Types, Names, Descriptions, Testimony
David A. Szwak


Postby David A. Szwak » Wed Nov 09, 2005 7:58 am

2 Southern Division
v. Civil Action No.
6 02-73673
9 The videotaped deposition of LYNN S.
10 ROMANOWSKI, called by the plaintiff for examination,
11 pursuant to notice, and pursuant to the Rules of
12 Civil Procedure for the United States District
13 Courts, taken before Cheryl A. Goetsch, CSR and
14 Notary Public in and for the County of DuPage and
15 State of Illinois, on October 22, 2003, at
16 2:39 p.m., at 25 East Washington Street, Suite 1805,
17 Chicago, Illinois.

7 Q Define the inquiry input information or
8 what we call the terminal audit trail.
9 A I -- I'm not familiar with the term
10 "terminal audit trail," but inquiry input
11 information is the information that's supplied to
12 TransUnion that -- on behalf of the consumer, the
13 consumer's name, address, Social Security number,
14 date of birth.
15 Q Now, when a subscriber makes an inquiry,
16 they're not necessarily required to input complete
17 consumer identification; is that true?
18 MR. CENTO: Objection to form.
19 A They're required to input the consumer's
20 first name, last name, and current address.
21 BY MR. Szwak:
22 Q Okay. Can they make an inquiry without
23 putting the consumer's address in?
24 A No.

1 Q There's no mechanism for them to make an
2 inquiry by inputting a Social Security number alone?
3 A And to return a credit report?
4 Q To return any information report.
5 A There's different products that might
6 return other reports based on Social Security number
7 alone, but that's not a credit report.
8 Q Okay. So in order to -- in order to
9 retrieve what -- what is generally termed a full
10 credit report, they must enter the consumer's first
11 name, last name, and full address, meaning street
12 number, street name, city, state, and ZIP?
13 A Yes.
14 Q Okay. Now, from your review of
15 TransUnion's records, is it your testimony that you
16 don't know what was inputted in order to create
17 Exhibit 2 and 3?
18 A Yes, that's true.
19 Q Okay. And where -- where is the audit
20 trail or where is the record showing what was
21 actually inputted by Brighton Ford?
22 A I don't have access to that.
23 Q Okay. Is it something that TransUnion
24 maintains?

1 A Yes.
2 Q And what is the -- the exact descriptive
3 title?
4 A I would normally look at a billing log.
5 Q A billing log would be the information that
6 is sent to the subscriber in order to invoice them
7 for the inquiry?
8 A The billing log I would look at is an
9 internal TransUnion document that -- I don't believe
10 that that's actually sent out to the subscriber,
11 though. I think --
12 Q Is there any other record that contains the
13 actual information that was keystroked at the time
14 of inquiry?
15 A Yes.
16 Q And what is that record called?
17 A A Journal 20.
18 Q And where is a Journal 20 maintained?
19 A It's maintained at TransUnion.
20 Q Okay. Is there any other record that would
21 maintain that information as to what was keystroked
22 at the time of inquiry?
23 A The complete -- are you asking for the
24 complete input?

1 Q Yes, ma'am. I'm asking you about each and
2 every different type of document or record at
3 TransUnion that -- that maintains or archives, where
4 you can go back and review and determine exactly
5 what the subscriber keystroked in at the time of
6 inquiry.
7 A No. Then there's no other document that I
8 can think of.
9 Q Okay. And -- and as we sit here, we
10 don't -- we don't know because we don't have the
11 record of -- you called it a Journal 20; is that
12 right?
13 A There is a Journal 20.
14 MR. CENTO: They're the documents I sent
15 you, David.
16 THE WITNESS: Not a Journal 20.
17 BY MR. Szwak:
18 Q Let me ask you. In the Journal 20
19 documents that you have, if you could pull those
20 out.
21 MR. CENTO: Oh, maybe I'm wrong. I'll
22 let --
23 A No.
24 MR. CENTO: -- Lynn explain.

1 A No. There are no Journal 20 documents
2 here.
3 BY MR. Szwak:
4 Q Okay. What about any other records that
5 you have in front of you that pertain to the actual
6 information keystroked at the time of inquiry?
7 A From these? For this inquiry that we're
8 looking at here?
9 Q Yes, ma'am. Let's talk about this inquiry,
10 and then I'll ask you about any others.
11 A There's an Invoice Detail here, but this
12 isn't necessarily the actual input that was keyed
13 in. It's some of the actual input that's keyed in,
14 but it's not complete.
15 Q Okay. And what is that document? What's
16 the Bates numbers on that document?
17 MR. CENTO: It hasn't been Bates numbered
18 yet, but it was part of the package that I faxed
19 over this morning. It's the one -- the page
20 she's looking at, it says -- it has a little
21 heading -- it says TransUnion, Chicago Division,
22 Invoice Detail. And then there's some header
23 information. And then there's a big blank
24 space; and it says "Redacted"; and then there's

1 one line of information. Do you see it?
2 MR. Szwak: I'm looking for a document that
3 looks like that, and I don't --
4 MR. CENTO: Towards the -- it would be
5 after -- it should have been right after the --
6 the Common Form Tax.
7 MR. Szwak: Okay. I think I do -- I have
8 identified what -- what you're referring to.
9 Q And it is called an Invoice Detail. And
10 let me ask you. Which inquiry would this Invoice
11 Detail pertain to?
12 A This inquiry on this Invoice Detail
13 pertains to the Brighton Ford inquiry on
14 November 30th, 2000, at 1527 Central Time.
15 Q Okay. And that is the inquiry that we're
16 looking at and the -- and the subject of Exhibit 2
17 and 3?
18 A Yes.

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