Names, Types, Descriptions, Testimony
David A. Szwak


Postby David A. Szwak » Tue Nov 22, 2005 9:59 pm

2 Q. (BY MR. Szwak) That is the -- that is the
3 response to his request in November?
4 A. Yes.
5 (Exhibit No. 11 was marked.)
6 Q. I want to show you Experian Document No. 158. Is
7 that a -- a single page out of a policy and procedure
8 manual at Experian with regard to mixed file issues?
9 A. These are the texts of the paragraph that are the
10 system letters that we use.
11 Q. Those are form letters which can be generated in a
12 single key stroke to be sent to the consumer to address
13 some issue that Experian has with their complaint?
14 A. Yes.
15 Q. Those letters in a single key stroke would take, I
16 assume, less than a second to generate. It would not be
17 something actually handled by the CRS agent?
18 A. They have to generate it into the system, and at
19 that point it's mailed out.
20 Q. With a key stroke, they would generate the letter,
21 and someone else would take care of stuffing the envelope
22 and sending it?
23 A. Yeah. It's system generated.
24 Q. And one of the system-generated letters at this
25 point in time, 1998/1999, was the system letter No. 19,

1 which says, "We believe that we can best answer your
2 questions on the phone," right?
3 A. Yes.
4 Q. "Please call us at the number listed on the credit
5 report. When you call, please give us the report number
6 listed at the top of the report." Is that correct?
7 A. Yes.
8 Q. What phone number is listed on the report?
9 A. I believe at that point in time it was an 800
10 number, but we've changed our numbers, so I can't tell you
11 exactly which one.
12 Q. Is it your belief that that's the same phone
13 number which was at issue with the Federal Trade
14 Commission?
15 A. I don't know.
16 Q. Is that the main line coming into the call center?
17 A. Yeah -- well, they've changed over the past
18 several months.
19 Q. One of them was an 888 number?
20 A. 888-Experian is one that people can call in to
21 request a copy of their credit report.
22 Q. And that's the automated system?
23 A. Yes. It is now.
24 Q. Okay.
25 A. It had different functions before.

1 MR. Szwak: Let's -- if you need to take a
2 break, let me know because we're about to kind of shift
3 into a different topic.
5 MR. Szwak: It's up to you.
6 THE WITNESS: I'm fine.
7 MR. Szwak: Okay.

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