XPN SPOILATION:ZEROING OUT NAME & ADDRESS ROW ELEMENTS

Names, Types, Descriptions, Testimony
David A. Szwak

XPN SPOILATION:ZEROING OUT NAME & ADDRESS ROW ELEMENTS

Postby David A. Szwak » Mon Nov 21, 2005 6:19 pm

1
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. *
8
9 *********************************************************
10 ORAL AND VIDEOTAPED DEPOSITION OF CAROLYN HELM
11 AUGUST 16, 2000
12 VOLUME 1
13 *********************************************************
14
15
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.

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24 Q. Okay. Looking at that Chase item on Experian 181 [Experian's Administrative "Admin" Report],
25 does it also appear to have the name -- the name

64
1 cross-reference is zeroed out again and the address is
2 zeroed out
.
3 A. Yes.
4 Q. Do you see that reference?
5 So at least from what the admin is telling us, there
6 is no name or address reported in connection with this
7 particular Chase item, true?
8 A. Not at this time.

9 Q. You say "not at this time." Is there ever a time
10 that there might have been a name and address?
11 A. There could be. The 000, both on the name and
12 address, is not an indication of it always having been
13 listed that way
.

14 Q. But at the time this report was generated and the
15 item was placed into the admin report, that's what it was
16 shown as?
17 A. Well, at the time this report was generated, this
18 is what it is indicating now. But that doesn't mean the
19 Chase account has always had that.

20 Q. But how would the Chase account make its way into
21 this admin report unless it had had some identifiers
22 associated with it?
23 A. Well, that's true. But we don't know what they
24 are now.

25 Q. But according to this report, there is no name, no

65
1 address, and no social security number associated with the
2 Chase item; is that true?
3 A. According to that report as it is now.
4 Q. What possible identifier is there left to
5 associate this item with Mr. Jensen?
6 A. Well, if it was on -- if there was any identifying
7 information associated with it prior to this report, that
8 would be an indication of it being on the report.

9 Q. Well, let's say, for example, that the particular
10 name and address that are actually associated with this
11 Chase account are just not listed on this admin report, is
12 that a possible explanation for why the name and address
13 are zeroed out on this admin?
14 A. I'm sorry. I didn't follow you.
15 Q. If the -- if the cross-reference name and address
16 are not listed in the cross-reference system on page 178 on
17 this same admin, is that one explanation for why the name
18 and address would be zeroed out as it is on the Chase and
19 Elan Financial?
20 A. I don't -- I can't answer that because I wouldn't
21 know. There's different reasons why that name and address
22 row is zeroed out. Sometimes it's through investigation
23 and the updating of the file.

24 Q. Is it your belief that this Chase account was ever
25 suppressed?

66
1 A. I don't believe it was.
2 Q. So someone -- it could be suggested that someone
3 went in, looked at this particular Chase account at
4 Experian, and zeroed out the name and the address on it,
5 but never suppressed it?
6 A. I don't believe that that could happen.

7 Q. You don't --
8 A. If there was an investigation done and it was
9 suppressed and information came back to be deleted, it
10 would have been suppressed.

11 Q. Well, I mean, I'm asking you for your -- I guess,
12 your educated opinion on why this Chase account was
13 never -- if it was disputed -- and we have records to show
14 it was disputed multiple times -- and this is a 2000 --
15 February 1, 2000, admin report, it shows the Chase, it
16 shows it in derogatory status, it shows no name associated
17 with it in the cross-reference log, it shows no address
18 associated with it in the cross-reference log, it shows no
19 social security number at all, and yet it's not suppressed,
20 how did it get to be in Mr. Jensen's file?
21 A. I don't know. Therefore, that's a system issue.

22 Q. Okay.
23 MR. Szwak: Why don't we take a break for a
24 minute? I don't want you to feel like you're getting
25 beaten on.


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1 THE WITNESS: Okay.
2 THE VIDEOGRAPHER: We're off the record at
3 11:25.

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