Identity Theft:FRCP 30[b][6]: Notice of Depo: to Trans Union

David A. Szwak

Identity Theft:FRCP 30[b][6]: Notice of Depo: to Trans Union

Postby David A. Szwak » Fri Oct 14, 2005 12:31 pm

UNITED STATES DISTRICT COURT
IN AND FOR THE EASTERN DISTRICT OF TEXAS
Marshall Division

MIKE HAMMOND,
Plaintiff,
Versus Civil Action No.
2:05CV0061
TRANS UNION, LLC, ET AL JURY DEMANDED
Defendants. JUDGE WARD

NOTICE OF ORAL DEPOSITION
To: TRANS UNION, LLC
through its attorneys of record:
Amanda Lewis, Esq., Strasburger Price

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, TRANS UNION L.L.C. [“TRANS UNION”], before a certified court reporter at the offices of Amanda Lewis, Esq., Strasburger & Price, 901 Main Street, Ste. 4300, Dallas, Texas 75202-3794, 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; TRANS UNION’s responses, answers, pleadings and defenses alleged; TRANS UNION’s history search summary records for each and every File Identification Number of each data file bearing any of plaintiff’s personal identifiers such that the file[s] would be returned as a possible file in
response to an inquiry about plaintiff; all Trade Detail Set records involving the account[s] made subject of this litigation and any account[s] bearing any of plaintiff’s personal identifiers; all name scans for each and every data file bearing any of plaintiff’s personal identifiers such that the file[s] would be returned as a possible file in response to an inquiry about plaintiff, for a period of four years predating the filing of this lawsuit; the Audit 16 and Journal 20 records for each and every data file bearing any of plaintiff’s personal identifiers such that the file[s] would be returned as a possible file in response to an inquiry about plaintiff, for a period of four years predating the filing of this lawsuit; each and every archived subscriber-version credit report which TRANS UNION generated and published to each user/subscriber listed in the inquiry logs shown on plaintiff’s credit reports and credit data files maintained in TRANS UNION’s records; TRANS UNION’s inquiries into plaintiff’s credit reports; TRANS UNION's relationship and subscriber contracts with its co-defendants/furnishers; TRANS UNION's information archival system regarding credit reportings made by its co-defendants/furnishers; TRANS UNION's information archival system regarding credit data files in its CRONUS system; TRANS UNION’s audit trail of its credit and credit reporting systems; TRANS UNION's ability to maintain physical and computerized records; TRANS UNION's credit reporting dispute reinvestigation procedures and policies; TRANS UNION’s policies and procedures for compliance with 15 U.S.C. 1681e; TRANS UNION’s policies and procedures for compliance with 15 U.S.C. 1681i; TRANS UNION’s policies and procedures for posting and reporting account information from its co-defendants/furnishers; TRANS UNION’s CDV and ACDV processes; TRANS UNION’s UDF and AUDF processes; any and all CDVs, ACDVs, UDFs and AUDFs bearing any of plaintiff’s identifiers and/or the disputed account[s]; TRANS UNION’s reinvestigation methods used to address plaintiff’s disputes; TRANS UNION’s data suppression and deletion mechanisms; all TRANS UNION 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 TRANS UNION’s communications log and records which pertain to the accounts and reportings made subject of this litigation and any accounts bearing any of plaintiff’s personal identifiers; each dispute lodged by plaintiff and any responses by TRANS UNION to each dispute; each dispute lodged by plaintiff and any responses by your co-defendants/furnishers to each dispute; communications between TRANS UNION and its co-defendants regarding plaintiff; communications between plaintiff and TRANS UNION; the cost of a reinvestigation of a consumer’s dispute by TRANS UNION; the cost incurred by TRANS UNION in reinvestigating plaintiff’s disputes; audits by TRANS UNION to study and assess the cost of dispute reinvestigations; TRANS UNION's contacts with plaintiff; TRANS UNION's data and file matching programs; TRANS UNION's use of a quota system; TRANS UNION’s reinvestigation activities; prior written statements, depositions, affidavits and trial testimonies of persons who TRANS UNION may call as witnesses in the trial of this lawsuit; each credit score, Empirica or otherwise, which TRANS UNION published regarding plaintiff; each adverse action [a/k/a risk factor a/k/a denial code] TRANS UNION published regarding plaintiff.

Bodenheimer, Jones, Szwak

By: ________________________________________
David A. Szwak, LBR#21157, TA
416 Travis Street, Suite 1404
Mid South Tower
Shreveport, Louisiana 71101
(318) 424-1400
Fax 221-6555
ATTORNEYS FOR PLAINTIFF

CERTIFICATE OF SERVICE
I hereby certify that a copy of the above and foregoing has been served upon defendants’ counsels of record by email and also 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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