6 to those creditors as reported to you by the creditors?
7 A. I'd have to review a report because I -- I don't
8 remember exactly if all of them were absolutely perfect
9 credit.
10 Q. Do you remember seeing anything negative about
11 Mr. Jensen that was truly his?
12 A. I'd have to review it.
13 Q. Well, let's take a few minutes and do that --
14 A. Sure.
15 Q. -- because I'd kind of like to get an idea, from
16 your standpoint, if you see anything in the admin report
17 that you can say is Mr. Jensen's that is derogatory in any
18 way.
19 A. Okay.
20 MR. Szwak: Let's go off the record for a few
21 minutes.
22 THE VIDEOGRAPHER: We're off the record at
23 12:21.
24 (Off the record.)
25 THE VIDEOGRAPHER: On the record at 12:23.

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1 A. (Continuing.) Okay. Based on this particular
2 admin report, there are still some unsuppressed delinquent
3 accounts. I do believe that we have done a subsequent
4 investigation, and those were removed as well. So I --
5 Q. (BY MR. Szwak) And that's subsequent to the
6 February 1, 2000, report?
7 A. Yes.
8 Q. Based upon your review, do you find any -- any
9 reported failure to meet his obligations by the plaintiff?
10 A. No.
11 Q. From what you see there -- from what's been
12 reported by the subscribers, it appears that Mr. Jensen has
13 met his commitments with his creditors?
14 A. Yes.

David A. Szwak

Asleep at the Switch at Experian...Anybody Home?!?!?

Postby David A. Szwak » Mon Nov 21, 2005 9:15 pm

1
1 IN THE UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF TEXAS
2 SHERMAN DIVISION
3 JAMES E. JENSEN, *
*
4 Plaintiff, *
* CIVIL ACTION
5 VS. * NO. 00-CV-0040
*
6 EXPERIAN INFORMATION SOLUTIONS, INC.*
*
7 Defendant. *
8
9 *********************************************************
10 ORAL AND VIDEOTAPED DEPOSITION OF CAROLYN HELM
11 AUGUST 16, 2000
12 VOLUME 1
13 *********************************************************
14
15
16 ANSWERS AND DEPOSITION OF CAROLYN HELM, produced as a
17 witness duly sworn by me at the instance of the Plaintiff,
18 taken in the above-styled and -numbered cause on the 16th
19 day of August, 2000, A.D., beginning at 9:54 a.m. to 2:29
20 p.m., before LISA C. HUNDT, a Certified Shorthand Reporter
21 in and for the State of Texas, reported by machine
22 shorthand, in the offices of Jones, Day, Reavis & Pogue,
23 located at 2727 North Harwood, Dallas, Texas, in accordance
24 with the Federal Rules of Civil Procedure and the
25 agreements hereinafter set forth.


97
15 Q. When you reviewed the records as a whole, did you
16 find that there was any failure on the part of Mr. Jensen
17 to be helpful towards Experian in explaining, to his
18 knowledge, what was going on with this?
19 A. Yes, I did. There -- we needed to have specific
20 disputes, and we had requested information from him. And
21 basically, in subsequent reports or contacts with him, we
22 got the same repeated disputes. What we needed to have is
23 very specific information of what accounts were not his
24 after we had done the initial investigation.
25 Q. And I understand that -- that it would be

98
1 Experian's position that when he said that he's disputing
2 everything on the account, even though he made some very
3 specific disputes and filled up the form that was provided
4 him, that it would be Experian's position that that is not
5 specific enough?
6 A. Yes. In a statement of "investigate all items" is
7 not specific enough.
8 Q. Okay. Do you know why, in the original
9 reinvestigation request -- the original dispute from
10 Mr. Jensen that was received in March of 1998 -- why did
11 that only trigger one CDV when he, in fact, even according
12 to the form, disputed four specific accounts in addition to
13 making the notation about that he was disputing everything
14 because there were so many problems with it? Why only one
15 CDV?
16 A. I believe that the other ones could be related to
17 the address and the social security number of the other
18 person.
19 Q. But if Mr. Jensen was complaining, and the agent
20 could easily see that these other three items were
21 associated with other people's identifiers, at that point
22 in time, we know from the admin, that there were other
23 items that appeared on the report that were also related to
24 other identification.
25 We know that, based upon the February 11, 2000 --

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1 February 11, 1998 report that shows the other social
2 security numbers being reported eight times on one of them
3 and one time on the other social security number. Why
4 didn't they delete all of those?
5 A. Well, because there probably weren't enough clues
6 that would indicate that that truly did belong to the other
7 person. There were probably clear indications that these
8 other three accounts besides the Discover was related,
9 maybe address, social security number, variance in names.
10 In order for the mixed file agent to be sure that he's
11 not deleting something that actually belonged to the
12 consumer, he has to have clear delineation. And he did not
13 have it. That's why he sent "I need more specific
14 disputes. Please call us."
15 Q. Let me ask you this: Mr. Jensen -- as I gather,
16 the agent looked at the four specific items that were
17 delineated out on that form. He looked at them. And three
18 of them, he readily identified as being associated with
19 other ID and deleted them; and he sent one CDV out which
20 came back verified but indicating there was variance in
21 some ID.
22 However, according to the February 11, '98, report
23 there would have been at least five other reportings -- or
24 four other reportings for sure -- with one of the other
25 social security numbers and another reporting with the

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1 other social security number. That's in addition to
2 Mr. Jensen's true social being reported in association.
3 So we know, based upon that report, there were at
4 least four other accounts -- or five other accounts
5 appearing on that report when the agent saw it. Yet he
6 only deleted three of them. Do you follow me?
7 He would have seen other accounts there with the same
8 ID, the same social which was not the plaintiff's, the
9 other associated address which was not the plaintiff's, and
10 the name that was not the plaintiff's. Why wasn't it
11 deleted?
12 A. And that's not necessarily true. There could have
13 been maybe one social but it could have had the address of
14 our consumer or the name of our consumer, so there was no
15 clear delineation on each of the accounts. And that's why
16 we wanted to talk with the consumer.
17 Q. Okay. Well, let's look at that Exhibit No. 1,
18 which is our February 11. 1998, report. Exhibit No. 1 on
19 the Experian Bates No. 106 shows the plaintiff's true
20 social security number reported 26 times; is that true?
21 A. That's true.
22 Q. Presumably, Mr. Jensen did not complain about
23 accounts that were truly his, correct?
24 A. Well, we don't know that because he said
25 reinvestigate all items on the report. So there could have

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1 been some items that were his. I would suppose that there
2 were.
3 Q. Okay. Now, then it shows that the second social
4 security number, which we've identified as not being his,
5 was reported eight times; is that correct?
6 A. That's true.
7 Q. And then it shows that last social security number
8 being reported one time, true?
9 A. That's true.
10 Q. So if he complained about four very specific items
11 and then indicated generally as to the report that he
12 disputed the whole thing, he wanted it reinvestigated,
13 would you agree or disagree that when the agent retrieved
14 the file up to investigate in March, it had to have had
15 other accounts associated with the second social which was
16 not the plaintiff's?
17 A. It may have, but -- and not knowing exactly what
18 was on the file at the time -- but not enough information
19 for the mixed file agent, not enough of a match. These --
20 the three that he did probably had enough of the three --
21 the variance in the name, the address, and the social
22 security number. But without all of that, that's why you
23 would send out the "call us. We need more specific
24 information".
25 Q. Wouldn't you agree that the variance on the second

102
1 social and the other address -- not the plaintiff's social,
2 not the plaintiff's address -- would have appeared on at
3 least, at least four or five other accounts as shown on
4 that report in February 11 of '98?
5 A. Well, it may have, but -- but there again, that
6 would not have been enough information to take over that
7 type of investigation.
8 Q. Okay.
9 THE VIDEOGRAPHER: I'm sorry. If you -- I
10 need to check my audio real quick. Can we go off the
11 record for just a moment? We're off the record at 12:30.
12 (Off the record.)
13 THE VIDEOGRAPHER: On the record at 12:32.
14 Q. (BY MR. Szwak) Subsequent to Mr. Jensen's initial
15 dispute, did he lodge other disputes?
16 A. Yes.

David A. Szwak

Postby David A. Szwak » Mon Nov 21, 2005 9:41 pm

103
23 Q. Let me hand to you what I believe to be all of the
24 D/R logs that I have. This is a disclosure log, and you
25 can tell me if that appears to be complete. And you may

104
1 want to put them in chronological order if you don't mind.
2 (Witness reviewed document.)
3 A. Okay. There was a full CDF sent to him on 4/9 of
4 1998, and it would be the results of the investigation and
5 the moves.
6 Q. Okay. Did he respond to you following his first
7 letter?
8 A. He did not -- I would not say it was respond to
9 us. I think he had another -- well, I guess it could have
10 been. What he did -- we sent out system letters indicating
11 for him to contact us by phone and we needed specific
12 disputes.
13 He responded to the system letters with a duplicate
14 dispute of what he had sent in in March -- mid-March. But
15 as far as responding to the CDF that was sent out -- the
16 full CDF, we didn't get a response
17 (Exhibit No. 5 was marked.)
18 Q. Now, you all had asked him to call in to the call
19 center; is that true?
20 A. Call in or however he could contact us. We would
21 prefer calling because that would be more of a one-on-one.
22 Q. But you all already had a letter in hand with his
23 phone number on it that you could have called him, true?
24 A. That -- we had his telephone number, but that is
25 not part of our procedure. At a call center, there's very

105
1 little opportunity to call out.
2 Q. And yet, you all sent him a letter requesting him
3 to call in to the call center, correct?
4 A. Yes.
5 Q. Are you familiar with a problem that consumers
6 have had in reaching the call center?
7 A. We do have a toll free number and there -- at one
8 point in time, there was a wait.
9 Q. Carolyn, would you agree with me that, in fact,
10 Experian was charged with, and ultimately settled charges
11 that they had blocked phone calls from consumers?
12 A. During peak times.
13 Q. Okay. Well, if Mr. Jensen had gotten a letter and
14 you asked him to call in to the call center, you wouldn't
15 phone him, and he called in and his call's being blocked,
16 then how is he supposed to reach you?
17 A. He could send a letter by mail. He did send
18 subsequent information to us.
19 Q. But that's not what you all asked him to do,
20 right?
21 A. We asked him to call or contact us by phone, and
22 then we also told him we needed a more specific dispute.
23 Q. Why would the calls be blocked at a call center?
24 A. During peak time frames, there was an overload by
25 consumers.

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1 Q. An overload of complaints by consumers?
2 A. Well, not all of them were complaints. A lot of
3 them were requests for credit reports.
4 Q. Which have to be made in writing, true?
5 A. No.
6 Q. You all take telephonic requests for credit
7 reports?
8 A. Yes.
9 Q. How do you verify who is requesting a credit
10 report?
11 A. We have a system check in our system.
12 Q. What would that be?
13 A. Well, if a consumer calls and requests a copy of
14 the credit report, we have an address verification check to
15 make sure that we have the address on file. If they're
16 indicating they've been denied credit, we check for denials
17 within a certain time frame.
18 Q. Do you have any statistics on what the -- the
19 percentages are of your incoming phone calls, disputes
20 versus requests for CDI, credit reports?
21 A. Offhand, I don't.
22 Q. Now, I marked as Exhibit No. 5 a letter from
23 Mr. Jensen dated April 3 of 1998. Did you all receive
24 that?
25 A. Yes, I believe we did.

107
1 Q. Mr. Jensen wrote following up on his initial
2 complaint letter of March 10 of 1998, correct?
3 A. Yes.
4 Q. What is he indicating in his letter of April 3?
5 A. He's indicating that he's attaching his March
6 letter, and he has a postmark listed. And he's also
7 indicated that he received the letter that we sent him
8 asking for more specific disputes.
9 Q. Carolyn, I go back to the March 10 letter which
10 has previously been marked as an exhibit, and in the
11 opening paragraph, Mr. Jensen says, "Your credit report
12 [attached] is grossly inaccurate."
13 He goes on to describe some problems that he claims he
14 had. And he says, "I expect you to rectify these problems
15 both by, one, investigating all" -- and he's got it bolded
16 and underlined -- "all accounts on the 19-page report, copy
17 enclosed, and contacting each creditor with whom I have
18 never had an account to rectify their records and reinstate
19 my status and accounts with my actual creditors." True?
20 A. Yes.
21 Q. I may have paraphrased it a little, but there's
22 some exact language there. That seems to me to be about as
23 specific as a consumer can get, right?
24 A. No.
25 Q. You disagree with that?

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1 A. I disagree with that.
2 Q. Okay. In paragraph 2, he goes on to again say, "I
3 request and expect all of the accounts on the credit report
4 to be investigated, not just those listed on the
5 reinvestigation request form." You agree with me he put
6 that in there?
7 A. Yes.
8 Q. Okay. In paragraph 3 of the report, doesn't
9 Mr. Jensen indicate what are clear signals that, as you've
10 outlined for me, of a mixed file problem by indicating that
11 there are several different individuals, Jim or James
12 Jensens listed in the report, as well as different
13 addresses, social security numbers, and places of
14 employment, true?
15 A. Yes. And that's why that indication had it
16 transferred to the mixed file department.
17 Q. Well, if he's specifically disputed that he never
18 lived in Citrus Heights, California, or Libby, Montana,
19 isn't that specific enough to cause Experian to
20 reinvestigate accounts that, by their own record, showed a
21 reporting address in connection with the account as being
22 Citrus Heights, California, or Libby, Montana?
23 A. Not unless all the other criteria was there as
24 well. So the clues are there. He indicated it was a mixed
25 file. We clearly matched up all of the items that we could

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1 that matched to the name, social security number, and
2 address. There were specific accounts that were his -- or
3 appeared to be his because it had his social on there.
4 And yet, the consumer is indicating reinvestigate all
5 accounts. Well, that's why the information was sent back
6 to him. We need more specific disputes because clearly
7 some of those accounts belonged to him, and he would not
8 want those to be investigated as not mines.
9 Q. What I'm asking is: The two social security
10 numbers appearing on the February 11, '98, report show that
11 they're reported in nine different times -- nine different
12 creditors. He's telling you in the letter, "I don't live
13 in Citrus Heights, California, or Libby, Montana.
14 A. Right.
15 Q. Those social security numbers -- the two erroneous
16 numbers are associated with Libby, Montana, and Citrus
17 Heights, California?
18 A. I don't know that for sure. I have not seen all
19 of that. I know those addresses appeared on there.
20 Q. But that is information available to Experian that
21 is not available to the consumer, right?
22 A. That's true. We were able to tell that.
23 Q. It's in your admin report?
24 A. Yes.
25 Q. So anybody at Experian who is looking at this

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1 could have readily seen -- Mr. Jensen says he's never lived
2 in California or in Libby, Montana. He's got nine times
3 being reported with the wrong social that's merged in this
4 report. It seems to me that that's enough information to
5 cause Experian to delete those nine items.
6 A. And the items that we were able to move or
7 transfer or delete from Mr. Jensen, our consumer's report,
8 matched the criteria that was needed for that decision to
9 be made.
10 Q. And that --
11 A. The other ones did not for some reason.
12 Q. And that criterion that's required is for him to
13 have specified them out individually -- for example, on a
14 reinvestigation request form?
15 A. No. That's not true. Because there were more
16 than just these three items taken off the report.
17 Q. Well, let's -- let's look for a moment at the
18 other items from the February 11, '98, report that were
19 connected with the erroneous social and erroneous address
20 but were not specified in the reinvestigation request form.
21 What -- which ones were those?
22 A. Well, I think probably the best indication would
23 be on the D/R log because that tells us exactly what was
24 investigated.
25 Q. Okay. Well, let's I think what's easiest for me,

111
1 though, is to look at this reinvestigation request form.
2 There's four of them listed here, and let's pick one of
3 them that is not listed on here and match it up to the
4 admin and see how it was being reported. Probably a good
5 one, because I know it's here, is the Chase account.
6 If I understand the process at Experian correctly, the
7 Chase account --
8 A. I don't believe the Chase account was one of the
9 ones investigated on the first.
10 Q. I agree with you. It was not investigated, but it
11 was an account which appeared on his credit report at the
12 time?
13 A. Okay.
14 Q. And that Chase account, as indicated at least here
15 on this admin report, did not match any of the names or
16 addresses shown in the cross-reference log and had no
17 social security number associated with it.
18 A. Right. It had -- the name row was zero. On the
19 2/1/2000 admin, it has name row of zero, address rows of
20 zeros, and no social security number. However, we don't
21 know what the mixed file agent saw at the time he
22 investigated in 1998.


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