Equifax/CSC Frozen Scans:Archived Snapshots of Files:Monthly

David A. Szwak

Equifax/CSC Frozen Scans:Archived Snapshots of Files:Monthly

Postby David A. Szwak » Mon Oct 31, 2005 1:10 pm


Plaintiff, )
) CASE NO. 3:04CV 1142 (SRU)
vs. )
Defendant )
__________________________ )

30(b)(6) deposition of Equifax Information
Services, LLC, (Alicia Fluellen), taken on behalf
of the Plaintiff, pursuant to the stipulations set
forth herein, before Charna S. Perloe, Certified
Court Reporter, at 1100 Peachtree Street, Suite
2800, Atlanta, Georgia, on the 6th day of October
2005, commencing at approximately 3:20 p.m.

21 Q And have you reviewed any documents in
22 preparation for this deposition?
23 A Yes, ma'am.
24 Q What documents have you reviewed?
25 A I reviewed the letters that we produced, the

1 consumer letters. I reviewed the ACIS archive
2 reports, and then I've also reviewed some frozen
3 scans.
4 Q And did you bring those documents here with
5 you today?
6 A Yes.
7 Q And are those all documents that are made and
8 kept in the ordinary course of Equifax's business?
9 A Yes, with the exception of the frozen
10 database scans. The frozen database scans are
11 requested, but it is the normal process that we have
12 at Equifax.
13 Q But those are stored in your system
14 somewhere? They are regularly kept?
15 A The information is stored in our system, yes,
16 ma'am.
17 Q And do the documents accurately reflect the
18 information that is in your system?
19 A Yes.
20 Q And were they made contemporaneously by
21 somebody with knowledge of the contents of those
22 documents?
23 A I'm sorry. I don't understand. I'm sorry.
24 Q Were the documents made at or near the time
25 of the occurrence of the matters set forth in the

1 documents?
2 A Yes. The information -- well, the documents
3 are printed sometime thereafter, but the information
4 was kept during that time.
5 Q That's it. Thank you.
6 And when those original -- when those
7 original documents were made, there was
8 contemporaneous knowledge that their contents were
9 accurate?
10 A Oh, yes.

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