Names, Types, Descriptions, Testimony
David A. Szwak


Postby David A. Szwak » Wed Nov 09, 2005 9:15 pm

2 Q. Now, when I looked at the admin report, there's

3 some exclusion codes -- what I call suppression codes, the

4 EXCL. Can you tell me what the different suppression codes

5 are and what they mean?

6 A. Well, if you could point one -- some out, I do

7 know --

8 Q. Sure. On Experian 178, there's an "EXCL equal 1"

9 on several of the address items. And they also appear in

10 connection -- well, there's another exclusion code --

11 there's another "EXCL 1" -- "equal 1" on page 182.

12 A. The "EXCL equals 1" is a deletion code. It's a

13 soft deletion code. It has a monitor flag.

14 Q. When you say "a monitor flag," what does that

15 mean?

16 A. Well, that is a special procedure we put on the

17 file to ensure that that trade line or that address being

18 reported the exactly same way doesn't reappear.

19 Q. So in essence, if -- if a creditor subsequently

20 reported that address in connection with an account, it

21 would automatically suppress it by virtue of the "EXCL

22 equal 1" suppression notation?

23 A. Yes. If it was an exact duplicate.

24 Q. And it would also delete that from appearing in

25 the personal identification section of a report?


1 A. Yes.

2 Q. Now, it would have to be that exact address,

3 correct?

4 A. Exactly.

5 Q. So if there was any deviation of that address,

6 say, instead of saying "Apartment No. 4," it said "Suite

7 4,"that might make a difference in an address as it's read

8 by the system?

9 A. Yes.

10 Q. But as it's shown there, the suppression function

11 would, for example, on page 178, as it's shown suppressing

12 a 4160 MT Highway 37, Libby, Montana, the particular ZIP.

13 If that exact address is again reported, it should be

14 suppressed from appearing in any report?

15 A. Yes, it should be.

16 Q. Would that apply across all of the different PIN

17 numbers or just this one file as we define by virtue of PIN

18 number?

19 A. I'm not -- I'm not sure on that. It should apply

20 on all the different PIN numbers, but I'm not sure that

21 that always happens.

22 Q. So you believe that a suppression function invoked

23 in one particular file would cause the suppression across

24 other files that might be merged together to form a single

25 credit report?


1 A. Yes. I believe that happens, but it -- there are

2 times when it may not.

3 Q. Do you know if that ever occurred in this

4 particular case?

5 A. I don't know.

6 Q. Now, there are "EXCL equal 1" in connection with

7 trade lines. I gather that that particular suppression

8 function would indicate that if that particular account is

9 reported again in connection with the address that is

10 shown, that it would suppress that account?

11 A. Yes.

12 Q. Now --

13 A. If it's been reported exactly the same way.

14 Q. Okay. Is the "EXCL equal 1," when shown as a

15 suppression in connection with a trade line, does that key

16 off of the -- the address that is suppressed or does it key

17 off the trade line information?

18 A. It keys off the trade line information.

19 Q. So a moment ago, I may have misstated my question;

20 you may have agreed with me. The suppression function in

21 connection with an account would key off of the subscriber

22 name and their account number?

23 A. Yes.

24 Q. Or perhaps the subscriber code and their account

25 number?


1 A. It keys off the exact information on -- all of the

2 information on the account.

3 Q. Now --

4 A. If there's -- and the reason why I state that is

5 because if there is any kind of derivative of that, it

6 would not always prevent the information from appearing.

7 Q. If this particular subscriber, such as shown on

8 page 182, Elan Financial STL, if they had sold that

9 particular account to another subscriber who subsequently

10 reported under their own code with the same account number,

11 it would not suppress that, would it?

12 A. No. It would not.

David A. Szwak

Postby David A. Szwak » Wed Nov 09, 2005 9:16 pm

25 Q. It was an exclusion No. 1, which you've identified


1 for me is a soft delete with a monitor flag?

2 A. Yes.

David A. Szwak

Postby David A. Szwak » Mon Nov 21, 2005 9:05 pm

15 Q. So you would suppress the address with a 777
16 function, and it would knock out any accounts that reported
17 that exact address?
18 A. Yes.
19 Q. And the "EXCL equal 1" is the opposite. You could
20 place it with regard to -- let's see, you would place it,
21 and it would just suppress the entire account?
22 A. Yes.
23 Q. Now, there is an "EXCL equal 999" listed on page
24 187. Do you know what that particular code is?
25 A. Yes. That's another code -- exclusion code that

1 is produced by the creditor on their individual tapes if,
2 for some reason, they wanted to suppress an account to do
3 some maintenance on the file.
4 Q. Okay. So exclusion 2 is just them saying, "This
5 is an inactive account, but we may want to reactivate the
6 reporting on it." The 999 suppression function is one they
7 produce by automated means to you, and it says, "We're
8 going to block this account and do maintenance on it
9 internally, and maybe we'll report it at a later time or
10 maybe not"?
11 A. Yes, that's -- that could happen.
12 Q. Are there roughly a thousand different codes or...
13 A. I have no idea. I don't think there's that many.
14 Q. I just noticed that 999 is used and there's a 123
15 used. I was curious if maybe there were a thousand
16 different codes?
17 A. I don't think so, no.
18 Q. You've never used a thousand different codes, have
19 you?
20 A. No. No.

David A. Szwak


Postby David A. Szwak » Mon Nov 21, 2005 10:18 pm

25 Q. What is -- is the "SD equals 1"? Is that the soft

1 delete notation?
2 A. Yes.

David A. Szwak

Postby David A. Szwak » Sun Nov 27, 2005 4:23 pm

1 Q And if you soft delete something and suppress it,
2 it's shown with an exclusion code, an EXCL code, in the
3 administrative report; correct?
4 A If a particular trade item was removed from the
5 credit report or excluded, there would be an exclusion
6 number set aside to it.
7 Q And you've picked up on that. On the page you're
8 looking at, Experian 463, it's a page in the Exhibit A,
9 there's a Chase NA account, the third one down, that shows
10 an EXCL code. It says EXCL equals one. Do you see that
11 reference?
12 A Yes.
13 Q Would that be an indication that Experian has
14 suppressed that item from Mr. Carriere's credit report as of
15 the date of this Exhibit A?
16 A Yes.
17 Q Now, there are different numerical codes, maybe
18 1, 2, 3, 4, et cetera, which relate to different manners in
19 which that item came to be suppressed; is that true?
20 A When you say manner, reason --
21 Q Well, the way it happened.
22 A Yes.
23 Q I mean -- and I'm not trying to play a vernacular
24 game. I'm asking you if one way might be that the creditor
25 reported to Experian in an automated format asking you to

1 remove it out of the file. Is that one way someone could
2 remove something?
3 MR. McLOON: Objection. Questions
4 pertaining to the data system between subscribers and
5 Experian are outside the scope of this witness's designation
6 under Rule 30(b)(6) and there's no foundation for her
7 testimony. You may answer.
8 A Well, it's my understanding that, yes, that's one
9 way in which data could be removed is based on the request
10 of the subscriber.

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