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

David A. Szwak

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

Postby David A. Szwak » Sun Oct 16, 2005 6:56 am

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF TEXAS

MARICELA MENDOZA CAUSE NO.:
CIV-H-02-2465
Versus

EXPERIAN INFORMATION SOLUTIONS,
ET AL

NOTICE OF ORAL DEPOSITION DUCES TECUM
To: EQUIFAX INFORMATION SERVICES, LLC
through its attorney of record:
Tony Love, Esq.
Kilpatrick Stockton, LLP
1100 Peachtree Street, Ste. 2800
Atlanta, Georgia 30309-4530
Counsel for Equifax Information Services

Pursuant to Rule 30 of the Federal Rules of Civil Procedure, Plaintiff announces that she will take the deposition of EQUIFAX INFORMATION SERVICES, LLC [“EFX”], before a certified court reporter at the law offices of Kilpatrick Stockton, LLP, 1100 Peachtree Street, Ste. 2800, Atlanta, Georgia 30309-4530, on the ___ day of June, 2003, 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 deponent is to produce, on or before the date and time of the deposition, the documents and things called for the attached duces tecum request found in Exhibit A. The deposition will be taken for all purposes, including the perpetuation of testimony. The areas of inquiry includes: CDVs and ACDVs sent by Equifax to Verizon f/k/a Airtouch [defendant in this case], in the two year period preceding the filing of this lawsuit; the number of CDVs and ACDVs sent by Equifax to Verizon f/k/a Airtouch [defendant in this case], in the two year period preceding the filing of this lawsuit, which were coded or shown as the subject consumer contesting an account credit reporting by Verizon f/k/a Airtouch [defendant in this case] as involving a “fraud account” or “not mine” dispute; the number of CDVs and ACDVs sent by Equifax to Verizon f/k/a Airtouch [defendant in this case], in the two year period preceding the filing of this lawsuit, which were coded or shown as the subject consumer contesting an account credit reporting by Verizon f/k/a Airtouch [defendant in this case] as involving a “fraud account” or “not mine” dispute and where Verizon f/k/a Airtouch [defendant in this case] responded to the CDV or ACDV by coding the response “035" [code 35; “verified”] or by stating that the reporting was confirmed or verified as belonging to the contesting consumer; the number of contested account credit reporting by Verizon f/k/a Airtouch [defendant in this case] which Equifax has deleted or suppressed based upon a complaint that the account reporting was a fraud account and should not be attributed to the subject of the credit report or data file.

Respectfully submitted:

Bodenheimer, Jones, Szwak

By: _________________________________
David A. Szwak, LBR#21157
416 Travis St., Ste. 240
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 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 __________________, 2003.

__________________________________
OF COUNSEL


Page 1 of 3
To: EQUIFAX INFORMATION SERVICES, LLC, hereinafter merely referred to as "Company" or "you" or "your":
EXHIBIT "A"
1. All documents in your possession which contain information about CDVs and ACDVs sent by Experian to Verizon f/k/a Airtouch [defendant in this case], in the two year period preceding the filing of this lawsuit;

2. All documents in your possession which contain information about the number of CDVs and ACDVs sent by Experian to Verizon f/k/a Airtouch [defendant in this case], in the two year period preceding the filing of this lawsuit, which were coded or shown as the subject consumer contesting an account credit reporting by Verizon f/k/a Airtouch [defendant in this case] as involving a “fraud account” or “not mine” dispute;

3. All documents in your possession which contain information about the number of CDVs and ACDVs sent by Experian to Verizon f/k/a Airtouch [defendant in this case], in the two year period preceding the filing of this lawsuit, which were coded or shown as the subject consumer contesting an account credit reporting by Verizon f/k/a Airtouch [defendant in this case] as involving a “fraud account” or “not mine” dispute and where Verizon f/k/a Airtouch [defendant in this case] responded to the CDV or ACDV by coding the response “035" [“verified”] or by stating that the reporting was confirmed or verified as belonging to the contesting consumer;

4. All documents in your possession which contain information about the number of contested account credit reporting by Verizon f/k/a Airtouch [defendant in this case] which Experian has deleted or suppressed based upon a complaint that the account reporting was a fraud account and should not be attributed to the subject of the credit report or data file;

5. Your audits of reinvestigations of account credit reportings by Verizon f/k/a Airtouch [defendant in this case] where the consumer contested the reporting as involving a “fraud account” or “not mine” dispute.

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