19 Q Okay. Now, we know that on March 12, 2003,
20 there's a notation, we've got a possible mixed file issue,
21 and we know from earlier discussions we had -- I don't want
22 to belabor them too much, but we know that there was an
23 employee, Robin Jones, who went into Mr. Carriere's credit
24 file and altered a lot of personal identification data. Is
25 that true?
1 A Well, she updated some personal identification
3 Q Now, if we -- if we look at exactly what did
4 Ms. Jones have in front of her at the point in time when she
5 decided to do this, we know that presumably she would have
6 had access to the D/R log as it existed at that point in
7 time. Is that a fair statement?
8 A In March -- are you referring to March 2000 --
9 Q March 2003.
10 A She would have had access to the D/R log.
11 Q We don't know if she looked at it, but we know
12 she would have had access to it; right?
13 A Right.
14 Q She could look at the disclosure log and see
15 where he had previously received copies of his credit
16 reports; right?
17 A Yes.
18 Q She would have had access to an administrative
19 report or whatever it would have appeared to be at that
20 point in time; is that true?
21 A She -- as far as my understanding, they typically
22 do not pull administrative reports.
23 Q To unravel a mixed file they don't pull
24 administrative reports?
25 A They could.
1 Q But is it part of your policies and procedures to
2 have them do that when they're trying to unravel a mixed
4 A They may not necessarily need the administrative
6 Q To your knowledge, is there a better report or
7 pool of information at Experian to review when you're
8 considering a mixed file issue other than an administrative
10 A I don't think there's a better report. Sometimes
11 they can see the information as it is on file and make their
13 Q Is that what you call in a 7X format?
14 A They can look at the 7X version.
15 Q The 7X is very similar in format to the
16 administrative report; right?
17 A Yes. Or they contain a lot of the same
19 Q Is there another format that exists in the system
20 -- as you said they can see all information -- what would
21 that format be called?
22 A They can see -- I'm sorry, when you say all
23 information --
24 Q Yes, ma'am. You described for me that they don't
25 really need an administrative report or presumably a 7X
1 report to unravel a mixed file at Experian; they can look
2 into the system and see all information. And exactly what
3 format is that called when you say they can look in and see
4 all of it?
5 A Well, sometimes based on the 7X version they'll
6 be able to do some matching criteria. We'll still have some
7 information on the NX version of the report.
8 Q The NX is the updated version; right? After
9 changes are made?
10 A Yes.
11 Q So is it -- I still go back to the question of if
12 you're trying to unravel a mixed file and you need to know
13 what names and addresses and Social Security numbers are
14 reported in by the respective persons whose accounts or
15 public record items are appearing in the report, is there a
16 better format for your representative to have access to
17 other than the administrative or 7X format that have the
18 name and address rows?
19 A No. Those two reports would be the reports that
20 we would utilize.
21 Q Are all of these ladies given access to the
22 administrative and 7X report formats?
23 MR. McLOON: Objection. Vague.
24 A Well, everyone basically has access to the 7X
25 report if they conduct any disputes on behalf of consumers
1 or for the consumer. As far as access to the administrative
2 report, if they needed it, they would be able to obtain an
3 admin report.
4 Q Okay. But as far as you're concerned, the 7X is
5 basically in the same format as the administrative report.
6 In essence, it gives you name and address row information
7 and tells you basically how the creditor has been reporting
8 in the information; right?
9 MR. McLOON: Objection with respect to the
10 question of reporting being outside her scope. Beyond that
11 I don't have any objection.
12 A Yes. The 7X report would give us the name and
13 address tables.
14 Q Okay. Now, but this is a real important point.
15 If you're conducting a reinvestigation and
16 you look at the 7X or administrative report and you're
17 looking at the name and address row tables --
18 A Uh-huh.
19 Q -- to the best of your knowledge at Experian,
20 that is the manner in which the creditor reported and not
21 some independent source of identification data that Experian
22 has attributed to a particular account; right?
23 MR. McLOON: Objection. Beyond the scope of
24 the designation.
25 Q And we're talking about reinvestigation issue.
1 MR. McLOON: Still same objection. Assumes
2 facts not in evidence.
3 A Let me make sure I understand the question. If
4 you're asking me if the particular name and address is
5 associated with a particular account, unless there's some
6 type of maintenance activity that's done either through the
7 creditor, by Experian or by other behind-the-scenes means,
8 that from an investigation standpoint we would try and align
9 the name and address rows with the particular account.
10 Q Okay. But my point is is that when you're doing
11 a reinvestigation and you're looking into the records to try
12 to decide whether some consumer is right or wrong about the
13 way an item is reported, that you have an expectation that
14 if the N equals listed below the accounts says N equals and
15 it correlates up to the name row table, that that's what the
16 creditor is telling you at that point in time; right?
17 MR. McLOON: Objection. Assumes facts not
18 in evidence.
19 Q I can give a specific example. I mean, we can
20 look at the administrative report and talk about one that
21 actually has an entry next to it and see if that helps.
22 Let me give you one example. Here on
23 Page -- it's Page Experian 469 in Exhibit A, there's a
24 Dillard's Department Store account, the last one on the
25 page, it has N equals 19266, but no address listed.
1 If you were reinvestigating this particular
2 Dillard's account and you were looking at the data on the
3 trade, as a reinvestigation person, are you reasonably
4 expecting that the lender reported that name row element so
5 that you can cross reference it back up here and see how
6 it's being reported?
7 A Well, we're not necessarily basing it on whether
8 or not the lender. We're basing it on is the name that is
9 associated with that particular account based on the name
10 and address row.
11 Q I thought we just said the same thing, just two
12 different ways.
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