XPN BADGE NUMBERS, CASS, SPECIAL SERVICES, MUST READ

Names, Types, Descriptions, Testimony
David A. Szwak

XPN BADGE NUMBERS, CASS, SPECIAL SERVICES, MUST READ

Postby David A. Szwak » Wed Nov 16, 2005 9:32 pm

THE DISCLOSURE LOGS AND D/R LOGS LIST EMPLOYEE BADGE NUMBERS. TYPICALLY THESE ARE "TEAM LEADER" BADGE NUMBERS ONLY SO AS TO MASK THE IDENTITIES OF THE LOW LEVEL EMPLOYEES WHO ACTUALLY DID THE WORK. OFTEN STILL, CASS MEMBER BADGE NUMBERS ARE INSERTED SO XPN CAN PUT FORTH A STOCK WITNESS WHO WILL CLAIM THAT HE/SHE DID THE ACTUAL WORK PERFORMED. MANY TIMES THE EMPLOYEE WILL NOT RECALL THE THOUSANDS OF EVENTS TAKING PLACE IN A YEAR SO THEY MAY BE AN UNWITTING DUPE AS A WITNESS BELIEVING THEY DID THE WORK DUE TO THEIR BADGE NUMBER APPEARING IN THE RECORDS. BADGE NUMBERS LISTING FIRST AND LAST NAME INITIALS BUT WHERE THE LAST NAME INITIAL IS LISTED AS "X" DESIGNATES A CASS [SPECIAL SERVICES] AGENT AS THE PERSON ALLEGEDLY HANDLING THE PARTICULAR TRANSACTION

*************

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.

30
2 Q. Okay. I want to move into another area now and
3 ask you: Carla Blair, is she still with Experian?
4 A. Yes.
5 Q. Is she still working in -- with the CASS system?
6 A. Yes.
7 Q. When I say the CASS system, the CASS department,
8 the special services department?
9 A. Yes.
10 Q. Special services is different from some of the
11 other departments. I understand that it's a legal liaison
12 department; is that correct?
13 A. You may call it like that. We do some legal work
14 in that department.
15 Q. You handle, perhaps, requests from outside counsel
16 to help with researching issues?
17 A. Yes.
18 Q. You handle governmental and incoming attorney
19 requests or letters?
20 A. Yes.
21 Q. What other activities are performed by the CASS
22 department?
23 A. We handle subpoenas that come in regarding credit
24 reporting. We also handle anything coming in from the
25 Federal Trade Commission.

31
1 Q. Are the members of the CASS department, the
2 employees who are regularly proffered as deponents in
3 lawsuits?
4 A. Some of the CASS members are.
5 Q. Do you know of any employees outside of the CASS
6 department that are ever proffered from the Allen center?
7 A. By "proffered," what do you mean that --
8 Q. Put forth as deponents or corporate
9 representatives for purposes of corporate depositions?
10 A. They're not designated as corporate reps, but
11 other agents have been deposed.
12 Q. When you say other agents of the special services
13 department?
14 A. And of the rest of the national consumer
15 assistance center.
16 Q. Do you know, from your review of the records, who
17 the actual Experian employees who handled Mr. Jensen's
18 disputes and complaints and requests for information from
19 Experian?
20 A. Not from the admin report.
21 Q. Let me see if I can help you with some of the --
22 the various names that have appeared in here and the codes.
23 One is the name of John Sprague. Do you know Mr. Sprague?
24 A. Yes.
25 Q. Who is he?

32
1 A. John Sprague is the vice president of the national
2 consumer assistance center.
3 Q. Does he normally handle consumer complaints?
4 A. No.
5 Q. He would be called in either in a special case or
6 when there's a problem?
7 A. No.
8 Q. Would there ever be a reason for him to become
9 involved in a con -- a particular consumer's dispute?
10 A. Only if requested by plaintiff's attorney.
11 Q. In this case, did the plaintiff's attorney request
12 Mr. Sprague to become involved in this matter?
13 A. Not that I know of.
14 Q. I was curious. He is not listed in the Experian
15 disclosure in this case as having been involved in this
16 matter. Do you know whether he has any knowledge of the
17 matters raised in this lawsuit?
18 A. He doesn't typically work with consumers, so I
19 would say not.
20 Q. Okay. Does he have a badge number within
21 Experian?
22 A. No.
23 Q. My review of the various D/R logs and other things
24 raised a number of badge numbers that we could not identify
25 and have a cross-reference for them. I take it that the

33
1 Badge No. CB-800453 would be Carla Blair?
2 A. Yes.
3 Q. The Badge No. GX-022353, I could not identify. Do
4 you know who that person would be?
5 A. I don't.
6 Q. There is another badge number, CX-800496. I take
7 it that that is someone from special services, but I cannot
8 identify the initials CX. Do you know who that is?
9 A. I don't -- I wouldn't say that it's from special
10 services, so I don't know.
11 Q. Would be numeric designations beginning with 800
12 and then the remaining three digits designate a special
13 services badge number?
14 A. Not particularly.
15 Q. Would it designate a particular team that a
16 person's assigned to?
17 A. No.
18 Q. The -- in connection with my review of Experian's
19 disclosure, they have only identified Carla Blair as having
20 knowledge of the facts involved in this case. Were you
21 able to identify any of the other employees at all involved
22 in handling this matter?
23 A. I don't know. I haven't looked at all of -- I've
24 looked at all the D/R logs, but I don't know all the badge
25 number and who they represent.

34
1 Q. Is there a listing of that information that's
2 available at Experian?
3 A. Of the badge numbers?
4 Q. Yes, ma'am.
5 A. I believe they can be decoded and names can be
6 associated with them.
7 Q. If possible, could we please get that information?
8 A. Yes. Of the ones on the D/R log?
9 Q. Yes, ma'am. Subject to the protective order
10 that's in the case, just so that we know who actually
11 handled the transactions.
12 A. Okay.
13 Q. I assume that the names Carla Blair, Kelly
14 Currie -- some of the other people who I've come to know
15 at Experian -- those are their true names, not just desk
16 names; is that correct?
17 A. Oh, that's correct.

David A. Szwak

Postby David A. Szwak » Sun Nov 27, 2005 2:58 pm

1
1 UNITED STATES DISTRICT COURT
IN AND FOR THE WESTERN DISTRICT OF LOUISIANA
2
3 LARRY E. CARRIERE, II *
*
4 V. * Civil Action No.
* CV03-1340-S
5 EXPERIAN INFORMATION *
SOLUTIONS *
6
7
8
9
10 ORAL AND VIDEOTAPED DEPOSITION OF
11 SHANNON LEE STAFFORD
12 JUNE 8, 2004
13
14
15
16
17 ORAL AND VIDEOTAPED DEPOSITION OF SHANNON LEE
18 STAFFORD, produced as a witness at the instance of the
19 Plaintiff, taken in the above-styled and numbered cause on
20 the 8th day of June, 2004, at 9:57 a.m., before Frances M.
21 Blacha, a Certified Shorthand Reporter in and for the State
22 of Texas, reported by machine shorthand, in the offices of
23 Jones Day, 2727 N. Harwood Street, Dallas, Texas 75201, in
24 the City of Dallas, County of Dallas and State of Texas, in
25 accordance with the Federal Rules of Civil Procedure.
89
5 Q Okay. Now in this case there's a -- it appears
6 to me that Sandra Moore would have involved the initiation
7 of the reinvestigation reflected on Page 11 of Exhibit C,
8 but yet on the back end, whatever reinvestigation was
9 performed, that a different lady at Experian would have
10 entered the response code. Is that true?
11 A There would have been a different agent that
12 would have evaluated the information that we received and
13 updated or deleted or whatever action was taken to the
14 account.
15 Q Do you know who PE is as denoted on the Agent ID
16 PE018465?
17 A I believe that belongs to Patti Evans, but I
18 don't have all of their badge numbers memorized.
19 Q Okay. Now, when we talk about badge numbers on
20 this D/R log, are these people team leaders or are these the
21 actual individuals within the team that are performing the
22 functions?
23 A They're the individual members on the team
24 performing the functions.
25 Q So we never get a situation where just the team

90
1 leader's badge number is being reported in connection with
2 any activity on the file; right?
3 MR. McLOON: Objection. Vague.
4 A Well, they may do some.
5 Q If the team leader themselves does the function?
6 A Right. Then their badge number would be
7 reflected.
8 Q But individual employees who perform functions at
9 Experian, they don't ever use their team leader's badge
10 number?
11 A Right.


Return to “Experian Secret Documents”

Who is online

Users browsing this forum: No registered users and 4 guests