1 IN THE UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF TEXAS
2 SHERMAN DIVISION
3 JAMES E. JENSEN, *
4 Plaintiff, *
* CIVIL ACTION
5 VS. * NO. 00-CV-0040
6 EXPERIAN INFORMATION SOLUTIONS, INC.*
7 Defendant. *
10 ORAL AND VIDEOTAPED DEPOSITION OF CAROLYN HELM
11 AUGUST 16, 2000
12 VOLUME 1
16 ANSWERS AND DEPOSITION OF CAROLYN HELM, produced as a
17 witness duly sworn by me at the instance of the Plaintiff,
18 taken in the above-styled and -numbered cause on the 16th
19 day of August, 2000, A.D., beginning at 9:54 a.m. to 2:29
20 p.m., before LISA C. HUNDT, a Certified Shorthand Reporter
21 in and for the State of Texas, reported by machine
22 shorthand, in the offices of Jones, Day, Reavis & Pogue,
23 located at 2727 North Harwood, Dallas, Texas, in accordance
24 with the Federal Rules of Civil Procedure and the
25 agreements hereinafter set forth.
15 Q. In the past, have you ever had occasion to access
16 a consumer's report at the call center and find that --
17 that a report provided you, perhaps, by the consumer at the
18 same time frame contained -- which would have been a
19 subscriber version -- contained a differing number of
20 accounts and reportings?
21 A. Well, we would never have accessed a subscriber
23 Q. No. At the call center, you would have been
24 accessing a consumer disclosure, correct?
25 A. Yes.
1 Q. Whether it be CDI or CDF?
2 A. Well, we wouldn't access a CDF. We would have a
4 Q. CDF automatically generates at the end of a
5 reinvestigation period?
6 A. Yes.
7 Q. In connection with generating a CDI report, have
8 you ever had an opportunity to compare it with a recent
9 subscriber report on the same consumer generated at about
10 the same time?
11 A. Not usually.
12 Q. But have you ever had the ability to do that?
13 A. Only if the -- if the consumer provided that, if
14 he had gotten a copy from a subscriber or somebody that had
15 denied him credit.
16 Q. But I'm asking you, in your experience at
17 Experian, have you found that there are occasions when a
18 subscriber's version of a credit report contained more
20 A. I have -- personally speaking, no.
21 Q. Have they always been the same?
22 A. We hardly ever get subscriber reports, as far as
23 unless the consumer has sent it in. I've not -- I've not
24 ever seen they weren't the same as far as credit
1 Q. Have you --
2 A. The consumer report contains more information.
3 Q. Well, when we're talking about information, we're
4 talking about in terms of number of trade lines,
5 information that might be compiled into the subscriber
6 version which does not appear in the consumer version.
7 Additional accounts?
8 A. I'm not aware. There again, I don't -- we don't
9 access subscriber reports.
10 Q. Well, I guess the question is: When you all
11 access a consumer disclosure at the Allen center, you use
12 full information; is that correct?
13 A. Yes.
14 Q. You use the person's first and last name, middle
15 initial, right?
16 A. Yes.
17 Q. Address, city, state, ZIP code?
18 A. We try to receive all of the information that the
19 consumer has. We ask for it. If they don't give it or if
20 they don't provide it in a mail request then --
21 Q. Do you use their social security number?
22 A. Yes.
23 Q. On each request?
24 A. Yes.
25 Q. And you sometimes even use former address in
1 connection with the inquiry format?
2 A. Yes.
3 Q. Are you aware of any instances where a subscriber
4 version of a credit report actually was broader because the
5 inquiry information was not required, such as full
7 A. I am aware that that can happen.
8 Q. Does that lead to inaccurate information?
9 A. Yes.
Where credit reports can be acquired.
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