Trans Union: Mixed Fikes: Do Not Merge Tags

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Trans Union: Mixed Fikes: Do Not Merge Tags

Postby Administrator » Mon Oct 03, 2005 8:14 pm

2 Southern Division
v. Civil Action No.
6 02-73673
9 The videotaped deposition of REGINA
10 SORENSON, called by the plaintiff for examination,
11 pursuant to notice, and pursuant to the Rules of
12 Civil Procedure for the United States District
13 Courts, taken before Cheryl A. Goetsch, CSR and
14 Notary Public in and for the County of DuPage and
15 State of Illinois, on October 22, 2003, at
16 11:31 a.m., at 25 East Washington Street,
17 Suite 1805, Chicago, Illinois.

23 Q Okay. And let me ask you about the next
24 exhibit which would be Exhibit No. 22. I guess it

1 would be 22, 23, and 24. Would this be a complete
2 copy of TransUnion's -- this would be TransUnion's
3 copy of what we just looked at in Exhibit No. 18 and
4 19?
5 A Yes.
6 Q Let me ask you. To your knowledge has
7 TransUnion ever added any type of mechanism to the
8 data file of Wendy Porter in order to prevent it
9 from combining with or being joined together with
10 the other data file pertaining to William Porter so
11 that they're not returned as part of the same credit
12 report?
13 A I know that a "do not merge" tag was added
14 to the file, yes.
15 Q I'm sorry. I might have missed your --
16 your answer. Did you answer, and I just didn't hear
17 you?
18 MR. CENTO: Yeah, she did.
19 BY MR. Szwak:
20 Q I'm sorry. What did you tell me? What --
21 what was the date of the "do not merge" tag?
22 A 9-25-02.
23 Q Okay. So on September 25 of 2002,
24 TransUnion added a -- what -- what you've termed a

1 "do not merge" tag to the plaintiff's credit file?
2 A Correct.
3 Q What does a "do not merge" tag -- I mean,
4 what does that mechanism do?
5 A It prevents it from merging with other
6 files.
7 Q Does it prevent it from merging with any
8 other file or just some other specified file?
9 A Any other files.
10 Q Okay. So in the future if someone were to
11 request a con- -- let's start with just a request on
12 a consumer disclosure for the plaintiff. It would
13 be fair to say that certainly the William Porter
14 data file would not return as part of that
15 disclosure; is that true?
16 A No, that's not true.
17 Q Okay. Well, let me ask you. How could --
18 if a "do not merge" tag existed on plaintiff's
19 credit file and a consumer disclosure was requested
20 by the plaintiff from TransUnion, how could other
21 data files or the data file of William Porter be
22 returned as part of that disclosure if it's got that
23 tag on it?
24 A The tag prevents the files from merging.

1 Q So if I understand -- I mean, maybe --
2 maybe I didn't understand your full answer. But the
3 full answer might be but someone could manually
4 combine the two?
5 MR. CENTO: Object to the form.
6 A If they wanted to, yes.
7 BY MR. Szwak:
8 Q Is there any other way for those two files
9 to become joined together in any fashion?
10 MR. CENTO: Object to the form.
11 A But -- I don't understand -- what do you
12 mean by "combined" or "joined"?
13 BY MR. Szwak:
14 Q Well, I mean for those two separate data
15 files to become part of the same report.
16 A The "do not merge" tag prevents that.
17 Q Okay. So if I understand correctly, based
18 upon the -- the addition of the "do not merge" tag
19 to the plaintiff's credit file as of September 25 of
20 2002, it would be safe to say that Wendy Porter
21 should never have to worry about her credit file
22 information being part of a credit report along with
23 the data file of William Porter; is that fair to
24 say?

1 MR. CENTO: Object to the form.
2 A No.
3 BY MR. Szwak:
4 Q Well, how could it happen again if the
5 merge tag is in place?
6 MR. CENTO: Object to the form.
7 A The merge tag prevents the files from
8 combining or merging.
9 BY MR. Szwak:
10 Q Okay. So, in essence, even though the
11 merge -- the "do not merge" tag is in place, the
12 only thing that that will prevent is the actual
13 combination of those files into a single, resulting
14 file; is that correct?
15 A That's why in consumer relations we add the
16 "do not merge" tag.
17 Q Okay. But I want to make sure that -- that
18 we've got a clear understanding at least on my end
19 of -- of what has happened. On September 25, 2002,
20 there was a "do not merge" tag added to the credit
21 data file of the plaintiff, what we previously
22 looked at with an "infile" date of August of 1999;
23 is that true?
24 A I'm sorry. I'm sorry. Could you repeat

1 the question.
2 Q Yes, ma'am.
3 MR. Szwak: Ms. Court Reporter, could you
4 read that back, please.
5 MR. CENTO: David, and lately we've been
6 having some problems with trains here. You
7 don't -- you can't -- you can't tell, but some
8 of the reasons why people aren't hearing or
9 understanding your questions is because there's
10 a lot of trains that have been going by lately.
11 (Question read.)
12 A Correct.
13 BY MR. Szwak:
14 Q Okay. And based upon the presence of that
15 tag on that one data file, it will keep plaintiff's
16 data file from permanently combining or mixing
17 together with the data file of William Porter, for
18 example?
19 A It will prevent it from merging from any
20 file, correct.
21 Q But what I'm saying is, whether it's the
22 William Porter data file, what we've identified as
23 the file No. 2 or No. 3 on Exhibits 2 and 3, that
24 regardless of whether it's one of those two data

1 files or some other data file that has some
2 different information than that of the plaintiff, it
3 should keep it from permanently combining with such
4 a file, correct?
5 A Correct.
6 Q Now, the -- the "do not merge" tag will not
7 prevent two different data files from being returned
8 as part of the same credit report; is that true?
9 MR. CENTO: Object to the form.
10 A I don't know.
11 BY MR. Szwak:
12 Q Well, let me ask you. In your
13 understanding of how a "do not merge" tag operates,
14 does it prevent two different data files from being
15 returned as part of the same consumer disclosure?
16 A I know in consumer relations it doesn't.
17 Q Okay. And let me give you an example
18 and -- and make sure I understand correctly.
19 MR. CENTO: David, do you want to finish
20 this question? And then I think the
21 videographer needs to change his tape.
22 MR. Szwak: Okay. That's good. Let me --
23 let me do this question.
24 How are we on time, Mr. Videographer?

1 THE VIDEOGRAPHER: Well, we've got ten
2 minutes left on the tape. If you want -- if you
3 want to roll ten more minutes, that will be
4 fine.
24 Q However, is it possible that those two

1 files could be returned to a subscriber as part of a
2 subscriber version credit report?
3 MR. CENTO: Object to the form.
4 A I don't know if that occurs once the tag is
5 put on.
6 BY MR. Szwak:
7 Q Is there any documentation about how this
8 particular tag functions?
9 A I'm sure that we have some type of
10 documentation.
11 Q Do you have any of it in your office?
12 A We may, yes.
13 Q I mean, I'm assuming that if this is a
14 system capability that you have available to you to
15 use in your job and for your -- your employees, that
16 you would have some sort of documentation explaining
17 how it functions; is that a fair statement?
18 A Yes. We -- we know how it functions as far
19 as consumer relations is concerned, and we place
20 that tag on there to prevent the files from merging.
21 Q Okay. And what is it -- what is it that
22 you define as "merging"? Is that the combining, the
23 actual combining of two different data files to
24 create one resultant file?

1 A Yes.
2 Q But that does not -- in terms of "merging,"
3 when you all talk about "merging," that does not
4 involve the second situation, which is where more
5 than one data file may still come together as part
6 of a credit report, correct?
7 A Well, you're asking me two different
8 questions. I don't know if -- if that prevents it
9 from -- I don't know if by adding that "do not
10 merge" tag, if it prevents the subscriber from
11 pulling both reports.
12 MR. CENTO: David, I've been kind of
13 letting this go for a while now, but I'm going
14 to cut you off. There is no allegation in this
15 case at all that we merged Wendy Porter's file
16 with anybody else's, including William Porter's,
17 not even an allegation, let alone proof. So
18 any -- all this -- all this business about
19 merging and all this, I've let it go long enough
20 for her to give you some indication about why
21 the tag was added, but now we're going well
22 beyond that, well beyond the scope of this case.
23 MR. Szwak: Well, thank you. The -- the
24 objection is noted.

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