Identity Theft:FRCP 30[b][6] Notice of Depo: Furnisher/Duped

David A. Szwak

Identity Theft:FRCP 30[b][6] Notice of Depo: Furnisher/Duped

Postby David A. Szwak » Fri Oct 14, 2005 11:54 am

UNITED STATES DISTRICT COURT
IN AND FOR THE WESTERN DISTRICT OF LOUISIANA
Shreveport Division

JOHN MARANTO,
Plaintiff,
Versus Civil Action No.
CV05-0347-S
CITIBANK USA, N.A., ET AL JURY DEMANDED
Defendants.

NOTICE OF ORAL DEPOSITION
To: CITIBANK USA, N.A., through its counsel of record, Gabe Crowson and Tony
Rollo, McGlinchey Stafford, One American Place, 14th Floor, 301 Main Street,
Baton Rouge, Louisiana 70825

Pursuant to the Federal Rules of Civil Procedure, Plaintiff announces that she will take the deposition of Most Knowledgeable Witness[es] and Custodian of Records, CITIBANK USA, N.A. [“CITIBANK”], before a certified court reporter at the law offices of McGlinchey Stafford, One American Place, 14th Floor, 301 Main Street, Baton Rouge, Louisiana 70825, on the ____ day of ______________, 2005, beginning at 10:00 a.m., with video to likewise be taken, and continuing day to day until completed or concluded in accordance with court rules. The deposition will be taken for all purposes, including the perpetuation of testimony. The areas of inquiry includes the allegations and facts discussed in plaintiff’s complaint filed in this lawsuit; CITIBANK’s responses, answers, pleadings and defenses alleged and responses to requests for admissions and interrogatories; CITIBANK’s account history involving the account[s] made subject of this litigation and any account[s] bearing any of plaintiff’s personal identifiers; the payment histories and account histories on the account[s] made subject of this litigation and any
account[s] bearing any of plaintiff’s personal identifiers; CITIBANK’s inquiries into plaintiff’s credit reports; CITIBANK's relationship and subscriber contracts with any consumer reporting agency[ies]; CITIBANK's information archival system regarding account records and credit reportings made; CITIBANK’s audit trail of their credit and credit reporting systems; CITIBANK's ability to maintain physical and computerized records; CITIBANK's credit reporting dispute reinvestigation procedures and policies; CITIBANK’s policies and procedures for compliance with 15 U.S.C. 1681s-2; CITIBANK’s policies and procedures for reporting account information; CITIBANK’s CDV and ACDV processes; any and all CDVs, ACDVs, UDFs and AUDFs bearing any of plaintiff’s identifiers and/or the disputed account[s]; CITIBANK’s reinvestigation methods used to address plaintiff’s disputes; CITIBANK’s data suppression and deletion mechanisms; all CITIBANK data files and reportings regarding the plaintiff and/or any of his personal identifiers; each internal record and report generated about or concerning plaintiff; each record in CITIBANK’s communications log and records which pertain to the account[s] made subject of this litigation and any account[s] bearing any of plaintiff’s personal identifiers; each dispute lodged by plaintiff and any responses by CITIBANK to each dispute; communications between CITIBANK and the credit reporting agencies; communications between plaintiff and CITIBANK.

Respectfully submitted:

Bodenheimer, Jones, Szwak

By: ________________________________________
David A. Szwak, LBR#21157
416 Travis St., Ste. 240
Mid South Tower
Shreveport, Louisiana 71101
(318) 424-1400
FAX 221-6555
www.bjswlaw.com
ATTORNEYS FOR PLAINTIFF

CERTIFICATE OF SERVICE
I hereby certify that a copy of the above and foregoing has been served upon all counsel of record by placing a copy of same in the United States Mail, properly addressed and first class postage pre-paid on this the ______ day of __________________, 2005.
________________________________________
OF COUNSEL

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