XPN WHAT IS CASS [SPECIAL SERVICES]?

Names, Types, Descriptions, Testimony
David A. Szwak

XPN WHAT IS CASS [SPECIAL SERVICES]?

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

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 8:30 am

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.

60
22 Q Okay. Can you tell me who made -- whose badge
23 number appears on March 12, 2003, as making all of those
24 name changes, please?
25 A I believe this -- the agent that processed those

61
1 updates was Robin Jones.
2 Q Does she work in CASS or does she work elsewhere?
3 A She works in the National Consumer Assistance
4 Center.
5 Q But not under the CASS department?
6 A Right.
7 Q Does she work in a specific department or does
8 she generally work in the group handling reinvestigations?
9 A She works in our special services area, which is
10 also a department that processes investigation requests.
11 Q Now, that's not the same as the CASS department;
12 right?
13 A Right.
14 Q Okay. But it's called special services?
15 A Yes.
16 Q And why is it different from the ordinary process
17 of consumer disclosures and reinvestigation?
18 A They process the disputes in the same fashion
19 with the request for investigations. However, they may --
20 they're a little bit more specialized with assisting
21 consumers that may have been victims of fraud or may
22 potentially have a mixed file situation.
23 Q She works in the same area with Rebecca Holt?
24 A Same area. Different team.
25 Q Okay. And they handle primarily fraud files or

62
1 mixed file issues?
2 A Yes.


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