Equifax Pamela Smith Deposition

30(b)(6) Equifax (Pamela Smith)
September 9, 2014
Wells Fargo Bank, N.A. v.

Itzhak Benson, et al
Page 1
IN THE CIRCUIT COURT FOR THE
17th JUDICIAL CIRCUIT IN AND FOR
BROWARD COUNTY, FLORIDA
GENERAL JURISDICTION DIVISION
WELLS FARGO BANK, N.A.,
)
successor by merger to WELLS
)
FARGO BANK SOUTHWEST, N.A.,
)
f/k/a WACHOVIA MORTGAGE, F.S.B.,)
f/k/a WORLD SAVINGS BANK, FSB, )
)
Plaintiff,
)
)
vs.
)
)
ITZHAK BENSON, et al.,
)
)
Defendants.
)
________________________________)
CASE NO.:
2009-CACE-62642
30(b)(6) teleconference deposition of

EQUIFAX, INC. (Pamela Smith), taken on behalf
of the Defendants, pursuant to the stipulations
contained herein, reading and signing of the
deposition being reserved, in accordance with
the Florida Rules of Civil Procedure, before G.
Paige Alexander, Certified Court Reporter, at
5855 Sandy Springs Circle, Suite 140, Atlanta,
Georgia, on the 9th day of September, 2014,
commencing at the hour of 10:31 a.m.
D'AMICO GERSHWIN, INC.
Court Reporters & Videoconferencing
11475 West Road
Roswell, Georgia 30075
(770) 645-6111
www.AtlantaCourtReporter.com
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INDEX TO EXHIBITS (Continued)
Plaintiff's
Exhibit
Description
Marked/First
Identified
P-12
Equifax Report results,

dated 7/18/2013
96
P-13
Report of Credit Cards, Loans

& Other debt of
dated 3/30/2014
96
(All original exhibits retained by Attorney Berman and

no copies are attached hereto.)
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INDEX TO EXAMINATION
Examination by Mr. Berman
Examination by Ms. Spaulding White
74
Examination by Mr. Berman
105
INDEX TO EXHIBITS
Defendants'
Exhibit
Description
Marked/First
Identified
D-1
Subpoena
D-2
Automated Consumer Dispute Verification
D-3
Automated Universal Data Form,

Dated 4/11/2014
D-4
Automated Consumer Dispute Verification,

Dated 3/30/2014
D-5
Automated Consumer Dispute Verification,

Dated 6/12/2014
D-6
Dispute letter to Wells Fargo

Home Mortgage from
dated 6/20/2014
D-7
ACIS printout
D-8
Partial copy of Disclosure/Credit

Report, dated 9/4/2014
D-9
Credit dispute response and/or

credit report, dated 7/3/2013
65
D-10
Credit report, dated 6/3/2014
65
D-11
Reinvestigation process results
23
Min-U-Script
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REPORTER DISCLOSURE OF NO CONTRACT
I, G. Paige Alexander, Certified Court

Reporter, do hereby disclose pursuant to
Article 10.B of the Rules and Regulations of
the Board of Court Reporting of the Judicial
Council of Georgia that I am a Georgia
Certified Court Reporter. D'Amico Gershwin/I
was contacted by the party taking the
deposition to provide court reporting services
for this deposition; D'Amico Gershwin/I will
not be taking this deposition under any
contract that is prohibited by O.C.G.A.
15-14-37(a) and (b) or Article 7C of the Board;
and I am not disqualified for a relationship of
interest under the provisions of O.C.G.A.
9-11-28(c).
There is no contract to provide reporting
services between myself or any person with whom
I have a principal and agency relationship nor
any attorney at law in this action, party to
this action, party having a financial interest
in this action, or agent for an attorney at law
in this action, party to this action, or party
having a financial interest in this action.
Any and all financial arrangements beyond
my/D'Amico Gershwin's usual and customary rates
have been disclosed and offered to all parties.
This, the 4th day of December, 2014.
D'Amico Gershwin, Inc.

________________________________
G. PAIGE ALEXANDER, CCR-B-2115
(1) Pages 1 - 4

September 9, 2014

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FIRM DISCLOSURE OF NO CONTRACT
I, Kelly D'Amico, do hereby disclose

pursuant to Article 10.B of the Rules and
Regulations of the Board of Court Reporting of
the Judicial Council of Georgia that D'Amico
Gershwin, Inc. was contacted by the taking
attorney to provide court reporting services
for this deposition and there is no contract
that is prohibited by O.C.G.A. 15-14-37(a) and
(b) or Article 7C of the Rules and Regulations
of the Board for the taking of this deposition.
There is no contract to provide reporting
services between D'Amico Gershwin, Inc. or any
person with whom D'Amico Gershwin, Inc. has a
principal and agency relationship nor any
attorney at law in this action, party to this
action, party having a financial interest in
this action, or agent for an attorney at law in
this action, party to this action, or party
having a financial interest in this action.
Any and all financial arrangements beyond
D'Amico Gershwin's usual and customary rates
have been disclosed and offered to all parties.
KELLY D'AMICO, CEO

D'AMICO GERSHWIN, INC.
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PAMELA SMITH,
having been first duly sworn, was examined and
testified as follows:
EXAMINATION
BY MR. BERMAN:
Q. Can you state your full name for the
record, please.
A. Pamela Smith.
Q. And where are you employed?
A. Equifax Information Services, LLC.
Q. And your position there?
A. Legal support associate.
Q. So you work in the legal department, in
the in-house legal department?
A. Yes, I do.
Q. Are you a lawyer, a paralegal?
A. I am not.
Q. Are you like a legal assistant kind of
thing or more of like an information manager for the
legal department?
A. Legal support, where I produce documents.
Q. And are you aware that you're here
today -- or let me rephrase the question.
Are you here today as the corporate
representative of Equifax?
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APPEARANCES OF COUNSEL:
On behalf of the Plaintiff:

(Appearing via teleconference)
LINDA SPAULDING WHITE
Attorney at Law
Broad and Cassel
One Financial Plaza
100 S.E. 3rd Avenue
Suite 2700
Fort Lauderdale, Florida 33394
Phone: 954.764.7060
Fax: 954.761.8135
lwhite@broadandcassel.com
On behalf of the Defendants:

JEFFREY N. BERMAN
Attorney at Law
The Berman Law Firm
1111 Brickell Avenue
Suite 2050
Miami, Florida 33131
Phone: 305-371-8223
Fax: 305-371-8159
jberman@thebermanlawfirm.com
On behalf of the Deponent:

JASON F. ESTEVES
Attorney at Law
Equifax, Inc.
1550 Peachtree Street, NE
Atlanta, Georgia 30309
Phone: 404-885-8910
Jason.esteves@equifax.com
Also present:
Min-U-Script
(Appearing via teleconference)
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A. Yes, I am.
Q. To testify on its behalf?
A. Yes.
Q. Because you understand a legal entity
can't speak, so you're here to speak for it?
A. That is correct.
(Thereupon, marked for identification,
Defendants' Exhibit D-1.)
BY MR. BERMAN:
Q. Okay. I'm going to show you a copy of
the document that we've marked as Exhibit 1, which is
the Subpoena for the deposition today. The Subpoena
has yesterday's date, but we agreed to reschedule the
deposition for today; but otherwise, it's still in
effect.
Have you seen this document before?
A. Yes, I have.
Q. And in particular, if you would, please,
turn to -- so Exhibit 1 to the Subpoena is the Notice
of Taking Deposition. There are two exhibits to the
Notice itself, Exhibit A and Exhibit B. Exhibit A is
a list of the topics that we may go into today.
Have you seen this list before?
A. Yes, I have.
Q. And if you turn to the page to Exhibit B,

(2) Pages 5 - 8

September 9, 2014

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the document request, have you seen this list of

documents sought to be produced through the Subpoena
before today?
A. Yes, I have.
Q. And in response to the Subpoena, your
company, through Jason, was gracious enough to produce
some records to us ahead of the deposition.
MR. BERMAN: I appreciate that.
Defendants' Exhibit Numbers D-2, D-3, D-4, D-5,
D-6, D-7, and D-8.)
BY MR. BERMAN:
Q. I just want to go through them, mark
them, and have you identify them by exhibit number and
just describe the document.
A. In regards to Exhibit Number 2, this is
the Automated Consumer Dispute Verification. This is
the electronic reinvestigation dispute; that it was
submitted to Wells Fargo on behalf of
Exhibit 3 is an AUD, which is an
Automated Universal Data Form. It is dated April 11,
2014, and it was generated from Wells Fargo Home
Mortgage, on behalf of
Exhibit 4 is an ACDV, which is the
Automated Consumer Dispute Verification. It is dated
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A. Exhibit 8 is a disclosure, dated

September 4, 2014, on behalf of
And those are all of the documents I have
in front of me.
Q. And Exhibit 8 is -- for a layman, it's a
credit report?
A. That is correct.
Q. Okay.
MS. SPAULDING WHITE: That's the one
dated September 4th?
MR. BERMAN: Yes.
BY MR. BERMAN:
Q. So we've just gone through Exhibits 2
through 8. Did you compile these documents in an
effort to comply with the Subpoena, you personally?
A. I am not the agent that, or the
representative that, compiled those documents.
Q. Okay. Who did?
A. To my understanding, it may have been one
of several other agents within our office.
Q. I see. Okay. Did you review them, or at
least glance at them, before they were produced to us,
in advance of this deposition?
A. I was able to review them after they were
produced.
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March 30th, 2014, on behalf of

Exhibit 5 is another ACDV, submitted to
Equifax, on behalf of
from Wells Fargo
Home Mortgage, and it is dated June 12, 2014.
Exhibit 6 appears to be a dispute letter,
dated June 20th, 2014, from a
in
regards to a dispute at Wells Fargo Home Mortgage
account.
Exhibit 7 is the ACIS printout, and the
ACIS printout provides the results of the
investigation, the actions taken by each agent, and
also how the credit file appeared after the
reinvestigation was completed.
Q. And let me just stop you for one second.
And that's Exhibit 7, the ACIS report.
We've included in Exhibit 7 the last two pages as a
separate -- what appears to be a separate document.
Can you describe that, the last two pages of Exhibit
7?
A. In regards to Exhibit 7 and the last two
pages, which is the maintenance sheet summary, it
outlines all of the actions that were taken by the
agents, any updates or deletions that were made per
their data furnisher's request or by Equifax.
Q. Okay.
Min-U-Script
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Q. And for Exhibits 2 through 8, can you -let me rephrase the question.
Are Exhibits 2 through 8 the business
records of Equifax?
A. Except for the dispute letter, yes, they
are.
Q. And were those records generated during
the normal course and scope of Equifax's business
operations?
A. Yes, they are.
Q. And are they kept and maintained and
stored by Equifax during its normal business
operations?
A. Yes, they are.
Q. Can you give me, as brief as possible -this is a pretty open-ended question, but a brief
synopses of the process of a consumer disputing any
particular item in their credit report.
A. If a consumer contacts Equifax by written
correspondence, we have a vendor, or a contractor,
that goes through, opens the mail, review the
information and route it to a certain queue. And upon
receipt, the indicator receives the written
correspondence, review it, analyze it, and initiate a
dispute verification. It is then sent electronically

(3) Pages 9 - 12

September 9, 2014

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to the disputed data furnishers, and within a 30-day

timeframe, the data furnishers have within 30 days to
respond back to Equifax. Once we receive the
response, the maintenance reviewer or either the
system will review all of the responses, either
update, modify, or delete the information, either
based on the data furnishers' request or based on
Equifax's internal policies.
Q. And the upon-conclusion-of-the-dispute
investigation is something sent to the consumer?
A. Yes. The revised copies of the results
of the investigation is provided to the consumer, if
the current address is being reported on the credit
file.
Q. And by the -- you said revised copy?
A. Yes.
Q. By that, you mean -A. The results of the investigation or
revised copy, which means one and the same.
Q. Does it look like a credit report, with
the little notation at the beginning of it referencing
the dispute?
A. Yes, it does.
Q. And it usually says something like it's
been up- -- if it's a simple process of updating and
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A. What Equifax reports is the information

that has been reported in to us by the data
furnishers.
Q. I'm going to hand you what we've marked
as Exhibit 2, and we'll go into this document in a
little bit more detail than we did a few minutes ago.
You identified this document, I believe,
earlier as -- it's titled Automated Consumer Dispute
Verification; right?
A. That is correct.
Q. Who generates this document?
A. Equifax.
Q. And the purpose of this document is to do
what?
A. The purpose of this document is to
initiate or to forward the disputed information to a
disputed data furnisher on behalf of a consumer.
Q. And in this case, it appears as though
my client, disputed something in a
Wells Fargo Home Mortgage trade line in her credit
report. And if I understand your testimony, Equifax
would take that information, that dispute, and
generate this ACDV?
A. That is correct.
Q. So is it fair to say that all the
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getting the information, updated based on the response

from the information furnisher, it would just say
something like, you know, the information has been
verified and updated, and then here's your report,
here's the current information?
A. Yes, it would state something to that
degree.
Q. And that would be as reported by the
information furnisher?
A. That is correct.
Q. And I know everybody in the room and the
person on the phone knows this, but theoretically,
Equifax's role in the credit world is just to simply
be a middleman, an organizer and middleman, for
information, right, to get information -MS. SPAULDING WHITE: Objection to form.
MR. BERMAN: What?
MS. SPAULDING WHITE: I said objection to
form.
MR. BERMAN: Okay. I'll rephrase the
question.
BY MR. BERMAN:
Q. Does Equifax itself provide any
information on any of the loans that it reports in an
individual's credit report?
Min-U-Script
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information on this -- on Exhibit 2 was compiled or

put on this piece of paper, electronically, probably,
by an Equifax employee or agent?
A. Most of the information reports in the
light typesetting is the information of how the
account was being reported or the information being
reported at the time of dispute. It also provides the
Equifax control number, the date that it was created,
the subscriber code. It also provides the disputed
information, any FCRA relevant information that the
agent will submit. And the bold typesetting is the
responses that we received back from the disputed data
furnisher; which, in this case, is Wells Fargo.
Q. And in the first, or in the upper,
portion of this document, there is the word "trade,"
upper left-hand corner?
A. Yes.
Q. And below that are a bunch of black
boxes, I suppose identifying the information intended
to go to the right; the control number, the date that
the dispute was created, and things like that?
A. Yes.
Q. Do you see the third-from-the-bottom
responder name?
A. Yes, I do.

(4) Pages 13 - 16

September 9, 2014

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Q. It says Christine Nnadi?

A. Yes.
Q. Theoretically, or as far as you know, is
that the person from Wells Fargo who would have
provided the information that's in bold?
A. Yes.
Q. And the information in bold I'm referring
to is the information throughout the report, which you
just testified is information provided in response to
the ACDV by the information furnisher?
A. That is correct.
Q. Now, is this -- this ACDV form when it's
generated by Equifax to go out to the information
furnisher, is it done on a computer?
A. It is done electronically, yes.
Q. It is done electronically. And this
form -- how does that information get to Wells Fargo?
A. Electronically.
Q. Is that through e-OSCAR?
A. Yes, it is.
Q. Is it an Equifax employee that
electronically generates the ACDV and uploads it to
e-OSCAR?
A. If it is through written correspondence,
yes, it is, or by phone. If it's online, it is
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A. Yes.
Q. If I ask a question and you answer it,
I'm going to assume you understood the question. If
you don't understand a question or it's a little
confusing to you, just ask me to -- we can have the
court reporter repeat the question; she can read it
out loud; or I can rephrase it. Okay?
A. Yes.
Q. So on the response side, on the Wells
Fargo side of the dispute, and how they process an
ACDV, do you know if a Wells Fargo employee would be
getting the -- would be downloading -- and if I'm

using the wrong word, tell me -- but would be getting
the information transmitted through the ACDV, through
e-OSCAR, if it would be a Wells Fargo employee that
would get it and then respond?
A. I cannot verify -MS. SPAULDING WHITE: Object to the form;
lack of foundation.
BY MR. BERMAN:
Q. And the answer was?
A. I am unable to verify the process that is
handled through Wells Fargo once the information is
transmitted from Equifax.
Q. Okay. But as far as you understand, the
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submitted through the system by the agent -- I'm

sorry, by the consumer initiating the reinvestigation
process.
Q. Okay. And by the way, I forgot to ask
you some other background questions, or to give you
some sort of guidelines for the deposition. You seem
like a pro, but I'll go through it anyway.
Have you been deposed before?
A. Yes, I have.
Q. So you know the drill?
A. Yes.
Q. We're having a nice conversation, but we
have to remember that there's somebody typing up every
word, so we can't interrupt each other.
A. Yes.
Q. So if I interrupt you, you say, wait,
wait; I was talking. You can do that. You can tell
me to shut up; I was talking. Because, otherwise, the
record is a mess.
I don't want you to guess, nor does Jason
want you to guess. So if you don't know the answer to
a question, if I ask you something that maybe seems
more Wells Fargo related and you know, you can answer.
If you don't know the answer, then just tell me you
don't know. Okay?
Min-U-Script
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responder name, that person that's filled in is the

person that provided the information?
A. Based on the information, yes.
Q. Ultimately?
A. Yes.
Q. Whether it passes from e-OSCAR through
some third party before it gets to Wells Fargo?
A. Yes.
Q. Okay. Is there anywhere in this ACDV
that deviates from your general description that items
in regular font, as opposed to bold, was information
that would have been generated by Equifax, and
conversely, that anything in bold would have been
generated or provided by, in this case, Wells Fargo?
A. There's no other information other than
what was transmitted and what was received.
Q. And your understanding and your testimony
is that transmitted; that is, information by Equifax,
is not in bold, and anything that Equifax received
back from the information furnisher is in bold?
A. That is correct.
Q. Let's go to the -- there's no section
numbers, but if you go to the third grouping of -- on
the page, sort of in the middle of the page, on the
right it says narratives.

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A. Yes.
Q. The information in the first narrative
box: Removes compliance condition codes, account paid
for less than full value -- and the rest -- the other
two lines -A. Yes.
Q. -- that's information that would have
been provided by Equifax?
A. That is the information that was
reporting on the credit file at the time of dispute.
Q. Ah, okay. And so, then, the response
below that -- or the information below that -- if I
understand your testimony, the information in bold,
starting with consumer disputes after resolution;
second line, foreclosure; third line, real estate
mortgage; fourth line, conventional mortgage, all that
information would have been provided by Wells Fargo?
A. That is correct.
Q. As its response to the ACDV?
A. Yes.
Q. Including the word "foreclosure"?
A. That is correct.
Q. So in a perfect world, we can look at
this ACDV and we can see that in and around the months
of June of 2014, perhaps early July 2014, in a perfect
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Defendants' Exhibit D-11.)
BY MR. BERMAN:
Q. I am now going to show you what has been
premarked as Exhibit 11 to your deposition. Can you
identify this document for me?
A. Exhibit 11 is the results of the
reinvestigation process, initiated on behalf of the
plaintiff.
Q. When you say on behalf of the plaintiff,
you mean the results were added to the credit report
or the credit report was updated based on the
information furnished by the plaintiff, Wells Fargo?
A. This reflects the information that we
received from the data furnisher, and whether or not
there was any updates that may have been made or
deletions that may have made, it would have been
notated in the results column.
Q. So is there a narrative in there that
refers to the results of the investigation, in Exhibit
11?
A. Yes, there is. Maybe the second
paragraph from the bottom. It states, We have
researched the credit account and revised the account
number, excluding the last four digits. And then it
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world, prior to this dispute or prior to Wells Fargo's

response to this dispute, there was no reference to
foreclosure in the narratives of the credit report?
A. Based on the information I have here in
front of me, there was no indication of foreclosure
being reported.
Q. And, again, in a perfect world, we can
extrapolate from this ACDV that when Wells Fargo
responded, which it indicates right just in the area
in the upper left-hand corner near Miss Nnadi's name,
that they responded on July 3rd, 2014. When they
responded, it appears, in a perfect world, that they
responded, including in the narrative the word
"foreclosure"; is that right?
A. Yes.
Q. And so what, in a perfect world, should
have happened is, based on this verified information
coming back from Wells Fargo, Equifax would then
update
credit report, and at that
point, after the update, it would include in the
narrative "foreclosure"?
A. That is correct.
MR. BERMAN: Off the record.
(Thereupon, a recess was taken.)
///
Min-U-Script
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goes into the results, and what it states is that the

additional information has been provided from the
original source, and it also states that the date
closed has been updated and a prior -Q. Can I -- let me stop you for one second.
Sorry.
A. Yes.
Q. This first sentence that you read, you
said the original source.
That would be Wells Fargo here?
A. That is correct.
Q. Okay. I'm sorry. Go on.
A. And the next sentence states that the
date closed has been updated. The third is the prior
paying history has been updated, and the status is
reporting correctly.
The last payment date and date of last
activity are reporting correctly. And we also
advised, or informed, the consumer, or the plaintiff,
if you have any additional questions regarding this
item, at their discretion, they may wish to contact
Wells Fargo directly themselves; and provide the
address and telephone number if applicable.
Q. Just so there's no confusion when people
read this deposition later, the plaintiff in this

(6) Pages 21 - 24

September 9, 2014

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case -- this was a foreclosure case, so the plaintiff

is actually Wells Fargo Bank, as the foreclosure
lender.
A. I apologize.
Q. That's okay. So if you want to refer to
the individual, the borrower, in this case, you can
just call her
or the borrower, or
however you want to refer to her. But the plaintiff
is Wells Fargo.
A. I apologize.
Q. And for ease of reference, let's try to
just refer to Wells Fargo as Wells Fargo.
A. Okay.
Q. And so it says the status is reporting
correctly?
A. Yes, that is correct.
Q. And that statement is made because of the
response to the ACDV?
A. That is correct; there was no change -Q. Which we went -A. -- in the status.
Q. I'm sorry. Which is Exhibit 2, and we
went through that?
A. That is correct. On Exhibit 2 where it
has type and write (phonetic), it has M5. At the time
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Consumer Dispute Verification, we were disputing the

status and the prior paying history on behalf of
as well as have Wells Fargo verify all
of the dates reporting; and that is the information
that we received back regarding that information.
Q. And you're looking at and referring to
Exhibit 2, the ACDV?
A. Yes, that's correct.
Q. And included in the bold, which is the
information provided by Wells Fargo in response to the
ACDV, is foreclosure; correct?
A. Yes.
Q. And the rest of the -- the other three
items included in the narratives and the foreclosure
reference, do you see where all those made their way
into the report, which has been marked as Exhibit 11?
A. Yes.
Q. The July 4th -- and let me rephrase.
It's not a report. It's a response to a dispute.
A. That is correct.
Q. Showing the updated trade line.
MS. SPAULDING WHITE: I thought she said
it was the results of the reinvestigation.
A. This is the information that was
submitted back from Wells Fargo, and that is the
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of dispute, that is the status that was being

reported.
In response from Wells Fargo, they
continued to ask Equifax to report the M5 status.
Q. And M5 status means?
A. The M means mortgage and the 5 means that
the account is 150 days or more past due.
Q. And can you correlate -- actually, let's
go down to the actual trade line. Do you see a
reference to foreclosure in the trade line anywhere?
A. On Exhibit 11 -- bear with me for just a
moment. At the bottom where it has the Wells Fargo
Home Mortgage account information, on the last line
above the bold line across the page, it states
consumer disputes after resolution. Then it states
foreclosure; then it states real estate mortgage and
then conventional mortgage.
Q. And that information, that all follows in
all caps, "additional information," on the line above,
everything you just read?
A. Yes, it does.
Q. And so all that additional information
that you just read was provided by Wells Fargo and no
one else?
A. According to the ACDV, or the Automated
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reason why it's notated on Exhibit 11 on that very

last line.
BY MR. BERMAN:
Q. Is it possible that Equifax included the
word "foreclosure" in the update, dated July 4, 2014,
for reasons other than Wells Fargo providing the word
"foreclosure" -- including the word "foreclosure" in
their narrative response to the ACDV, that's marked as
Exhibit 2?
A. Not that I am aware of.
Q. And so as of -- based on Exhibit 11, as
of July 4th, 2014, Equifax was reporting for the Wells
Fargo Home Mortgage trade line, for account number
starting with 512004209, that that loan was in
foreclosure, or had been foreclosed?
A. That is the information that was provided
to Equifax.
Q. And that information, as of that date,
would have been included in the full credit report of
with Equifax?
A. Yes, at that time.
Q. So that if any potential lender were to
pull, or any vendor were to pull,
credit report on July 4th, and through such time that
any updates were done to
credit report

(7) Pages 25 - 28

September 9, 2014

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after July 4th, they would see in this trade line that
we're discussing on Exhibit 11 -- they would see the
word "foreclosure"?
A. Yes.
Q. Unless and until it got updated and that
information was removed?
A. That is correct.
Q. Okay. I'm showing you what's marked as
Exhibit 3. Can you identify this document for me?
A. Exhibit 3 is a Universal Data Form that
was sent electronically to Equifax. It is -- the
subscriber name is Wells Fargo Home Mortgage. It was
created on April 11, 2014. The responder is a Rachel
Howard. It is in regards to a Wells Fargo Home
Mortgage account, starting with
and it
provides account information that they are requesting
to have updated on
credit file.
Q. And this is a two-page document?
A. Yes, it is.
Q. And at the top of the first page, in the
upper left-hand corner are the initials AUD. What
does that stand for?
A. Automated Universal Data Form.
Q. And what is the purpose of this type of
document?
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A. An AUD is not generated based off of a

reinvestigation process. What is generated is an
ACDV.
Q. And then there's a response put on the
same AC- -- ultimately, on the same form. It's the
information being sent by Equifax, through e-OSCAR, to
the furnisher -- here, Wells Fargo -- and the same
document comes back with additional information on it?
A. Yes.
Q. That's the ACDV?
A. Yes, it is.
MS. SPAULDING WHITE: Object to form.
Can you please rephrase?
MR. BERMAN: No. She already answered
it. If it's a bad question, it won't come in
at the evidentiary hearing.
MS. SPAULDING WHITE: Are you-all still
there?
MR. BERMAN: Yes, we're here. Did you
hear my response to your objection?
MS. SPAULDING WHITE: Yes, but then
everything went silent, so I just wanted to
make sure.
MR. BERMAN: Yeah, if it's a bad
question -- I'm not going to rephrase it. If
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A. This is an offline update that a data

furnisher can submit in on behalf of a single
consumer, outside of their regular, or normal, tape
reporting.
Q. And can you tell if this was done in
response to a dispute by
A. I cannot state whether or not this was in
response to a dispute by
Q. It could have been?
A. I'm stating I cannot verify whether or
not this is.
Q. But it's -- not that you know for sure,
but it's possible that it was?
BY MR. BERMAN:
Q. You can answer.
A. Sometimes AUDs are generated based on the
consumer disputing information directly with the data
furnisher. And they would submit an AUD.
This is not generated based on a
reinvestigation process that's initiated by Equifax.
Q. This scenario that you just described?
A. Yes.
Q. Or are you saying that this document, you
can tell it wasn't a dispute with Equifax?
Min-U-Script
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it's a bad question, then it won't come in at

the evidentiary hearing, the answer.
BY MR. BERMAN:
Q. Are you familiar with the various codes
that are used by Equifax and information furnishers?
A. Yes.
Q. So to code foreclosure or past due a
certain number of days, you would be able to look at a
document and see if that code is on there?
A. Yes. But let me just emphasize, there
are many, many, metro two (phonetic) codes, and I do
not know all of them by heart.
Q. Okay.
A. But, yes, I am familiar with those.
Q. Okay. Now, on the second page of that
document, under authorization, it has an individual
named Rachel Howard and her phone number, it looks
like, and then it says date created?
A. Yes.
Q. Can you tell what the date of this AUD
is?
A. April the 11th, 2014.
Q. And what is the rest of the -- what are
the rest of the digits following the year 2014,
starting with 092?

(8) Pages 29 - 32

September 9, 2014

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A. I am not 100 percent sure, but I believe

that is the time: The hour, the minute, and the
seconds.
Q. But you are absolutely sure that this AUD
was uploaded or sent on April 11, 2014?
A. Yes. What I can state for the record is
that it was created. I can't state exactly when it
was sent, but it was created on April the 11th, 2014.
Q. I got you. Do you know on the first page
of Exhibit -A. 3.
Q. Thank you. On the first page, under -towards the bottom, under account information, the
right-hand column about halfway down, it says account
status.
A. Yes.
Q. And there's a 13.
A. Yes.
Q. Do you know what 13 stands for, under
status?
A. I believe it stands for paid and closed
account with a zero balance.
Q. Can you tell from this AUD what
information was changed through it or just what the
new reported information is?
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Consumer Dispute Verification Form. It is

sent/submitted to Equifax on behalf of -- from Wells
Fargo Home Mortgage. And the date that it was created
was March 30th, 2014, and the responder's name is
Rachel Howard. And it provides us with some account
information.
Q. How is this document, Exhibit 4,
different than the ACDV we marked as Exhibit 2? Do
those documents come about as a result of the same
dispute process, or similar dispute process?
A. Well, an ACDV from Exhibit 2 and Exhibit
4 are pretty much one and the same. They're just in
different formats.
Q. Should Equifax, theoretically, have an
ACDV document in the form of Exhibit 2 for the ACDV
that we see reflected in Exhibit 4?
A. Not necessarily. And the reason being is
that Exhibit 2 was initiated by Equifax. Exhibit 4
may have been initiated by another source.
Q. Interesting. Okay. So by another
source, do you mean it could have been a dispute with
TransUnion or a dispute with Experian?
A. Yes.
Q. Okay. And you would get something like
what Exhibit 4 looks like in the normal course when an
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A. I cannot state what information was

changed, only the information that was reported in to
us.
Q. A little bit down below the account
status, still on the right side under account
information, it says special comment code, AU.
Do you know what that stands for?
A. AU, to my understanding, stands for
account paid in full, paid for less than full balance.
Q. So some form of settlement was reached?
That code would suggest that some form of settlement
was reached between the borrower and the lender,
through which not the entire balance was paid, but
some portion was paid?
A. What I can state is based on that special
comment code is that it is stating that there was a
balance that was paid in full, but it was paid for
less than the full balance.
Q. Okay.
A. And we cannot state whether or not it was
through a settlement agreement or what have you.
Q. Okay. Fair enough. I'm going to show
you what is marked as Exhibit 4. Can you identify
this document?
A. Yes, Exhibit 4 is an ACDV, Automated
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individual disputes information on one of the two

other major credit bureaus reports for them?
A. If Wells Fargo or the data furnisher
provides that information to the other credit
reporting agencies.
Q. I see. Is that because these ACDVs all
run through e-OSCAR?
A. Yes.
Q. And the three big players in the credit
reporting industry run e-OSCAR?
A. Yes.
Q. And so is it fair to say, then -conversely, is it fair to generalize that the type of
ACDV in the form that we see that's marked as Exhibit
2 would be an Equifax -- an ACDV originating through
Equifax?
A. That's correct.
Q. I see. Okay.
MR. BERMAN: What's wrong with the form,
just out of curiosity?
MS. SPAULDING WHITE: Well, the way you
ended the question, it may not be
objectionable. But I saw you going towards
information from other credit reporting

(9) Pages 33 - 36

September 9, 2014

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agencies or Wells Fargo.

MR. BERMAN: Okay.
MS. SPAULDING WHITE: But to the extent
that the question was asking and to that -- and
to those credit reporting agencies or Wells
Fargo, objection.
MR. BERMAN: Okay.
BY MR. BERMAN:
Q. Exhibit 4 looks a lot like Exhibit 3 in
that, if I understood your testimony as it relates to
Exhibit 3, you can't tell what -- let me rephrase.
On Exhibit 4, this ACDV, which you've
testified appears to be from a different credit
bureau, or through a different credit bureau, can you
see what information is being disputed?
MS. SPAULDING WHITE: Object to form;
lack of foundation.
BY MR. BERMAN:
Q. You can answer.
A. I'm sorry, can you restate the question
again, please?
Q. I will rephrase it. Can you tell from
Exhibit 4 what information was being disputed in that
ACDV by the individual, by
A. I cannot.
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Christine Nnadi. And it provides account history

regarding an account being held by
Q. And is this Exhibit 5, the ACDV, similar
to what we just discussed for Exhibit 4, the other
ACDV that you produced?
A. Yes, it is.
Q. Does it appear to you as though this ACDV
was not generated, or not initiated, by Equifax?
A. This was created on June 12, 2014. I
believe, according to the dispute letter that
has sent in, her letter was dated
June the 10th. Equifax received it June the 14th, and
her investigation was initiated and started on
June the 17th. So this was not in regards to a
reinvestigation that was transmitted to Wells Fargo by
Equifax.
Q. Does that ACDV, Exhibit 5 -A. Yes.
Q. -- tie in to or is it related to the more
detailed form of ACDV that's Exhibit 2? Is that what
you're saying, that they're related?
A. I am stating, according to the
information that I have here in front of me regarding
Exhibit 5 -- and if you don't mind.
Q. Sure. Of course.
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Q. Can you tell from Exhibit 4 which credit

bureau initiated this ACDV?
A. I cannot.
Q. But you're fairly confident it was not
Equifax?
A. Based on the documents that I have
reviewed, it was not generated by Equifax.
Q. Okay. Which, again, explains why we
don't have a more detailed ACDV?
A. That's correct.
Q. Like Exhibit 2?
A. Yes.
Q. So it would really be beyond the scope of
your testimony here on behalf of Equifax to go into
the details of Exhibit 4?
A. I mean, I am able to answer questions
regarding the information that's placed within Exhibit
4, but the scope of it and what generated that, I
would not be able to verify that.
Q. Let me show you what we have premarked as
Exhibit 5, and if we can just go through this briefly,
in a little more detail.
A. Exhibit 5 is another ACDV. The
subscriber is Wells Fargo Home Mortgage. It was
generated, or created, on 6/12/2014. The responder is
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A. -- and Exhibit 2, these are not in

relation to the same reinvestigation initiated by
Equifax.
Q. I see. Okay.
A. As I mentioned, the date that the ACDV in
Exhibit 5 says it was created on June 12, 2014;
however, Equifax did not receive
dispute letter until June 14th.
Q. I see. Okay. I apologize for not
understanding that.
Now, the responder on Exhibit 5 -A. Yes.
Q. -- the more summary version of the ACDV,
is that -- apparently, the person from Wells Fargo is
Christine Nnadi?
A. That is the name that's listed.
Q. For Exhibit 5.
And, I'm sorry, but I want to make sure
the record is clear. Do you believe that this ACDV,
which is Exhibit 5, was initiated by Equifax or by one
of the other two bureaus?
A. What I can state is based on the
information and the documents that I have reviewed,
the date that Exhibit 5 was created was June 12th,
2014; however, Equifax's reinvestigation process on

(10) Pages 37 - 40

September 9, 2014

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behalf of
did not start until June 17th.
So this was prior to the date that we transmitted the
dispute over to Wells Fargo.
Q. Are there situations where there is an
Equifax dispute through e-OSCAR that's generated by
Equifax that you would have something -- an ACDV form
that looks like Exhibit 5, rather than one that looks

like Exhibit 2?
A. To my understanding, if Equifax initiates
a reinvestigation process, it would be in the
format -- the ACDV would be in the format of Exhibit
2.
Q. So based on the format and based on the
date in relation to the date that Equifax received
June 10, 2014 dispute letter, is it
your testimony that the ACDV that's been marked as
Exhibit 5 was not initiated by Equifax?
A. Yes.
Q. Okay. Let's go into Exhibit 7 in a
little bit more detail.
A. Exhibit 7 is the -- what we call the ACIS
printout. That's A-C-I-S. It consists of three
parts. The first part consists of how the credit file
looked after the reinvestigation process had been
completed. The other section provides the results, or
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Q. Yes.
A. In regards to the disputed Wells Fargo
Home Mortgage account, at the time the investigation
was completed, it was reporting an M5 status, a zero
balance. It indicates the consumer disputes after
resolution, foreclosure, real estate mortgage and
conventional mortgage.
Q. Are you looking at the fourth page of
Exhibit 7?
A. Yes, I am.
Q. It's not paginated, but counting the
pages, it's page four?
A. Yes.
Q. And it's the first complete entry on the
top of that page?
A. Yes, it is.
Q. Okay. And -MS. SPAULDING WHITE: Jeff, I thought you
did the maintenance sheet summary as part of
this exhibit.
MR. BERMAN: I did.
MS. SPAULDING WHITE: It's not just four
pages; is that correct?
MR. BERMAN: No. I'm talking about the
fact that she counted four pages into the
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the comments, that we provided to the consumer, and it

also provides the actions taken by the Equifax agents.
Q. That other part you're referring to is
the last two pages?
A. Yes.
Q. One of the issues in this lawsuit, I
guess the only -- let me rephrase that.
One of the issues still lingering in this
lawsuit is how -- obviously, is how this trade line is
being reported to Equifax and to other major credit
bureaus.
Can you tell me within Exhibit 7 if you
see any information relating to foreclosure?
A. On the Wells Fargo Home Mortgage account?
Q. Correct, on the account that we've been
talking about, the trade line we've been talking
about.
A. May I review the ACDV just so that I -Q. Oh, of course.
A. -- have the correct -Q. Sure.
A. -- account number, please?
Q. Absolutely. This one, the detailed one,
Exhibit 2?
A. Yes. Thank you.
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document, which is how she knows it's page 4.

MS. SPAULDING WHITE: You stated the
exhibit is four pages.
MR. BERMAN: Then I made a mistake. The
exhibit is quite a bit longer than four pages.
MS. SPAULDING WHITE: Okay.
BY MR. BERMAN:
Q. So this top line of the fourth page of
Exhibit 7 reflects the final result of the ACDV marked
as Exhibit 2?
A. It reflects how the account was being
reported. Whether or not there was any updates or
deletions made, it reports how the account will appear
on
credit file at the time the
reinvestigation process was closed.
Q. So it's an internal look at the data that
will ultimately make its way into the -- what will be
the updated credit report for that trade line?
A. Yes, at that time, yes.
Q. And so the data that you see being
provided in bold on Exhibit 2 on the ACDV marked as
Exhibit 2 which includes the word "foreclosure" in
bold provided by Wells Fargo, is reflected on the top
of the fourth page of Exhibit 7, and ultimately made
its way into what we discussed earlier, Exhibit 11,

(11) Pages 41 - 44

September 9, 2014

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which is a response to Mrs.

to the dispute.
That's the end of the dispute process, Exhibit 11?
A. That is correct.
Q. And it gives you a snapshot of the trade
line as of that date for that loan?
A. Yes, Exhibit 11 is the end results, as
well as Exhibit 7 is the end results.
Q. And so you can see the process through
these three exhibits. You can see how all this
information works its way through e-OSCAR, out from
Equifax, and then back from the information furnisher,
or Wells Fargo here, back to Equifax and then
ultimately, reported through an update?
A. To the consumer, that is correct.
Q. To the consumer. And to the world?
A. Yes.
Q. Or to whoever is looking at these credit
reports?
A. Yes, at that given time.
Q. And until such time as that report was
then updated, for whatever reason, theoretically, the
word "foreclosure" would be included in the narrative
of that report?
A. Yes, it would.
Q. From July 4, 2014, onward, until whenever
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A. What it shows is how the account appeared

at the time of dispute. It also demonstrates, or
reflects, the information received back. It also
reflects the agent and the date that the information
was initiated, as well as completed, and any comments
that we provided to the consumer on
Q. Let's go back to Exhibit 2 for just a
minute. I want to make sure that we are clear.
If you look at in the narrative section,
in the middle on the right of Exhibit 2 -A. Yes.
Q. -- the top narrative portion is not in
bold, and that's what was on the narrative section of
the report before this dispute, or at the time of this
dispute?
A. That's correct.
Q. And we keep talking about this dispute,
in general terms. What we're talking about is the
dispute started by
June 10, 2014
letter; right?
A. That's correct.
Q. And does the narrative section, not in
bold, which is the information that was already on the
report at the time include foreclosure?
A. It does not.
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it was updated?
A. That is correct.
Q. And that's because -- that word would
appear because Wells Fargo indicated it should appear
there?
A. Based on the response we received, yes.
Q. Do you see any other entries in Exhibit 7
relating to this same loan that we've been talking
about this morning?
A. In the last two pages, which is
identified as the maintenance sheet summary -Q. The last two pages of Exhibit 7?
A. Yes.
Q. Which is actually in a landscape format,
rather than portrait?
A. That is correct.
Q. Okay.
A. -- it identifies the disputed Wells Fargo
Home Mortgage account.
Q. On the first of those two last pages or
the second one?
A. On the second.
Q. This shows -- rather than showing what
this trade line will look like, this shows sort of the
back-of-the-house investigation notes for this ACDV?
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Q. Is it fair to say, then, that through

this dispute process and the verification, the
verified information obtained by Wells Fargo in
response to the dispute, in effect, added the word
"foreclosure" to the narrative of this trade line?
A. What I can state is that the response we
received back from the data furnisher does indicate
foreclosure.
Q. Other than the two sections of Exhibit 7
that we've gone through, do you see any other areas
where there is information about this loan that we're
talking about this morning?
A. No.
Q. I will next show you what has been marked
as Exhibit 8. Can you identify this document, please?
A. Exhibit 8 appears to be a partial copy of
a disclosure, or a credit file, or credit report.
Q. And it's dated?
A. September 4th, 2014, for
Q. You say a partial copy. Why do you say
that?
A. Well, this is the actual part of the -credit file, which is page 4 of 16
through page 11 of 16. The others have a coversheet.
The additional pages are cover sheets and they are the

(12) Pages 45 - 48

September 9, 2014

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consumer's rights and things of that nature. And

that's the reason I stated partial copy.
Q. So the first three pages that are missing
from Exhibit 8 are not -- have no trade lines on them?
A. That is correct, no trade line
information.
Q. Have no credit reporting information?
A. That is correct. It's -Q. So -- I don't want to use the word
"filler," but what we have in front of you, which is
what was produced by Equifax, is the meat of the
report?
A. This is the actual credit history of
Q. And can you tell me how this report came
about or why it was generated?
A. I believe there was a request submitted
to Equifax and, therefore, this disclosure, or credit
report, was generated.
Q. Do you know who made the request?
A. I cannot remember, right off the top of
my head, because I was not the agent that received the
request.
Q. Do you believe that this report was
generated in response to the Subpoena calling for your
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tape reporting, where a credit or a data furnisher

will update all of their records at one time with
Equifax.
Q. Like in a bulk manner?
A. Yes. They may have that information on a
tape; they submit that information to Equifax; we run
our tapes and the information is updated that way.
Q. Describe these tapes for me, please.
A. Well, I apologize, Jeff, I do not work on
that side. I'm not specialized in that area, so I
cannot validate or verify how that tape reporting
information is loaded into the system.
Q. But it's referred to as tapes?
A. Yes, it is.
Q. And you understand that to be bulk
updates?
A. Yes.
Q. Like Wells Fargo dumps -- without regard
to the number, but let's say, for example, 1,000
individuals' trade lines from Wells Fargo get loaded
in one shot, or however many it is?
BY MR. BERMAN:
Q. How often do the tape uploads happen?
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deposition today?
A. Yes, I do believe that.
Q. Is that Equifax's ordinary practice when
they are subpoenaed for document production and/or for
a deposition, that they will do an update report?
A. Yes. We will print a copy of the credit
file as it appears as of the date of request.
Q. Explain to me the different ways through
which information can change on a particular trade
line. We've already talked about the fact that you
could have an ACDV -A. Yes.
Q. -- which is a dispute that originates
with the individual whose report it is, and we talked
in length about that process. You explained to me
through our discussion over some of the other exhibits
that you could have an AUD, which is just a thing that
comes -- something that comes more information,
updated information, that comes from the information
furnisher, for one reason or another.
Other than those two ways to get updated
information into a credit report or to change the
information in a credit report, are there any other
ways that that could happen?
A. In regards to a trade line, there is the
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A. Well, it depends -Q. I'm sorry. Let me -- I'm sorry to cut

you off. Let me rephrase the question.
MR. BERMAN: I'm rephrasing it.
MS. SPAULDING WHITE: Are you making this
specific for Wells Fargo or just in general?
MR. BERMAN: I'm talking about Wells
Fargo.
MS. SPAULDING WHITE: Well, you didn't
say Wells Fargo.
MR. BERMAN: Okay. Every question will
now be prefaced with the words "for Wells
Fargo" -- the phrase "for Wells Fargo." Okay?
BY MR. BERMAN:
Q. So for Wells Fargo, the only other way
besides an ACDV; that is, a dispute generated through
Equifax by the consumer, or the AUD, which is, one way
or another, information coming on their own from the
information furnisher, the third way is for -- what
you're referring to as tape updates?
A. Yes.
Q. Which are bulk submissions of multiple
individuals' reports.
A. That's correct.

(13) Pages 49 - 52

September 9, 2014

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Q. Is there a fourth or fifth way that a

credit report could be updated?
A. There are other ways that a trade line
may be possibly updated. It could be that an agent or
representative of Wells Fargo may contact Equifax's
business department and request updates. That's very
rare, that creditors will have information updated
that way. Or sometimes consumers may provide
supporting documents to have information updated.
Q. And the fourth way that you described,
would that be by phone or email, in that sort of
informal kind of setting?
A. It could possibly be in that form.
Q. Do you know which of the five ways we've
talked about this morning that information could be
updated in one's credit report for a particular trade
line? Do you know -- let me actually ask you first to
turn to in Exhibit 8 to page 10. So we're on page 10
of Exhibit 8.
A. Okay. Page 10 of 16?
Q. Correct.
MS. SPAULDING WHITE: What is Exhibit 8?
MR. BERMAN: Exhibit 8 the September 4,
2014 Equifax report.
MS. SPAULDING WHITE: Thank you.
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"additional information" in the narrative, do you see

any references to foreclosure?
A. There is no reference to the word
"foreclosure" being reported.
Q. So the September 4, 2014 report reflects
an update or different information than the previous
report, at least the previous report that was provided
to us through Equifax -- or by Equifax, insofar as it
removes the word "foreclosure"?
A. I can state that as of September 4th, in
Exhibit 8, the word "foreclosure" is not being
reported.
Q. And do you also notice -- testing your
memory, or if you want to look at the July 4th, 2014
report, Exhibit 11 -- I can put it in front of you -that also another change, apparent change, is that the
reference in the September 4, 2014 report to account
paid for less than full balance was added, because it
was not in Exhibit 11, the September 14, 2014 trade
line?
A. I can state that it was not being
reported at that time.
Q. Can you tell from Exhibit 11 itself how
and why specifically this information was updated?
A. Well, in Exhibit 11, this information was
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BY MR. BERMAN:
Q. Can you -MS. SPAULDING WHITE: And what page are
you on?
MR. BERMAN: We are on page 10 of 16.
MS. SPAULDING WHITE: Okay. Thank you.
BY MR. BERMAN:
Q. It appears there are two Wells Fargo Home
Mortgage trade lines on this page. Can you identify
which -- can you tell which one is the one that we've
been talking about this morning?
A. If I can look at Exhibit 2?
Q. Sure. And by the way, you can look at
any of these exhibits at any point you'd like just to
sort of get your bearings.
A. Thank you. The Wells Fargo Home Mortgage
account that's reporting as the first Wells Fargo Home
Mortgage account on page 10 of 16 underneath the TD
Auto Finance account.
Q. Account Number 512004209?
A. Yes, it is.
Q. And whatever follows?
A. Yes.
Q. In this report, on this trade line that
you've just identified, following the words
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updated based on the response from Exhibit 2, the ACDV
response that we received.

Q. I'm sorry. I meant -- I asked the wrong
question.
Same question with reference to Exhibit
8; that as compared -MS. SPAULDING WHITE: What -MR. BERMAN: Go ahead.
MS. SPAULDING WHITE: I'm sorry, I didn't
hear what you said.
MR. BERMAN: I will ask the question
again.
BY MR. BERMAN:
Q. Can you tell me specifically the manner
in which the information which we just identified as
being updated when comparing the July 4, 2014
document, labeled Exhibit 11, and comparing it to the
September 4, 2014 document, that's marked as Exhibit
8?
MS. SPAULDING WHITE: 8.
A. In regards to Exhibit 11, the results of
the reporting of the Wells Fargo Home Mortgage account
is in regards to the reinvestigation that was

initiated by Equifax.
From looking at Exhibit 8 on page 10 of

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September 9, 2014

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16, it appears that the items as of the date reported

is July 16, 2014, and this is after the
reinvestigation process by Equifax.
BY MR. BERMAN:
Q. So within Exhibit 8, on the first of the
two, the top Wells Fargo Home Mortgage trade line on
page 10 -A. Yes.
Q. -- you just indicated -- oh, I see. On
the left side, second item on the left, items as of
date reported?
A. Yes.
Q. And so what you're saying is that as of
July 16, 2014, that you no longer have a reference to
foreclosure?
A. That is correct.
Q. But the doc- -- have I marked all the
documents that -- have I marked all the documents that
have been produced by Equifax in response to the
Subpoena as exhibits?
A. To my understanding, yes.
Q. And within those exhibits, within those
documents produced by Equifax, are there included an
AUD, an ACDV response, or any other documentation
which you can tie to an update done apparently on or
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to any Wells Fargo Bank or Wells Fargo Home Mortgage
accounts that are in the name of Mrs.

And so -MS. SPAULDING WHITE: And I want to go on
the record -- because you never responded to my
email -- that I objected to the time, the scope
of time in your Subpoena and that it should be
limited to the approval of the settlement on
June 20, 2013, forward -MR. BERMAN: I'm not asking.
MS. SPAULDING WHITE: -- nothing prior -MR. BERMAN: I understand. And although
I didn't say, yes, you're absolutely right, I
won't ask any questions, I don't necessarily
know if you're right, but I'm not asking
questions about anything before the date of the
settlement agreement. So don't worry.
MS. SPAULDING WHITE: Okay. Well, when
you're asking her to respond, it needs to be
limited to that time, from that day to current.
MR. BERMAN: Okay. If I ask a question
that offends you, you can object and we can
deal with it. But I don't think it's going to
be a problem.
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around July 16, 2014?

A. There are none that have been located.
Q. There are none that have been located?
A. No. It's a possibility -- and I'm only
speculating -- that from the time this investigation
was completed on July the 4th and the last time Wells
Fargo updated their records with Equifax was on
July 16th; therefore, it could have been tape reported
and there would not be any manual hard copies to
produce.
MR. BERMAN: Okay. Let's go off the
record for a second.
(Thereupon, an off-the-record discussion
was held.)
BY MR. BERMAN:
Q. I'm going to show you again what's been
marked as Exhibit 1, which is the Subpoena for the
deposition today. And the Subpoena has attached to it
an exhibit. I believe it's also Exhibit 1, which is
the Notice of Deposition.
A. Yes.
Q. Attached to that is Exhibit A to the
Notice and item number 2 basically asks for all
records of any kind that you have, electronic or
written, however they're kept, basically, that relates
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BY MR. BERMAN:
Q. So essentially, item 2 in the documents
that are -- I'm sorry, Exhibit B -- not Exhibit A -Exhibit B, number 2 asks for all documents in
electronic -- all written and electronic documents and
records of any kind relating to any accounts with
Wells Fargo Bank, N.A., a/k/a Wells Fargo Home
Mortgage, in the name of Defendant
formerly
And it indicates her date of
birth and has a reference to some external
information.
The tapes that you're describing, do you
understand them to be some kind of -- arcane as they
may be, some kind of computer data type of device or
storage method?
A. Yes.
Q. So they would be electronic? Maybe not
electronic in the typical sense of these days with a
laptop or a hard drive or something, but electronic in
a very prehistoric form?
A. It's a possibility. And as I mentioned,
Jeff, I do not work in that area and I'm not
specialized in it to understand the format that's
received, how it's uploaded into the system. I can
only state that at one time, it was actually an actual

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tape, reel tape, that was submitted in. It went from

reel to reel and it downloaded, uploaded into the
system. And, therefore, we would not be able to -- I
mean, what type of system would you have to be able to
go and look at thousands and thousands of -Q. Right.
A. -- consumers by any data furnisher to get
to this particular consumer and be able to find out
what was being reported or what they reported in to
us.
Therefore, we just do not provide that
type of information. We do provide all of the
documents that you have in front of you.
Q. In the modern electronic form?
A. That is correct.
Q. Like the computer at your workstation?
A. Yes.
Q. And the servers that Equifax has, the
modern servers?
A. Yes.
Q. So is it fair to say that the tapes
you're describing being in some form of electronic
storage would be responsive to document request number
2?
A. What I can state is that, once again,
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you're describing them?

A. I can only speculate. I cannot verify
100 percent -Q. Okay.
A. -- how the information was updated.
Q. But if the information was updated
through the types of documents we were going through
earlier, like the AUD, or it's unlikely, but another
dispute from the consumer through an ACDV
immediately -- like a week after the conclusion of the
investigation, there would be documents that you would
be able to produce to me?
A. Yes.
Q. As opposed to the tapes; which I
understand I -- I have no equipment, nor would I
probably be able to find any in south Florida that
would be able to let me see the information on the
tapes?
A. That is correct.
Q. But nevertheless, those tapes are -- if
there are any tapes of the type you're describing with
information on it, furnished by Wells
Fargo, such tapes would be -- assuming they're out
there, would be responsive to request number 2; right?
A. I cannot validate that, but, yes.
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I'll not specialized in that area, so I cannot

validate how Wells Fargo submitted their information
in to us. I can just state that based on the
documents I have our investigation was completed
July the 4th. And according to the Exhibit 8, the
last date reported was July the 16th. So something
transpired between those two dates or on those two
dates.
Q. And you have no documents that you
could -- Equifax has no documents that it can produce
in response to the Subpoena -- or Equifax has produced
no documents in response to the Subpoena which could
be tied to the July 16, 2014 update?
A. That is what I'm stating, that there has
not been any documents. I can only speculate that it
may have been tape reported and, therefore, we would
not have a hard copy or manual copy or a document to
produce.
Q. Okay. So it's basically a process of
elimination or deduction. I understand it's
definitely not something you know for certain, but
it's a sort of best guess based on all the information
you have and the information gathered in response to
the Subpoena that it's very likely, or most likely,
that this update was done through these tapes, as
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Q. But, again, assuming that there are -that there's some tape out there somewhere in a
facility owned by Equifax, or where Equifax's tapes
are stored, if it has
information on
it relating to a Wells Fargo trade line, then it would
be responsive to number 2?
MR. ESTEVES: Objection to form. She's
asked and answered.
A. Well, what I can state is that it would
not only include
information, it would
also include -- there are thousands of other -BY MR. BERMAN:
Q. Of course.
A. -- consumers' information as well; which
I do not believe -- as I mentioned, I don't know if
you would even have the equipment to be able to go
through and to go through all of the information to
come to
information to see how it
was being reported by Wells Fargo.
Q. I understand. But just so the record is
clear -- and your lawyer is going to object again, but
I want you to answer.
If the data we're talking about is on a
tape somewhere at Equifax or in one of Equifax's
storage facilities, it would be responsive to request

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number 2; right?
A. I can't -MR. ESTEVES: Objection; asked and
answered.
A. I can't answer that. I don't know.
MR. BERMAN: Well, it's not asked and
answered if it's not answered, but okay.
BY MR. BERMAN:
Q. Do you know if there are -- let me
rephrase.
Are there any AUDs and ACDVs for this
trade line in Mrs.
credit report with
Equifax other than the ones that were produced in
response to the Subpoena?
A. There were none that were found.
Q. Besides the ones produced?
A. There were none that were found.
Q. And how far back did the person who
compiled the information go?
A. Well, it depends on what was stipulated
in the Subpoena request. And as I mentioned earlier,
I wasn't the agent that produced those documents.
Q. And do you know who that was, or no?
A. I do not know the exact agent.
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MR. BERMAN: Yes, we will.

BY MR. BERMAN:
Q. So which page are we looking at here?
A. We're reviewing page 8 of 14.
Q. And here there are -- there appear to be
four Wells Fargo trade lines. Can you tell me which
of those four is the one we've been talking about this
morning?
A. It is the very first Wells Fargo Home
Mortgage account being reported underneath the TD Auto
Finance. It is the second entry.

Q. So in this July 3, 2013 report, what is
the date as of this information is provided, or when
was this information provided?
A. Item as of date reported is -- the date
reporting is March 11, 2013.
Q. And do you see a reference to foreclosure
anywhere in that trade line?
A. No.
Q. Let's go to Exhibit 10, next in time.
This is June 3, 2014. This is a credit report?
A. Yes, it is.
Q. So this is where we're seeing those first
four pages of filler, or nonindividual specific
information?
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Defendants' Exhibit Numbers D-9 and D-10.)

BY MR. BERMAN:
Q. I'm going to hand you -- it's going to be
out of exhibit order, but what I'm handing you are
Exhibits 8, 9, 10, and 11. And all these documents
either are a response to a credit dispute by
Mrs.
or her credit report. Either way, they
include the subject Wells Fargo trade line, the one
we've been talking about this morning. And I'm going
to give them to you and ask you questions about them;
to avoid any confusion, in chronological order, rather
than the order in which they are marked as exhibits.
And I'd like to come around the table;
because I don't have them handy on my screen, if I
may. So in chronological order, going back the
farthest, out of the reports that we have with us
today is Exhibit 9, and the date of that report is
July 3, 2013; correct?
A. Yes.
Q. And for your ease of and the speed of the
deposition, I've tabbed the page with a blue plastic
tab where the Wells Fargo trade line is that we've
been talking about, if you want to turn to that page.
MS. SPAULDING WHITE: Can you tell me the
page that you tabbed?
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A. Noncredit reporting or account history,

yes.
Q. And I've tabbed again -- for
Miss Spaulding-White's benefit, could you tell us the
page that the subject Wells Fargo trade line is on?
A. That is page 9 of 16.
Q. And that's the last trade line on this
ninth page of this report?
A. Yes, it is.
Q. And do you see -- I'm sorry, I just want
to go back for one second.
So in Exhibit 9, the July 3, 2013 Equifax
credit report, on page 8, the second from the top of
the page is the subject Wells Fargo trade line. And I
just want to make sure I have your testimony right.
There is a reference to foreclosure in
this trade line; right?
A. No, there is not.
Q. In additional information?
A. Oh, I apologize.
Q. That's okay.
A. It does reference foreclosure.
Q. You almost got me.
A. I apologize.
Q. No, I'm just kidding. This has nothing

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to do with Equifax. You guys are just the middleman.

So there's a reference to foreclosure,
and that is information provided by Wells Fargo to
Equifax as of March 11, 2013; right?
A. Yes, as of last date reported.
Q. There's no other reason why foreclosure
would be included in the narrative on this trade line,
other than Wells Fargo provided that information to
Equifax; correct?
A. I have no record of any other reason why
the account information would reflect foreclosure.
Q. And you're not aware of any other reason
either? Other than not having records, you're not
aware of any other reason; right?
A. I am not aware.
Q. So next, let's go back to Exhibit 10, and
again, we are on page 9; Exhibit 10 being the June 3,
2014 credit report. You have at the bottom of the
page, Wells Fargo Home Mortgage; the subject trade
line. And do you see a reference to foreclosure on
this credit report?
A. It does not reflect the word
"foreclosure."
Q. And the information is indicated that it
was provided on what date?
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Q. And this trade line, just, again, it

reflects what would have been -- at the time, been
reported in her full credit report?
A. Yes.
Q. And does it include reference to the word
"foreclosure"?
A. Yes, it does.
Q. And would that have made its way back
into Mrs.
credit report in any manner other
than Wells Fargo providing an update which added back
in the word "foreclosure"?
A. What I can state in regards to Exhibit
11, this was in regards to a reinvestigation process,
and based on the results or the response that we
received from Wells Fargo at that time.
Q. And we know for sure that this
foreclosure reference was added back in to
Mrs.
credit report as of July 4, 2014, as
reflected in Exhibit 11, because the source or the
proof of that would be the document marked as Exhibit
2, which is the detailed ACDV?
A. Yes, it is.
Q. In which we see that someone from Wells
Fargo in bold reports foreclosure?
A. Yes.
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A. Item as of date reported, 4/11/2014.

Q. So Wells Fargo is reporting to Equifax
for this trade line as of April 11, 2014 was such that
they were no longer referring to foreclosure in the
narrative.
A. There's no record of the word
"foreclosure."
Q. And so in a perfect world, that would be
because Wells Fargo did an update to the credit report
as of April 11, 2014, which did not include the word
"foreclosure" in the narrative?
A. Based on that information in front of me,
as of that date reported, they had not made any
additional updates, and the word "foreclosure" is not
being reported.
Q. Let's go to Exhibit 11. So Exhibit 11 is
the July 4, 2014 response from Equifax to
Mrs.
letting her know of the conclusions of
the investigation following her June 10, 2014 dispute
letter; is that correct?
A. Yes.
Q. And in Exhibit 11, do you see the Wells
Fargo trade line that's provided as part of the
response from Equifax?
A. Yes, on page 1 of 2 at the bottom.
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Q. And there's no other way that foreclosure

made it into this trade line as of July 4, 2014;
right?
A. Exhibit 11 is based off of the response
to the ACDV.
Q. And so, then, anybody that pulled
Mrs.
credit report that was considering
loaning her money or giving her some form of credit as
of July 4, 2014, until such time as the report was
updated, would have seen the word "foreclosure" in the
narrative of this trade line?
A. Yes.
Q. And do we know -- do we know when the
next credit report was or the next update from Wells
Fargo, following what's reflected in Exhibit 11?
A. I believe, based on the other documents
that I reviewed, it's dated July 16, 2014, was another
date reported; and as I had verified, that I cannot
validate the method and how the account information
was submitted in to Equifax.
Q. And what you just described is you know
from looking at Exhibit 8; right?
A. From reviewing Exhibit 8.
Q. Which is the September 4, 2014 credit
report?

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A. That's correct. And based on item as of

date reported on page 10 of 16, it states that that
date is 7/16/2014.
Q. You're reading from the second trade line
from the top of the page?
A. Yes, I am.
Q. And in this report, is there any
reference to foreclosure?
A. No.
Q. So all the back and forth between these
four reports of foreclosures in, foreclosures out,
foreclosures in, foreclosures out, all that -- all
those updates, putting the word in, taking the word
out, putting the word in, taking it back out, there's
no way that happened unless Wells Fargo provided that
information to Equifax; right?
A. To my understanding, that is correct.
Q. Are you aware of whether Wells Fargo has
some other layer for another entity which is between
itself and Equifax or itself and the e-OSCAR process?
A. I cannot verify that. I'm not aware of
it if there is.
Q. Okay.
MR. BERMAN: I just need like a
two-minute break, if we can. I think I'm done.
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because I'm not an expert on this credit reporting -what the -- (indecipherable.)
MR. BERMAN: Hold on one second, Linda.
Are you on speaker?
MS. SPAULDING WHITE: Yes.
MR. BERMAN: How far are you from it?
MS. SPAULDING WHITE: How far do I need
to be?
MR. BERMAN: Get as close as you can to
your phone and speak towards your phone;
because it seems like you're looking away from
your phone to a piece of paper or a screen, and
it's going in and out.
MS. SPAULDING WHITE: I'll start over.
MR. BERMAN: Perfect.
BY MS. SPAULDING WHITE:
Q. I'm not a credit reporting aficionado.
Can you please tell me what e-OSCAR
stands for?
A. If I can recall, Linda -- if you don't
mind me calling you Linda -- e-OSCAR stands for
Electronic Online Secure and Accurate Credit
Reporting.
Q. Thank you. I had to write that down.
I'm going to go back over some
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I just want to -MS. SPAULDING WHITE: And I'm going to

need a five-minute break before we start.
BY MR. BERMAN:
Q. One quick follow-up question.
When there are updates to a trade line
through the tape uploads, is there a corresponding
physical paper record or a more modernized -- a more
modern computer record of the update?
A. Well, as I had mentioned earlier, I do
not work in that field and I'm not specialized in that
area, so I do not know the full process of tape
reporting in to Equifax by any data furnisher.
Q. Okay.
MR. BERMAN: Let's go off the record for
a second.
(Thereupon, an off-the-record discussion
was held.)
EXAMINATION
Q. I think I can say good afternoon now,
Miss Smith.
A. Thank you. It is.
Q. Can you please briefly explain to me --
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information that Mr. Berman asked you.

I know you're not the agent who
personally compiled the documents that were produced.
Did you do an independent review of the
Equifax records to determine if there are any other
responsive documents, excluding the tapes?
A. Yes, I did.
Q. And were you able to find any other
responsive documents?
A. No, I did not.
Q. Thank you. On Exhibit 4 -MR. BERMAN: Hold on one second; I will
give it to her.
A. I have Exhibit 4 in front of me.
Q. Thank you. This is one of the ACDVs that
Equifax did not generate, but it did receive from
Wells Fargo; is that correct?
Q. And if you look at what was reporting,
can you tell me what the special comment code is, the
AU?
A. The special comment code AU stands for, I
believe, paid in full, account paid for less
balance -- less than full balance. It is the same, I

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believe, as the -- I apologize.

Q. And does it reflect that the date closed
was February 1, 2012?
A. Yes, it does.
Q. Does it reflect how many days past due it
was being reported?
A. According to the payment history, it does
reflect some late payment history. As far as -- and,
I'm sorry, Linda. What was the other part of the
question?
Q. Does it anywhere reflect on there whether
it was 180 days past due, or is there any code on here
that would reflect that?
A. The only code that would reflect that it
had some late payment history would be under the
payment history 1-84 months; however, it does not
indicate that anywhere else that I can see.
Q. The account status 68, what does that
refer to?
A. The account status means the status of
the account at the time that the ACDV was submitted in
to us. And what it's stating, 68, I believe, stands
for the same thing as AU, account paid in full and
paid for less than full balance.
Q. Thank you. And this was as of -- what
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A. It goes back from today's date that it

was created and it goes backwards. So the first
line -Q. The (indecipherable) -A. Yes, the first line -Q. What do the open boxes represent?
A. There's no information being reported at
that time.
Q. And what does open box mean?
A. It just means there's nothing being
reported during that timeframe.
Q. Well, I'm just trying to figure out where
the H falls in with this reporting.
A. If you look at the date created, which
was March 30th, 2014, the agent is going back. They
cannot go forward, but they can only go back. And it
usually starts maybe one or two months prior to that
timeframe.
So there's no information -- I can't
state when they started this on Wells Fargo's end. I
can just state that the first would be the first year,
the current year that we're in, and that would be
2014. The second open set of boxes would probably
generate 2013. The other set would probably generate
2012; and it would go all the way back.
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date; was it March 30, 2014?

A. Yes; according to the second page, that
is the date that it was created.
Q. So it's not being reported as a
foreclosure at that time?
A. The word "foreclosure" does not appear at
that time; however, in the payment history grid, the
letter H represents foreclosure.
Q. The letter H?
A. Yes. It would not -Q. And what does that grid mean?
A. It reflects the late payment history for
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Q. But how do you read that grid? Because
14
there's open marks. There's sixes, there's four,
15
three, two, one. How do you read this grid?
16
A. Well, according to the standard metro two
17
format, the one just means that the account is
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be 60 days to 89 days past due, and so forth. Once
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you get to the number six, it means that it's 180 days
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or more past due. And then there's the letter H,
22
which represents foreclosure. And that would -23
Q. But how do you read this as far as timing
24
goes?
25
Min-U-Script
Page 80
Q. So the H appears in the 2012?

A. Somewhere in or around that timeframe,
that's correct.
Q. Okay.
A. But it doesn't necessarily mean that it
represents the full year. It could possibly represent
the timeframe that the agent created this document and
go back.
So March -- this was created in March of
2014. They may start from February 2014 and go back;
which that first line may cut off from February 2014
or February or March or January of 2013. It just
depends on what the agent was entering into the
system.
Q. So in 2014 and '13, it's not representing
foreclosure. In 2012, in the third box in, it
represents foreclosure?
MR. BERMAN: Object to form.
A. The letter H represents foreclosure;
however, it does not mean that the word "foreclosure"
will report on a consumer's credit file or on that
trade line. That will only be in the payment history.
Q. This ACDV and the -- this -- what do you
call this?

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A. It is an ACDV.
Q. I mean this box with boxes in it. What
is it called?
A. A payment history grid.
Q. Right. That payment history grid, does
that show up in a credit report?
A. The late payment history will reflect on
a consumer's credit report, yes.
Q. But is this grid shown on the credit
report?
A. Well, what I can state to you,
Miss Berman [sic], is that I do not have a credit
report dated for January 30th, 2014; therefore, I
cannot state whether or not the account, the Wells
Fargo Home Mortgage account, was reflecting the late
payment history. What I can state is what was
submitted in to us. They are stating that there were
late payment history and that there -- during this
certain timeframe, foreclosure, the account went into
foreclosure.
Q. In 2012?
A. Somewhere in or around that timeframe.
Q. I'm looking for the other ACDV here
that's Exhibit 5.
A. And I have Exhibit 5 in front of me.
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reaches a zero balance, the account is automatically

considered as closed.
And activity date could be any type of
activity that took -- that transpired. It could be a
payment that was made; it could be that the account
went -- the status of the account changed. It could
be a number of things that generates that activity
date.
Q. Okay. Thank you. If we can go to
Exhibit 7 for a moment, please. It's the ACIS
summary; correct?
MR. BERMAN: Hold on.
A. If you can hold for just a moment,
please.
MR. BERMAN: Which exhibit again; 7?
Q. 7.
A. Yes, I have Exhibit 7 in front of me.
Q. On the pages that -- actually, on the
bottom of page 1 and on all the pages that follow,
including page 4, the Wells Fargo Home Mortgage, over
on the right there are three letters, "AUI."
Can you tell me -- I don't know what that
stands for. Do you?
A. AUI stands for tape reporting.
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Q. Is it correct that this has the same

comment code, AU, that we just discussed as it relates
to Exhibit 5?
A. Yes, it does.
Q. And it also has the same account status,
68?
A. Yes, it does.
Q. Does it also reflect the high credit as
312,500?
A. Hold on just a moment.
Yes; they both do.
Q. And there are two different dates here.
There's a date closed and an activity date.
The date closed is February 1, 2012,
correct -A. That's correct.
Q. -- on each?
And the activity code is January 1, 2012;
correct?
A. That's correct.
Q. What is the difference between those two
dates?
A. Well, the date closed just simply means
the timeframe that the account was closed. There's a
possibility on a mortgage account, once an account
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Q. Tape reporting?
A. Yes.
Q. Is that the kind of tape reporting that
we were just discussing off the record?
A. To my understanding, it is.
Q. So would this actually be a record of the
tape reporting that we were discussing off the record
earlier?
A. In regards to the Wells Fargo account?
Q. Yes.
A. It does have AUI listed alongside the
Wells Fargo Home Mortgage account, so, therefore, I
will state that probably this is maybe in regards to
some type of tape reporting.
Q. So if you can look at all of the pages
for all of the creditors, there's the code AUI for
every single creditor on here.
A. Yes.
Q. So is this maybe a record that is
generated as a result of those tapes?
A. Not necessarily. I can state that in
regards to this Exhibit 7, this is in regards to a
reinvestigation process. If I'm not mistaken,
Miss Berman, sometimes there's a -MR. BERMAN: Miss White.

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A. I'm sorry. I apologize. I really do.

Q. Just call me Linda, like you were doing.
A. Okay, Linda; because that's my best
friend's name. I'm sorry. But thank you so much,
Linda.
Usually, there's an asterisk. If you
look just, say, for example, on page 1 for American
Express, underneath the word -- the title American
Express, it has DFD/DLA and it has -Q. Right.
A. -- 6/06/2014, there is an asterisk out to
the side -Q. Right.
A. -- if I'm not mistaken, Linda, that
indicates it was tape reported in to us. The AUI
indicates that these creditors submit information in
to us by tape reporting. It doesn't necessarily mean
that on page 4, this information came in from Wells
Fargo through a tape reporting; because the asterisk
is not there.
But as I had mentioned earlier, I am not
a specialist in that area, so I do not know all of the
processes that take place with the creditors updating
bulk information at one time.
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Q. Thank you. Let's go back to Exhibit 6,

which is
dispute letter, dated
June 10, 2014; Exhibit 6.
A. I have Exhibit 6 in front of me.
Q. What is it that Mrs.
is
disputing as it relates to her credit report?
A. It appears from this letter, where it
states number 1, the Wells Fargo Mortgage account,
she's disputing the date of last payment as incorrect
and that the date of first delinquency is incorrect.
Q. She's not disputing the account status as
it relates to a foreclosure being reported, is she?
A. According to this letter, it does not
appear that she is disputing the status, nor the prior
paying history.
Q. And if you look at the document attached,
which it appears she enclosed a copy of her credit
report, is it reporting this as a foreclosure?
A. Bear with me just a moment.
Q. It's a little blurry, but I think you can
read it.
A. It does not appear that the word
"foreclosure" is being reported.
Q. So the sole reason she's supposedly filed
this dispute was as it related to the date of the last
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Q. Thank you. The last two pages of Exhibit

7, the maintenance sheet summary -A. Yes.
Q. -- can you tell me what the comments
section means here?
A. Are you speaking of consumer comments?
Q. Is that what this -- yes, where it says
consumer comments; and then you have codes, and then
it comes down and there's the comments with the dash
and it says disputes current/previous account status?
A. I believe you are referring to the last
page in regards to the Wells Fargo Home Mortgage
account.
Q. Yes, I am.
A. The comments indicate the first line, and
the second line indicates dispute code number 1 and
dispute code number 2, if you would review Exhibit
Number 2. Exhibit Number -- I'm sorry, the third line
where it has updated information verified by grantor,
that is the information that we received back. It
identifies IHA, identifies the agent, and it
identifies the date that the update was made.
The consumer comments that's listed below
maintenance action, it tells the information that we
provided to Mrs.
at that time.
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payment and the date of the first delinquency;

correct?
A. According to the letter, it does appear
that those are the two items that she is disputing.
Q. Then if we look at your Exhibit 2 for
your dispute one and dispute two -A. Yes.
Q. -- the two disputes, how do we get from
what she is disputing in her letter, the two things,
date of last payment and date of first delinquency,
how is it that you code these disputes one and two,
based on her letter?
A. Well, here within the Equifax
organization, when we initiate a reinvestigation or
dispute process, we only have the option of using
dispute code one or dispute code two. If there's any
additional information, we will place that in the FCRA
relevant information field.
According to -- and I can only speculate
what the agent -- the reason they also disputed the
status and the prior paying history, is based on at
the time of dispute, the account was reporting an M5
status; however, it was not reporting any late payment

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history. And whenever we use dispute code 007, it

covers not only one, but it will cover both. And in
dispute code number 2, 016, we're asking any data
furnisher to verify all of the dates, not just the
date that the account was closed, but the date of last
payment, the date of first delinquency, the date that
it was open. We're asking them to verify all dates as
it indicates.
Q. So even though Mrs.
is only
disputing two things, when you submitted this dispute
to Wells Fargo, you included all aspects, including
the account status, the date it was opened, the date
it's closed, all the information, not just the
information she was disputing; correct?
A. Well, I can state that based on the
information in Exhibit 2, we did ask Wells Fargo to
verify the status and the prior paying history. But
the agent did address Mrs.
concerns
regarding the date of last payment and the date of
first delinquency.
Q. But you also requested Wells Fargo to
provide an update on all of the other line items on
your form, the dispute one and dispute two. All
that's covered in 007 and 016?
A. Well, 007, dispute code 007, only
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Q. Right.
A. Once again -- and I apologize, I cannot
verify what the agent was reading or looking at at
that time. I can just only state that according to
the type and rate field where it has an M5, the agent
may have felt the need to go ahead and dispute the
status and the prior paying history as well. But I
can only speculate.
Q. In response to one of Mr. Berman's
questions, you indicated that one of the other manners
in which a credit report would be changed or updated
is if a consumer provided supporting documents
relating to their dispute -A. Yes; there are times that -Q. -- correct?
Did
ever provide any
supporting documents relating to her dispute as it
relates to this June 10, 2014 dispute?
A. I apologize. I had over spoke and you
got cut off. Can you repeat the question again,
please?
Q. Yes. I'm sorry. Did Mrs.
ever
provide any supporting documents relating to this
June 10, 2014 dispute?
A. There were no other additional documents
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correlates with the status and the prior paying

history.
Dispute code number 2, which is 016,
relates to all of the dates: The date closed, the
date opened, all of those dates that may report on any
given trade line.
Q. But she was only disputing the date of
last payment and the date of first delinquency, which
would be covered by dispute 2, 016.
Why would the ACDV be submitted to Wells
Fargo, including dispute one, 007, when she was not
disputing that?
A. And I understand, Linda. I cannot
validate what the agent was thinking at that time. I
can just only state that the agent went ahead and
disputed the status and prior paying history, in
addition to verifying the late -- the dates reporting
on the account.
Q. Even though the current code was as it's
in your narrative 098, account paid for less than full
balance, and also 158, closed or paid account, zero
balance?
A. If I understand you correctly, Linda,
you're asking me in regard to dispute number one where
we used a dispute code 007, why the agent used that?
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that were filed, only the two pages that were

submitted in to Equifax.
Q. And I was just trying to confirm. You
said that would be another manner in which Equifax may
update its credit report, or another manner in which
they would investigate the status of the report?
A. Well, there have been times where
consumers have provided information in directly
themselves and information on a trade line or a public
record item has been updated; however, according to
Exhibit 6, there were no supporting documents;
therefore, the agent initiated the reinvestigation
process.
Q. Did Mrs.
ever provide any
supporting documents at any other time from June 20,
2013, to the present as it relates to her credit
report?
A. Not that I am aware of, no.
Q. If they had been submitted, would you
have those documents and would they have been produced
in response to the Subpoena?

A. Yes.
Q. And based on the Exhibit 8, which is the
credit report that you generated in response to the
Subpoena on September 4, 2014; correct?

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A. Hold on just a moment. I need for them

to provide me with Exhibit 8.
Q. Certainly.
A. Exhibit 8, which is dated September 4th,
2014, is in response to the Subpoena request.
Q. So as of September 4, which report
reflects that as of June 16, 2014, on page 10, that
Wells Fargo is reporting this as closed or paid
account/zero balance; correct?
A. Yes. I can state on page 10 of 16 of
Exhibit 8 that item as of date reported is 6 -7/16/2014. And that is the information that has been
reported since that timeframe up until the timeframe
this disclosure, or credit file or credit report, was
created.
Q. And it shows the high credit of 312,500?
A. Yes, it does.
Q. Does it show the date closed as
January 2012?
A. Yes, it does.
Q. Does it also reflect it as account paid
for less than full balance?
A. Yes, it does.
Q. And there's been no change since July 16,
2014; correct?
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printed -MR. BERMAN: Yes.

MS. SPAULDING WHITE: -- I would like to
mark two of them.
MR. BERMAN: Okay. I have two documents,
each three pages: Report results, this form
produced by Equifax, and a user reference, page
1 of 3, is how they both start.
MS. SPAULDING WHITE: Right. I would
like -- well, I would like to mark that as
Plaintiff's Exhibit 1.
MR. BERMAN: Do you want to go
sequential, or no?
MS. SPAULDING WHITE: Well, it's a
three-page document.
MR. BERMAN: Do you want to mark it -instead of Plaintiff's 1, why don't you just
mark it as -MS. SPAULDING WHITE: I am fine to do
that. We can do mark that as Exhibit -- what
are we, 12?
MR. BERMAN: 12, right. There's two of
them, so let me make sure I have this right, or
the order in which -- they look the same.
MS. SPAULDING WHITE: I sent you three
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A. What I can state is as of the date of
this document, which is September 4th, 2014, that is
the way the Wells Fargo Home Mortgage account was
being reported.
Q. Back to July 16, 2014?
A. Yes.
Q. And even though as of June 3, 2010, when
submitted her report -- her dispute
letter -- I'm sorry -- June 10, 2014, even though her
loan was not being reported as for foreclosure, she
still submitted a dispute; correct?
A. What I can state is that according to
Exhibit 2, at the time of dispute, the account was not
being reported -- did not have a notation of
foreclosure; however,
did submit a
dispute letter in to Equifax regarding her Wells Fargo
account in regards to two other items being reported
on that trade line.
MS. SPAULDING WHITE: The documents that
I sent to you, Jeff -MR. BERMAN: Yes.
MS. SPAULDING WHITE: -- that were
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documents. This was the only three-page

document, I think.
MR. BERMAN: Ah.
MS. SPAULDING WHITE: On the bottom it
shows httpsx4Equifax71813 (phonetic).
MR. BERMAN: Yeah, so I got two of the
same document.
So this will be 12.
Plaintiff's Exhibit P-12.)
MR. BERMAN: And then what was the other
one that you emailed me?
MS. SPAULDING WHITE: It's the
Credit Cards, Loans and Other Debt,
CreditScore.com. It's a document you sent me.
MR. BERMAN: Yes, okay.
MS. SPAULDING WHITE: If we could mark
that Exhibit 13.
MR. BERMAN: Off the record.
Plaintiff's Exhibit P-13.)
Q. Miss Smith, could you please look at the
document we've identified as Exhibit 12?

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September 9, 2014

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A. Yes; I have that in front of me.

Q. Do you know what type of report this is?
A. I do not. I'm not familiar with this
particular document.
Q. Is it exported from Equifax.com?
A. This is the -- that is what's stated at
the bottom and at the top of the page on Exhibit 12.
Q. And the user reference number A498306, do
you know if that is Wells Fargo's user number?
A. I do not know what the user ID number is.
But based on other information, as far as Wells Fargo
subscriber number with Equifax, they are not one and
the same.
Q. Do you know if the information that would
have been pulled from the Equifax.com electronic
service or on their website would be accurate?
A. I cannot validate that. I do not work -I'm not specialized in that area as well.
Q. This appears to reflect the report
results of the account/trade line information for
Wells Fargo for
loan number; is that
correct?
A. That is what it indicates.
Q. And the date on there that says
7/13/2013, do you know what that date is supposed to
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A. That is the date that appears at the

bottom right-hand corner of Exhibit 12.
Q. Can we now look at Exhibit 13?
A. Yes.
Q. And this is a document from
CreditScore.com; correct?
A. It indicates that in the top right-hand
corner.
Q. And the report is dated as of what date?
A. Reported as of 3/30/2014.
Q. Do you know how third-party vendors
obtain Equifax's information on a particular debtor?
A. I do not.
Q. Does the information provided by Equifax
here reflect a date that it was opened?
A. Now, there are two Wells -Q. If you look on -A. There are two Wells -Q. If you look on the far left, it says date
opened, and then you have the block for Equifax.
A. Yes, I see that.
Are we referring to the first Wells Fargo
account or the second Wells Fargo account? Because
the first Wells Fargo account indicates, under the
Equifax portion, a date opened of July 1, 2013 -- I'm
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reference?
A. And where is that date located?
Q. Under the heading -- there are several
bold headings. The second heading underneath that.
A. It would probably be the reported date.
Q. And does it appear to also reflect the
high credit of 312,500?
A. Yes, it does.
Q. Does it reflect that the account is paid
and closed?
A. It does.
Q. The date on there that -- in the next two
columns over, the January 2012, is that the closed
date?
A. It appears to be, yes.
Q. And is there any narrative for this
account?
A. The narrative states account paid for
less than full balance.
Q. Is there any code or narrative on here
reflecting foreclosure?
A. From reviewing Exhibit Number 12, I do
not show any reference to foreclosure being reported.
Q. And the date that this was pulled from
Equifax.com, is that July 18, 2013?
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sorry, 2003. On the second Wells Fargo Home Mortgage
account, there's not a date reporting. As a matter of

fact, there's no account history being reported at
all.
Q. So whatever account, that one is not even
being reported; correct?
A. According to this document, it's not
being reported by Equifax, or they were unable to
obtain any information regarding this account number
from Equifax.
Q. And if you look at the account number
using the Experian account -- do you see that?
A. On the second Wells Fargo account, yes, I
do.
Q. -- is that the account number, the loan
number, that we've been discussing in today's
deposition?
A. If I can review Exhibit Number 2, I can
almost verify that for you.
It appears that it's the same account,
with the last four digits masked.
Q. So as of March 30, there doesn't appear
to be any reporting by Equifax for this loan, at least
through CreditScore.com; correct?
A. Well, what I can state is I cannot

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September 9, 2014

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validate the records for CreditScore.com. I can just

validate that, based on the information in front of
me, there's no history being reported by Equifax, nor
TransUnion, regarding the account that's been in
dispute today.
Q. Going through all the exhibits that we've
gone through to date, is it correct to say that Wells
Fargo, through Equifax, was not reporting this loan as
a foreclosure, at least from July 13, 2013, through
July 4, 2014?
A. Well, what I can state -- and I would
need to go back and review the documents. But what I
can recall, Linda, is that in June 2014, we initiated
a reinvestigation process on behalf of Mrs.
And at the time of dispute, the account was not
reporting the status of, or the narrative of, being in
foreclosure; however, based on the ACDV response that
we received back from Wells Fargo, they did request
that the account reflect foreclosure, of which we did
and updated accordingly.
Q. So the first record we have of Wells
Fargo, through Equifax, reporting it as a foreclosure
was June -- I'm sorry, July 4, 2014; correct?
A. From what I can recall, yes, from Exhibit
4.
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Q. And then the foreclosure reference was
removed on July 16, 2014; correct?
A. I believe that was Exhibit 8, the credit
file, or the credit report, that was dated
September the 4th. It stated as of the date of last
reported, it was July the 16th, 2014, and that it was
not reporting any information regarding foreclosure.
Q. So it reported foreclosure only from July
4, 2014, through July 15, 2014; because it was removed
on July 16, 2014; correct?
A. Based on the information I have here in
front of me and the documents that have been
presented, that is correct.
Q. Is there a way for Wells Fargo to go
back -- you know, we have this document from
Equifax.com that shows it being reported not as a
foreclosure as far back as July 13, 2013.
Are there records to reflect how Wells
Fargo was reporting this from June 20, 2013, until she
filed her dispute on June 10, 2014?
A. There are documents that can be produced.
Q. And is there a reason we don't have --
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Q. Prior to that date -A. I mean Exhibit 2.

Q. -- you don't have record showing it being
reported as a foreclosure; correct?
A. Can you repeat that, please.
Q. Prior to the date of July 4, 2014, you
don't have records reflecting Equifax, through Wells
Fargo, reporting her loan as in foreclosure?
A. Well, what I can state, Linda, is that
prior to the dispute process, I cannot verify how the
account was being reported, based on the documents
that have been presented; however, the documents that
have been presented today, it does indicate that we
initiated a dispute process on June the 17th, and at
the time of dispute, the account did not reflect
foreclosure.
Q. So until she filed her dispute, the
account did not reflect foreclosure?
A. I can state between the time that we
initiated the dispute and the time that the dispute
process was completed, the account was not reporting
foreclosure.
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MR. BERMAN: Hold on, Linda.

Q. -- those today?
MR. BERMAN: Linda, one second.
Can you please read back the last
question and the answer.
(Thereupon, the court reporter read the
pertinent portion of the record.)
MR. ESTEVES: Can we go off the record?
MS. SPAULDING WHITE: No. I want this on
the record, please.
MR. ESTEVES: Okay. Well, I just want to
clarify, and Miss Smith can clarify, that those
documents have to be created.
A. That's what I was going to say.
MR. ESTEVES: They're not -MR. BERMAN: They're not existing?
MR. ESTEVES: They're not existing.
THE WITNESS: Right.
MS. SPAULDING WHITE: Okay. And that we
should have on the record.
MR. ESTEVES: Okay.
Q. But there are documents that can be
pulled or created to show how Wells Fargo was

(26) Pages 101 - 104

September 9, 2014

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reporting the loan from June 20 through the date of

her dispute?
A. There are documents that can be created,
I believe the timeframe that you stated, from June 20,
2013, up until her dispute in June '14, a year later.
Q. We may ask for those to be created.
MS. SPAULDING WHITE: I have no further
questions.
MR. BERMAN: I just need a minute.
RE-EXAMINATION
BY MR. BERMAN:
Q. As relates to any timeframe -- I have a
couple of follow-up questions. I will be as brief as
possible.
As relates to creating a timeline where
we just are looking at the word "foreclosure" and we
want to say from X date to X date it was in the
report, foreclosure was in the report, and then it
came out and then it went back in and then it came
out, and this yo-yo of the word "foreclosure" in and
out of the report, to create a timeline, the most
reliable information would not be your testimony, but,
in fact, would be from what we have today, your
testimony and these records, would be these records;
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MR. BERMAN: Okay.

BY MR. BERMAN:
Q. I want to ask you a brief follow-up
question on Exhibit 11, which is the July 4, 2014
response to the credit dispute by Mrs.
And in the section that provides the
subject trade line, in the additional information at
the end -- starting at the end of the line -- the
first narrative of the -- the first line of the
narrative section and then it goes on to the second
line, the first actual substantive information in that
part of the narrative says consumer disputes after
resolution.
What does that mean to you, as you read
it today?
A. Usually, up under the Fair Credit Billing
Act, they submit -- when a consumer disputes
information directly with the creditor, or data
furnisher, they are required to place that
information, stating that the account is under
dispute.
That narrative that states consumer
disputes after resolution is that their investigation,
or their internal review, has been completed;
although, the consumer still disputes the results of
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right? Because they will show you the date it was

updated and they will show you when it's in and out.
And perhaps this other document that you might be able
to create would be even more reliable, but the records
that we have before us today are the most reliable;
correct?
A. Well, the documents that we have before
us today indicate when foreclosure was reporting and
when the word "foreclosure" was not being reported.
Q. Okay.
A. I believe Linda was -- had a timeframe
between June 2013 up until June 2014. Those are the
additional documents that would have to be created
that would show how the account was being reported for
each one of those additional timeframes.
Q. Okay.
MS. SPAULDING WHITE: And we do have
Exhibit 12 that is from Equifax.com that shows
on July 13, 2013, it was not being reported as
a foreclosure.
MR. BERMAN: Okay. Is that a question or
just a statement?
MS. SPAULDING WHITE: I mean, I'm
pointing out this document that is from their
Equifax.
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their findings. Just say, for example, if

Mrs.
had contacted Wells Fargo -- and I can't
state this is what happened. But just state, for
example, that Mrs.
had contacted Wells Fargo
Home Mortgage, disputing the information directly with
them; that they submitted the information to Equifax,
stating that this account is under -- is being
disputed by the consumer. They have a certain
timeframe before their investigation is completed, or
their internal review is completed. Once it's
completed, then they can either have that narrative
statement removed altogether -- but it appears based
on this -- and I'm only speculating -- is that they
did complete their research, or their internal
investigation; however, Mrs.
still disputed
the information -Q. Okay. And we can -A. -- or their findings.
Q. I'm sorry to cut you off.
A. That's okay. Go ahead.
Q. And so if we go back to Exhibit 2, which
is the very detailed one-page ACDV -A. Yes.
Q. -- we can actually see where, in bold,
under the narrative, the response that you got from

(27) Pages 105 - 108

September 9, 2014

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Wells Fargo was that exact same information that the

consumer disputes after resolution?
A. That is correct.
Q. So that phrase is in the trade line
included in Exhibit 11 solely because Wells Fargo
asked that it be included; right?
A. That is correct.
MR. BERMAN: That's all the questions I
have.
MS. SPAULDING WHITE: I have nothing
further.
MR. BERMAN: Would you like to read and
sign or waive?
MR. ESTEVES: Yes, I think we want to
read and sign.
MR. BERMAN: Okay. I'll let you know if
I want to order it, but it certainly won't be
expedited.
(Deposition concluded at 1:18 p.m.)
---
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E R R A T A
S H E E T
Pursuant to Rule 30(e) of the Federal Rules

of Civil Procedure and/or O.C.G.A. 9-11-30(e), any
changes in form or substance which you desire to make
to your deposition testimony shall be entered upon the
deposition with a statement of the reasons given for
making them.
To
corrections,
supplemental
furnish same
assist you in making any such

please use the form below. If
or additional pages are necessary, please
and attach them to this errata sheet.
- - -
I, the undersigned, PAMELA SMITH, do hereby

certify that I have read the foregoing deposition and
that said transcript is true and accurate, with the
exception of the following changes noted below, if
any:
Page_____/Line_____/Should Read:______________________
______________________________________________________
Reason:_______________________________________________
______________________________________________________
Reason:_______________________________________________
______________________________________________________
Reason:_______________________________________________
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C E R T I F I C A T E
I hereby certify that the foregoing

transcript was reported, as stated in the caption;
that the witness was duly sworn and elected to reserve
signature in this matter; that the colloquies,
questions and answers were reduced to writing under my
direction; and that the foregoing pages 1 through 109
represent a true, correct, and complete record of the
evidence given.
I further certify that I am not
disqualified for a relationship of interest under
O.C.G.A. 9-11-28(c); that I am a Georgia Certified
Court Reporter here as a representative of D'Amico
Gershwin, Inc.; that I/D'Amico Gershwin was contacted
by the party taking the deposition to provide court
reporting services for this deposition; that I will
not be taking this deposition under any contract that
is prohibited by O.C.G.A. 15-14-37(a) and (b) or
Article 7C of the Rules and Regulations of the Board;
and by the attached disclosure forms I confirm that
I/D'Amico Gershwin is not a party to a contract
prohibited by O.C.G.A. 15-14-37 or Article 7C of the
Rules and Regulations of the Board.
The above certification is expressly
withdrawn and denied upon the disassembly or
photocopying of the foregoing transcript, unless said
disassembly or photocopying is done under the auspices
of D'Amico Gershwin, Inc. and the signature and
original seal is attached thereto.
Min-U-Script
________________________________
G. PAIGE ALEXANDER, CCR-B-2115
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______________________________________________________
Reason:_______________________________________________
______________________________________________________
Reason:_______________________________________________
______________________________________________________
Reason:_______________________________________________
______________________________________________________
Reason:_______________________________________________
______________________________________________________
Reason:_______________________________________________
______________________________
PAMELA SMITH
Sworn to and subscribed before me,
______________________________, Notary Public.
This___________day of__________, 20_____.
My Commission Expires:

(28) Pages 109 - 112

September 9, 2014

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20,21;93:21;94:4,16,
20;98:9,17,18;99:23,
23,24;100:2,3,5,9,11,
12,13,15,20;101:4,15,
19;102:12,16,20,24;
106:14;107:20;108:7
account/trade (1)
97:20
account/zero (1)
93:9
accounts (2)
59:2;60:6
Accurate (2)
75:22;97:16
ACDV (60)
9:24;10:2;15:23;
17:10,12,22;19:11,14;
20:9;21:19,24;22:8;
Min-U-Script
25:18;26:25;27:7,11;
28:8;31:3,10;34:25;
35:8,11,15,15;36:14,
15;37:12,24;38:2,9,
23;39:3,5,7,17,20;
40:5,13,19;41:6,11,
16;42:18;44:9,21;
46:25;50:11;52:17;
56:1;57:24;63:9;
71:21;72:5;77:21;
80:24;81:1,23;90:10;
101:17;108:22
ACDVs (3)
36:6;65:11;76:16
ACIS (5)
10:9,10,15;41:21;
83:10
A-C-I-S (1)
41:22
across (1)
26:14
Act (1)
107:17
action (1)
86:24
actions (3)
10:11,22;42:2
activity (6)
24:18;82:13,18;
83:3,4,7
actual (5)
26:9;48:22;49:13;
60:25;107:11
actually (8)
25:2;26:8;46:14;
53:17;60:25;83:19;
84:6;108:24
added (5)
23:11;48:4;55:18;
71:10,17
addition (1)
90:17
additional (14)
24:2,20;26:19,22;
31:8;48:25;55:1;
68:19;70:14;88:19;
91:25;106:13,15;
107:7
address (3)
13:13;24:23;89:18
advance (1)
11:23
advised (1)
24:19
aficionado (1)
75:17
afternoon (1)
74:22
again (14)
22:7;37:21;38:8;
56:12;58:16;61:25;
64:1,21;68:3;69:17;
71:1;83:15;91:2,20
agencies (3)
36:5;37:1,5
agent (23)
10:11;11:16;16:3,
11;18:1;47:4;49:22;
53:4;65:22,24;76:2;
79:15;80:7,13;86:21;
88:22;89:18;90:14,
15,25;91:3,5;92:12
agents (3)
10:23;11:20;42:2
ago (1)
15:6
agreed (1)
8:13
agreement (2)
34:21;59:18
Ah (2)
21:11;96:3
ahead (5)
9:7;56:8;90:15;
91:6;108:20
almost (2)
68:23;100:19
alongside (1)
84:11
although (2)
59:13;107:25
altogether (1)
108:12
American (2)
85:8,9
analyze (1)
12:24
and/or (1)
50:4
answered (5)
31:14;64:8;65:4,7,7
apologize (10)
25:4,10;40:9;51:9;
68:20,24;77:1;85:1;
91:2,19
apparent (1)
55:16
apparently (2)
40:14;57:25
appear (11)
39:7;44:13;46:4,4;
67:5;78:6;87:14,22;
88:4;98:6;100:22
appeared (2)
10:12;47:1
appears (17)
10:5,17;15:18;
22:12;37:13;48:16;
50:7;54:8;57:1;80:1;
87:7,17;97:19;98:15;
99:1;100:20;108:12
applicable (1)
24:23
appreciate (1)
9:8
approval (1)
59:8
April (7)
9:21;29:13;32:22;
33:5,8;70:3,10
arcane (1)
60:13
area (7)
22:9;51:10;60:22;
62:1;74:13;85:23;
97:18
areas (1)
48:10
around (5)
21:24;58:1;66:13;
80:2;81:22
aspects (1)
89:11
assistant (1)
7:18
associate (1)
7:12
assume (1)
19:3
assuming (2)
63:23;64:1
asterisk (3)
85:7,12,20
attached (3)
58:18,22;87:16
AU (6)
34:6,8;76:22,23;
77:23;82:2
AUD (11)
9:20;29:21;30:19;
31:1;32:20;33:4,23;
50:17;52:18;57:24;
63:8
AUDs (2)
30:17;65:11
AUI (5)
83:22,25;84:11,16;
85:16
authorization (1)
32:16
Auto (2)
54:19;67:10
Automated (7)
9:17,21,25;15:8;
26:25;29:23;34:25
automatically (1)
83:1
avoid (1)
66:11
aware (8)
7:22;28:10;69:12,
14,15;73:18,21;92:18
away (1)
75:11
B
back (38)
13:3;16:12;20:20;

22:18;27:5,25;31:8;
45:11,12;47:3,7;48:7;
65:18;66:15;68:11;
69:16;71:8,10,17;
73:10,14;75:25;79:1,
15,16,25;80:8,10;
86:20;87:1;94:7;
101:12,18;103:18,20;
104:5;105:20;108:21
background (1)
18:5
back-of-the-house (1)
46:25
backwards (1)
79:2
bad (3)
31:15,24;32:1
balance (16)
33:22;34:9,13,17,
18;43:5;55:18;76:25,
25;77:24;83:1;90:21,
22;93:9,22;98:19
Bank (3)
25:2;59:1;60:7
based (35)
13:7,7;14:1;20:3;
22:4,17;23:12;28:11;
30:17,20;31:1;34:15;
38:6;40:22;41:13,13;
46:6;56:1;62:3,22;
70:12;71:14;72:4,16;
73:1;88:14,23;89:15;
92:23;97:11;101:2,
17;102:12;103:13;
108:12
basically (3)
58:23,25;62:19
bear (2)
26:11;87:19
bearings (1)
54:15
beginning (1)
13:21
behalf (15)
8:2;9:19,23;10:1,3;
11:2;15:17;23:8,10;
27:2;30:2;35:2;38:14;
41:1;101:14
below (5)
16:18;21:12,12;
34:4;86:23
benefit (1)
68:4
Benson (3)
9:23;60:9;94:10
Benson's (2)
29:17;97:21
BERMAN (95)
7:5;8:9;9:8,12;
11:11,12;14:17,20,22;
19:20;22:23;23:3;
28:3;30:15;31:14,19,
24;32:3;36:20;37:2,7,
(1) [sic] - BERMAN

September 9, 2014

8,18;43:21,24;44:4,7;
51:24;52:5,8,12,15;
53:23;54:1,5,7;56:8,
11,13;57:4;58:11,15;
59:10,13,22;60:1;
64:12;65:6,8;66:2;
67:1,2;73:24;74:5,16;
75:3,6,9,15;76:1,12;
80:18;81:12;83:12,
15;84:24,25;88:3;
94:1,14,24;95:2,5,12,
16,22;96:3,6,11,16,
19;102:9,21;103:12;
104:1,4,17;105:9,12;
106:21;107:1,2;
109:8,12,16
Berman's (1)
91:9
besides (2)
52:17;65:16
best (2)
62:22;85:4
beyond (1)
38:13
big (1)
36:9
Billing (1)
107:16
birth (1)
60:10
bit (4)
15:6;34:4;41:20;
44:5
black (1)
16:18
block (1)
99:20
blue (1)
66:21
blurry (1)
87:20
bold (17)
16:11;17:5,7;20:11,
13,19,20;21:13;
26:14;27:9;44:21,23;
47:13,23;71:24;98:4;
108:24
borrower (3)
25:6,7;34:12
both (3)
82:11;89:2;95:8
bottom (9)
23:23;26:12;33:13;
69:18;70:25;83:20;
96:4;97:7;99:2
box (4)
21:3;79:9;80:16;
81:2
boxes (4)
16:19;79:6,23;81:2
break (2)
73:25;74:3
brief (4)
Min-U-Script
12:15,16;105:14;
107:3
briefly (2)
38:21;74:25
bulk (4)
51:4,15;52:23;
85:25
bunch (1)
16:18
bureau (3)
37:14,14;38:2
bureaus (3)
36:2;40:21;42:11
business (4)
12:3,8,12;53:6
C
call (4)
25:7;41:21;80:25;
85:3
called (1)
81:3
calling (2)
49:25;75:21
came (4)
49:15;85:19;
105:20,20
Can (114)
7:6;10:18;12:1,15;
18:17,17,23;19:5,6,7;
21:23,24;22:7;23:5;
24:5;25:6;26:8;29:9;
30:2,5,16,25;31:13;
32:20;33:6,23;34:15,
23;37:14,19,20,22;
38:1,21;40:22;42:12;
45:8,9;48:6,15;49:15;
50:9;54:2,9,10,12,13;
55:10,15,21,23;56:14;
57:25;59:23,23;
60:24;61:25;62:3,10,
15;63:2;64:9;66:24;
67:6;71:12;73:25;
74:22,25;75:9,18,20;
76:21;77:17;79:16,
21;81:11,16;83:9,13,
23;84:15,21;86:4;
87:20;88:21;89:15;
90:15;91:4,8,20;
93:10;94:2,15;95:20;
99:3;100:18,18,25;
101:1,11,13,24;102:5,
10,22;103:24;104:5,9,
13,24;105:3;108:11,
17,24
caps (1)
26:19
Cards (1)
96:14
case (6)
15:18;16:13;20:14;
25:1,1,6
certain (5)
12:22;32:8;62:21;
81:19;108:8
Certainly (2)
93:3;109:17
change (6)
25:19;50:9,22;
55:16,16;93:24
changed (4)
33:24;34:2;83:6;
91:11
Christine (3)
17:1;39:1;40:15
chronological (2)
66:11,15
clarify (2)
104:13,13
clear (3)
40:19;47:8;64:21
client (1)
15:19
close (1)
75:9
closed (18)
24:4,14;33:21;
44:15;77:2;82:13,14,
23,24;83:2;89:5,13;
90:4,21;93:8,18;
98:10,13
code (25)
16:9;32:7,9;34:6,
11,16;76:21,23;77:12,
14;82:2,18;84:16;
86:16,17;88:13,18,18;
89:1,3,25;90:3,19,25;
98:20
codes (4)
21:3;32:4,11;86:8
column (2)
23:18;33:14
columns (1)
98:13
coming (2)
22:18;52:19
comment (5)
34:6,16;76:21,23;
82:2
comments (8)
42:1;47:5;86:4,6,8,
9,15,23
company (1)
9:6
compared (1)
56:6
comparing (2)
56:16,17
compile (1)
11:14
compiled (4)
11:17;16:1;65:19;
76:3
complete (2)
43:14;108:14
completed (11)
10:13;41:25;43:4;
47:5;58:6;62:4;
102:24;107:24;108:9,
10,11
compliance (1)
21:3
comply (1)
11:15
computer (4)
17:14;60:14;61:16;
74:10
concerns (1)
89:18
concluded (1)
109:19
conclusion (1)
63:10
conclusions (1)
70:18
condition (1)
21:3
confident (1)
38:4
confirm (1)
92:3
confusing (1)
19:5
confusion (2)
24:24;66:11
considered (1)
83:2
considering (1)
72:7
consists (2)
41:22,23
Consumer (34)
9:17,25;12:17,19;
13:10,12;15:8,17;
18:2;21:14;24:19;
26:15;27:1;30:3,18;
35:1;42:1;43:5;45:14,
15;47:6;52:18;61:8;
63:9;86:6,8,23;91:12;
107:12,17,22,25;
108:8;109:2
consumers (3)
53:8;61:7;92:8
consumers' (1)
64:14
consumer's (3)
49:1;80:21;81:8
contact (2)
24:21;53:5
contacted (2)
108:2,4
contacts (1)
12:19
continued (1)
26:4
contractor (1)
12:20
control (2)

16:8,20
conventional (3)
21:16;26:17;43:7
conversation (1)
18:12
conversely (2)
20:13;36:13
copies (2)
13:11;58:9
copy (10)
8:10;13:15,19;
48:16,20;49:2;50:6;
62:17,17;87:17
corner (5)
16:16;22:10;29:21;
99:2,8
corporate (1)
7:24
correctly (4)
24:16,18;25:15;
90:23
correlate (1)
26:8
correlates (1)
90:1
correspondence (3)
12:20,24;17:24
corresponding (1)
74:8
counted (1)
43:25
counting (1)
43:11
couple (1)
105:14
course (5)
12:8;35:25;39:25;
42:19;64:13
court (2)
19:6;104:7
cover (2)
48:25;89:2
covered (2)
89:24;90:9
covers (1)
89:2
coversheet (1)
48:24
create (2)
105:22;106:4
created (22)
16:8,21;29:13;
32:18;33:7,8;35:3;
38:25;39:9;40:6,24;
78:3;79:2,14;80:7,9;
93:15;104:14,25;
105:3,6;106:13
creating (1)
105:16
credit (82)
10:12;11:6;12:18;
13:13,20;14:13,25;
15:20;21:10;22:3,19;
(2) Berman's - credit

September 9, 2014

23:11,12,24;28:19,24,
7;15:2,17;16:12;
25;29:17;36:2,4,9,25;
23:15;29:10,23;30:1,
37:5,13,14;38:1;
18;36:3;44:16,20;
41:23;42:10;44:14,
48:7;51:1;60:14;61:7;
18;45:17;48:17,17,
64:23;74:14;89:3;
23;49:7,13,18;50:6,
107:18
22,23;51:1;53:2,16; date (89)
65:12;66:6,7;67:21;
8:13;16:8,20;24:3,
68:13;69:18,21;70:9;
14,17,17;28:18;32:18,
71:3,9,18;72:7,8,14,
20;35:3;40:5,24;41:2,
24;75:1,17,22;80:21;
14,14;45:5;47:4;50:7;
81:6,8,9,12;82:8;87:6,
57:1,11;59:17;60:9;
17;91:11;92:5,16,24;
62:6;66:17;67:13,15,
93:14,14,16;96:14;
15;69:5,25;70:1,13;
98:7;103:4,5;107:5,
72:18;73:2,3;77:2;
16
78:1,3;79:1,14;82:13,
creditor (2)
13,14,23;83:3,8;
84:17;107:18
86:22;87:9,10,25;
creditors (4)
88:1,12,12;89:5,5,6,6,
53:7;84:16;85:17,
12,12,19,19;90:4,5,7,
24
8;93:11,18;94:2;
CreditScorecom (4)
97:24,25;98:2,5,12,
96:15;99:6;100:24;
14,24;99:1,9,15,19,
101:1
25;100:2;101:7;
curiosity (1)
102:1,6;103:6;105:1,
36:21
18,18;106:1
current (5)
dated (15)
13:13;14:5;59:21;
9:21,25;10:4,6;
79:22;90:19
11:1,10;28:5;39:11;
current/previous (1)
48:18;72:17;81:13;
86:10
87:2;93:4;99:9;103:5
cut (4)
dates (10)
52:2;80:11;91:20;
27:4;62:7,8;82:12,
108:19
22;89:4,7;90:4,5,17
day (1)
59:21
D
days (10)
13:2;26:7;32:8;
D-1 (1)
60:18;77:5,12;78:19,
8:8
20,20,21
D-10 (1)
deal (1)
66:1
59:24
D-11 (1)
Debt (1)
23:2
96:14
D-2 (1)
debtor (1)
9:10
99:12
D-3 (1)
deduction (1)
9:10
62:20
D-4 (1)
Defendant (1)
9:10
60:8
D-5 (1)
Defendants' (4)
9:10
8:8;9:10;23:2;66:1
D-6 (1)
definitely (1)
9:11
62:21
D-7 (1)
degree (1)
9:11
14:7
D-8 (1)
delete (1)
9:11
13:6
D-9 (1)
deletions (3)
66:1
10:23;23:17;44:13
dash (1)
delinquency (6)
86:9
87:10;88:1,12;89:6,
Data (24)
20;90:8
9:21;10:24;13:1,2,
Min-U-Script
demonstrates (1)
47:2
department (4)
7:13,14,20;53:6
depends (3)
52:1;65:20;80:13
deposed (1)
18:8
deposition (15)
8:12,14,20;9:7;
11:23;18:6;23:5;
24:25;50:1,5;58:18,
20;66:21;100:17;
109:19
describe (3)
9:15;10:18;51:8
described (3)
30:22;53:10;72:21
describing (4)
60:12;61:22;63:1,
21
description (1)
20:10
detail (3)
15:6;38:22;41:20
detailed (5)
38:9;39:20;42:23;
71:21;108:22
details (1)
38:15
determine (1)
76:5
deviates (1)
20:10
device (1)
60:14
DFD/DLA (1)
85:10
difference (1)
82:21
different (7)
35:8,13;37:13,14;
50:8;55:6;82:12
digits (3)
23:25;32:24;100:21
directly (5)
24:22;30:18;92:8;
107:18;108:5
disclosure (4)
11:1;48:17;49:18;
93:14
discretion (1)
24:21
discussed (3)
39:4;44:25;82:2
discussing (4)
29:2;84:4,7;100:16
discussion (3)
50:16;58:13;74:18
Dispute (89)
9:17,18,25;10:5,7;
12:5,25;13:22;15:8,
22;16:7,21;19:10;
21:10;22:1,2;26:1;
27:1,19;30:6,8,25;
35:1,10,10,21,22;
39:10;40:8;41:3,5,15;
45:1,2;47:2,14,15,17,
19;48:2,4;50:13;
52:17;63:9;66:6;
70:19;86:16,17;87:2,
25;88:8,8,17,18,18,
24;89:1,3,10,23,23,
25;90:3,9,11,24,25;
91:6,13,17,18,24;
94:10,13,16,19;101:5,
15;102:11,15,16,19,
23,23;103:23;105:2,
5;107:5,21
disputed (14)
13:1;15:16,17,19;
16:9,12;37:15,23;
43:2;46:18;88:22;
90:16;108:8,15
disputes (12)
21:14;26:15;36:1;
43:5;86:10;88:10,13;
107:12,17,23,25;
109:2
disputing (14)
12:17;27:1;30:18;
87:6,9,11,14;88:5,11;
89:10,14;90:7,12;
108:5
doc- (1)
57:17
document (44)
8:11,16;9:1,15;
10:17;15:5,7,11,13,
15;16:15;23:6;29:9,
18,25;30:24;31:8;
32:9,16;34:24;35:7,
15;44:1;48:15;50:4;
56:17,18;61:23;
62:17;71:20;80:7;
87:16;94:3;95:15;
96:2,7,15,25;97:4;
99:5;100:7;103:18;
106:3,24
documentation (1)
57:24
documents (49)
7:21;9:2;11:3,14,
17;35:9;38:6;40:23;
53:9;57:18,18,23;
60:2,4,5;61:13;62:4,9,
10,12,15;63:7,11;
65:22;66:5;72:16;
76:3,6,9;91:12,17,23,
25;92:11,15,20;
94:22;95:5;96:1;
101:12;102:12,13;
103:14,24;104:14,24;
105:3;106:7,13
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17:14,15,16;28:25;

30:5;57:25;62:25;
73:25
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26:9;33:14;34:4;
75:24;86:9
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61:2
downloading (1)
19:12
drill (1)
18:10
drive (1)
60:19
due (7)
26:7;32:7;77:5,12;
78:19,20,22
duly (1)
7:2
dumps (1)
51:18
during (4)
12:7,12;79:11;
81:18
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earlier (7)
15:8;44:25;63:8;
65:21;74:11;84:8;
85:22
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21:25
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25:11;66:20
effect (2)
8:15;48:4
effort (1)
11:15
either (7)
13:4,5,6;66:6,7;
69:13;108:11
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9:18;58:24;60:5,5,
17,18,19;61:14,22;
75:22;97:15
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12:25;16:2;17:15,
16,18,22;29:11
elimination (1)
62:20
else (2)
26:24;77:17
email (2)
53:11;59:6
emailed (1)
96:12
emphasize (1)
32:10
employed (1)
7:9
employee (4)
16:3;17:21;19:11,
15
(3) creditor - employee

September 9, 2014

enclosed (1)
87:17
end (6)
45:2,6,7;79:20;
107:8,8
ended (1)
36:23
enough (2)
9:6;34:22
entering (1)
80:13
entire (1)
34:13
entity (2)
8:4;73:19
entries (1)
46:7
entry (2)
43:14;67:11
e-OSCAR (12)
17:19,23;19:15;
20:6;31:6;36:7,10;
41:5;45:10;73:20;
75:18,21
Equifax (105)
7:10,25;10:3,24;
12:4,12,19;13:3;
14:23;15:1,12,21;
16:3,8;17:13,21;
19:24;20:12,18,19;
21:8;22:18;26:4;28:4,
12,17,20;29:11;30:21,
25;31:6;32:5;35:2,14,
18;36:15,16;38:5,7,
14;39:8,12,16;40:3,7,
20;41:5,6,9,14,17;
42:2,10;45:11,12;
49:11,18;51:3,6;
52:18;53:24;55:8,8;
56:24;57:3,19,23;
58:7;61:18;62:10,11;
64:3,24;65:13;68:12;
69:1,4,9;70:2,17,24;
72:20;73:16,20;
74:14;76:5,17;88:15;
92:2,4;94:19;95:7;
97:12;99:14,20,25;
100:8,10,23;101:3,8,
22;102:7;106:25;
108:6
Equifaxcom (5)
97:5,15;98:25;
103:19;106:18
Equifax's (9)
12:8;13:8;14:13;
40:25;50:3;53:5;64:3,
24;99:12
equipment (2)
63:15;64:16
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60:2
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21:15;26:16;43:6
Min-U-Script
ESTEVES (8)
64:7;65:3;104:9,12,
16,18,22;109:14
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64:16;89:9;90:19;
94:9,11;100:5;106:4
everybody (1)
14:11
evidentiary (2)
31:16;32:2
exact (2)
65:24;109:1
exactly (1)
33:7
EXAMINATION (2)
7:4;74:20
examined (1)
7:2
example (4)
51:19;85:8;108:1,4
Except (1)
12:5
excluding (2)
23:25;76:6
Exhibit (185)
8:8,11,19,21,21,21,
25;9:10,14,16,20,24;
10:2,5,9,15,16,18,20;
11:1,5;15:5;16:1;
23:2,5,7,20;25:22,24;
26:11;27:7,16;28:1,9,
11;29:2,9,10;33:10;
34:23,25;35:7,8,11,
11,15,16,18,18,25;
36:14;37:9,9,11,12,
23;38:1,11,15,17,21,
23;39:3,4,17,20,24;
40:1,6,11,17,20,24;
41:7,8,11,17,19,21;
42:12,24;43:9,20;
44:3,5,9,10,21,22,24,
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47:7,10;48:9,15,16;
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54:12;55:11,15,19,23,
25;56:1,5,17,18,21,
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68:12;69:16,17;
70:16,16,22;71:12,19,
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76:11,14;81:24,25;
82:3;83:10,15,18;
84:22;86:1,17,18;
87:1,3,4;88:7;89:16;
92:11,23;93:2,4,11;
94:16;95:11,20;
96:10,18,22,25;97:7;
98:22;99:2,3;100:18;
101:24;102:2;103:4;
106:18;107:4;108:21;
109:5
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8:20;11:13;12:1,3;
45:9;50:16;54:14;
57:20,22;66:5,12;
101:6
existing (2)
104:17,18
expedited (1)
109:18
Experian (2)
35:22;100:12
expert (1)
75:1
Explain (2)
50:8;74:25
explained (1)
50:15
explains (1)
38:8
exported (1)
97:5
Express (2)
85:9,10
extent (1)
37:3
external (1)
60:10
extrapolate (1)
22:8
F
facilities (1)
64:25
facility (1)
64:3
fact (4)
43:25;50:10;100:3;
105:24
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15:25;34:22;36:12,
13;48:1;61:21;107:16
fairly (1)
38:4
falls (1)
79:13
familiar (3)
32:4,14;97:3
far (10)
17:3;19:25;65:18;
75:6,7;77:8;78:24;
97:11;99:19;103:20
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9:19,22;10:3,7;
15:20;16:13;17:4,17;
18:23;19:10,11,15,23;
20:7,14;21:17;22:8,
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25:2,9,12,12;26:3,12,
23;27:3,10,25;28:6,
13;29:12,14;31:7;
35:3;36:3;37:1,6;
38:24;39:15;40:14;
41:3;42:14;43:2;
44:23;45:12;46:4,18;
48:3;51:18,20;52:7,9,
11,14,14,16;53:5;
54:8,16,17;56:22;
57:6;58:7;59:1,1;
60:7,7;62:2;63:23;
64:5,19;66:8,22;67:6,
9;68:5,14;69:3,8,19;
70:2,9,23;71:10,15,
24;72:15;73:15,18;
76:18;81:15;83:21;
84:9,12;85:20;86:12;
87:8;89:11,16,21;
90:11;93:8;94:4,19;
97:11,21;99:22,23,24;
100:1,13;101:8,18,22;
102:8;103:17,22;
104:25;108:2,4;
109:1,5
Fargo's (3)
22:1;79:20;97:9
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66:16
FCRA (2)
16:10;88:19
February (5)
77:3;80:10,11,12;
82:14
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91:6
few (1)
15:6
field (3)
74:12;88:20;91:5
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53:1
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79:12
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10:12;13:14;21:10;
29:17;41:23;44:14;
48:17,23;50:7;80:21;
93:14;103:5
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87:24;92:1;102:19;
103:23
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20:1
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49:10;67:24
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44:9
Finance (2)
54:19;67:11
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61:8;63:16;76:8
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108:1,18
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95:19
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7:2;16:14;21:2;

24:8;29:20;33:9,12;
41:23;43:14;46:20;
49:3;53:17;54:17;
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101:21;107:9,9,11
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53:14
five-minute (1)
74:3
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63:16
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83:20
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32:24;54:25;70:19;
72:15
follows (3)
7:3;26:18;54:22
follow-up (3)
74:6;105:14;107:3
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20:11
foreclosed (1)
28:15
foreclosure (85)
21:15,21;22:3,5,14,
21;25:1,2;26:10,16;
27:11,14;28:5,7,7,15;
29:3;32:7;42:13;43:6;
44:22;45:22;47:24;
48:5,8;55:2,4,9,11;
57:15;67:17;68:16,
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70:4,7,11,14;71:6,11,
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78:5,6,8,23;80:16,17,
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102:4,8,17,20,25;
103:2,8,9,20;105:17,
19,21;106:8,9,20
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73:11,11,12,12
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18:4
Form (38)
9:21;14:16,19;
17:12,17;19:18;
29:10,23;30:14;31:5,
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36:14,19,20;37:16;
39:20;41:6;51:23;
52:4;53:13;60:20;
61:14,22;64:7;72:8;
80:18;88:3;89:23;
94:1,14;95:6;102:9,
21;103:12
format (6)
41:11,11,13;46:14;
(4) enclosed - format

September 9, 2014

60:23;78:18
formats (1)
35:13
formerly (1)
60:9
forth (2)
73:10;78:20
forward (3)
15:16;59:9;79:16
found (2)
65:15,17
foundation (2)
19:19;37:17
four (12)
23:25;43:12,22,25;
44:3,5;67:6,7,24;
73:11;78:15;100:21
fourth (6)
21:16;43:8;44:8,24;
53:1,10
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85:5
front (14)
11:4;22:5;39:23;
49:10;55:15;61:13;
70:12;76:14;81:25;
83:18;87:4;97:1;
101:2;103:14
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7:6;21:4;28:19;
34:9,9,17,18;55:18;
71:3;74:13;76:24,25;
77:23,24;80:6;90:20;
93:22;98:19
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23:13;63:22
furnisher (21)
14:2,9;15:17;16:13;
17:10,14;20:20;
23:15;30:2,19;31:7;
36:3;45:11;48:7;
50:20;51:1;52:20;
61:7;74:14;89:4;
107:19
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13:1,2;15:3;32:5
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13:7
furnisher's (1)
10:24
further (2)
105:7;109:11
G
gathered (1)
62:23
general (3)
20:10;47:18;52:7
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36:13
generate (4)
15:23;76:17;79:24,
Min-U-Script
24
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15:11;17:22;83:7
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20:7
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45:19;90:6
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45:4
giving (1)
72:8
glance (1)
11:22
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12:21;24:1;78:25;
79:1,2;107:10
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74:22
gracious (1)
9:6
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86:19
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78:7,11,14,16;81:4,
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20:23
guess (4)
18:20,21;42:7;
62:22
guidelines (1)
18:6
guys (1)
69:1
H
halfway (1)
33:14
hand (2)
15:4;66:3
handing (1)
66:4
handled (1)
19:23
handy (1)
66:14
happen (2)
50:24;51:25
happened (3)
22:17;73:15;108:3
hard (3)
58:9;60:19;62:17
head (1)
49:22
heading (2)
98:3,4
headings (1)
98:4
hear (2)
31:20;56:10
hearing (2)
31:16;32:2
heart (1)
32:12
held (3)
39:2;58:14;74:19
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14:4,5
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82:8;93:16;98:7
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24:15;27:2;39:1;
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75:3;76:12;82:10;
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33:2
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29:14;32:17;35:5
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10:16;27:9,14;28:4,
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44:22
Including (6)
21:21;22:13;28:7;
83:21;89:11;90:11
incorrect (2)
87:9,10
indecipherable (2)
75:2;79:4
independent (1)
76:4
indicate (5)
48:7;77:17;86:15;
102:14;106:8
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46:4;57:9;69:24;
91:10
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22:9;43:5;60:9;
85:16,17;86:16;89:8;
97:23;99:7,24
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22:5
indicator (1)
12:23
individual (5)
25:6;32:16;36:1;
37:24;50:14
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51:20;52:24
individual's (1)
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I
53:12
Information (170)
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10,10,19;17:5,7,8,9,
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20:2,3,11,15,18,20;
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21:2,7,9,12,13,17;
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22:4,17;23:13,14;
56:15;96:25
24:2;26:13,18,19,22;
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27:4,5,10,24;28:16,
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31:6,8;32:5;33:13,24,
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34:23;48:15;54:9
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18,20;108:5,6,16;
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24:19
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7:14
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29:21
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23:8;30:21;35:18,
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41:9
initiating (1)
18:2
insofar (1)
55:8
instead (1)
95:17
intended (1)
16:19
Interesting (1)
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internal (5)
13:8;44:16;107:24;
108:10,14
interrupt (2)
18:14,16
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27:16;38:14;41:19;
43:25;44:17,25;
50:22;51:12;60:24;
61:2;71:9;72:2;80:13;
81:19
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92:6
investigation (15)
10:11;13:10,12,18;
23:20;39:13;43:3;
46:25;58:5;62:4;
63:11;70:19;107:23;
108:9,15
issues (2)
42:6,8
(5) formats - issues

September 9, 2014

item (10)
12:18;24:21;57:10;
58:23;60:2;67:15;
70:1;73:1;92:10;
93:11
items (7)
20:10;27:14;57:1,
10;88:5;89:22;94:20
J
January (5)
80:12;81:13;82:18;
93:19;98:13
Jason (2)
9:6;18:20
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43:18;51:9;60:22;
94:23
July (42)
21:25;22:11;27:18;
28:5,12,24;29:1;
45:25;55:14;56:16;
57:2,14;58:1,6,8;62:5,
6,13;66:18;67:12;
68:12;70:17;71:18;
72:2,9,17;93:24;94:7;
98:25;99:25;101:9,
10,23;102:6;103:3,7,
9,10,11,20;106:19;
107:4
June (34)
10:4,6;21:25;39:9,
12,12,14;40:6,8,24;
41:1,15;47:19;59:9;
67:21;69:17;70:19;
87:3;91:18,24;92:15;
93:7;94:9,11;101:13,
23;102:15;103:22,23;
105:1,4,5;106:12,12
K
keep (1)
47:17
kept (2)
12:11;58:25
kidding (1)
68:25
kind (7)
7:18;53:12;58:24;
60:6,13,14;84:3
knows (2)
14:12;44:1
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15:19;25:7;27:3;
28:20;30:6,8;37:24;
39:2,11;41:1;45:1;
47:6;48:19;49:14;
59:2;60:8;66:7;70:18;
78:13;86:25;87:5;
89:9;91:16,22;92:14;
Min-U-Script
94:18;96:14;101:14;
107:5;108:2,4,15
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22:19;28:23,25;
40:7;41:15;44:14;
47:19;48:23;63:22;
64:4,10,18;65:12;
71:9,18;72:7;87:2;
89:18
80:19;87:2,7,13;88:4,
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83:22
letting (1)
70:18
light (1)
16:5
likely (2)
62:24,24
limited (2)
L
59:8,21
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labeled (1)
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56:17
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101:13;102:10;104:1,
19:19;37:17
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line (63)
46:14
15:20;21:15,15,16;
laptop (1)
26:9,10,13,14,19;
60:19
27:21;28:2,13;29:1;
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42:9,16;44:8,18;45:5;
10:16,18,20;23:25;
46:24;48:5;49:5;
24:17,17;26:13;28:2;
50:10,25;53:3,17;
42:4;46:10,12,20;
54:24;55:20;57:6;
58:6;62:6;68:7;69:5;
64:5;65:12;66:8,22;
86:1,11;87:9,25;
67:18;68:5,7,14,17;
88:12;89:5,19;90:8;
69:7,20;70:3,23;71:1;
100:21;103:6;104:5
72:2,11;73:4;74:7;
late (8)
79:3,5;80:11,22;
77:8,15;78:12;81:7,
86:15,16,18;89:22;
15,18;88:25;90:17
90:6;92:9;94:21;
later (2)
97:20;107:7,8,9,11;
24:25;105:5
109:4
lawsuit (2)
lines (5)
42:6,9
21:5;49:4;51:20;
lawyer (2)
54:9;67:6
7:16;64:21
lingering (1)
layer (1)
42:8
73:19
list (3)
layman (1)
8:22,23;9:1
11:5
listed (3)
least (4)
40:16;84:11;86:23
11:22;55:7;100:23;
little (7)
101:9
13:21;15:6;19:4;
left (3)
34:4;38:22;41:20;
57:10,10;99:19
87:20
left-hand (3)
LLC (1)
16:16;22:10;29:21
7:10
Legal (7)
loaded (2)
7:12,13,14,18,20,
51:12,20
21;8:4
loan (11)
lender (3)
28:14;45:5;46:8;
25:3;28:22;34:12
48:11;94:12;97:21;
length (1)
100:15,23;101:8;
50:15
102:8;105:1
less (10)
21:4;34:9,18;55:18; loaning (1)
72:8
76:24,25;77:24;
loans (2)
90:20;93:22;98:19
14:24;96:14
letter (20)
10:5;12:5;39:10,11; located (3)
58:2,3;98:2
40:8;41:15;47:20;
longer (3)
70:20;78:8,9,22;
44:5;57:14;70:4
look (22)
13:20;21:23;32:8;
44:16;46:24;47:9;
54:12,13;55:14;61:5;
76:20;79:14;84:15;
85:8;87:16;88:7;
95:24;96:24;99:3,17,
19;100:11
looked (1)
41:24
looking (10)
27:6;43:8;45:17;
56:25;67:3;72:22;
75:11;81:23;91:3;
105:17
looks (5)
32:17;35:25;37:9;
41:7,7
lot (1)
37:9
loud (1)
19:7
41:16;44:9,21;48:14;
56:18;57:17,18;
58:17;65:25;66:12;
71:20;96:9,21
marks (1)
78:15
masked (1)
100:21
matter (1)
100:2
may (21)
8:22;11:19;23:16,
17;24:21;35:19;
36:23;42:18;51:5;
53:4,5,8;60:14;62:16;
66:15;80:10,11;90:5;
91:6;92:4;105:6
maybe (6)
18:22;23:22;60:17;
79:17;84:13,19
mean (14)
13:17;23:11;35:21;
38:16;61:4;78:11;
79:9;80:5,20;81:2;
M
85:18;102:2;106:23;
107:14
means (10)
M5 (6)
13:19;26:5,6,6;
25:25;26:4,5;43:4;
77:20;78:18,21;
88:24;91:5
79:10;82:23;86:5
mail (1)
meant (1)
12:21
56:3
maintained (1)
meat (1)
12:11
49:11
maintenance (6)
memory (1)
10:21;13:4;43:19;
55:14
46:11;86:2,24
mentioned (6)
major (2)
40:5;60:21;64:15;
36:2;42:10
65:21;74:11;85:22
making (1)
mess (1)
52:6
18:19
manager (1)
method (2)
7:19
60:15;72:19
manner (5)
metro (2)
51:4;56:14;71:9;
32:11;78:17
92:4,5
middle (2)
manners (1)
20:24;47:10
91:10
middleman (3)
manual (2)
14:14,14;69:1
58:9;62:17
might (1)
many (4)
106:3
32:11,11;51:21;
mind (2)
77:5
39:24;75:21
March (10)
minute (3)
10:1;35:4;67:16;
33:2;47:8;105:9
69:4;78:1;79:15;80:9,
minutes (1)
9,12;100:22
15:6
mark (7)
Miss (33)
9:13;95:4,10,16,18,
22:10,19;25:7;27:3;
20;96:17
28:20,23,25;30:6,8;
marked (24)
37:24;39:11;40:7;
8:7,11;9:9;15:4;
41:1,15;44:14;47:6,
23:1;27:16;28:8;29:8;
19;48:23;63:22;64:4,
34:23;35:8;36:14;

(6) item - Miss

September 9, 2014

10;68:4;74:23;81:12;
84:24,25;87:2;91:16;
94:10,18;96:24;
97:21;104:13
missing (1)
49:3
mistake (1)
44:4
mistaken (2)
84:23;85:15
modern (3)
61:14,19;74:10
modernized (1)
74:9
modify (1)
13:6
moment (6)
26:12;82:10;83:10,
13;87:19;93:1
money (1)
72:8
months (3)
21:24;77:16;79:17
more (14)
7:19;15:6;18:23;
26:7;38:9,22;39:19;
40:13;41:20;50:18;
74:9,9;78:22;106:4
morning (6)
46:9;48:12;53:15;
54:11;66:9;67:8
Mortgage (38)
9:23;10:4,7;15:20;
21:16,16;26:6,13,16,
17;28:13;29:12,15;
35:3;38:24;42:14;
43:3,6,7;46:19;54:9,
16,18;56:22;57:6;
59:1;60:8;67:10;
69:19;81:15;82:25;
83:21;84:12;86:12;
87:8;94:4;100:1;
108:5
Most (4)
16:4;62:24;105:22;
106:5
Mrs (19)
45:1;59:2;65:12;
66:7;70:18;71:9,18;
72:7;86:25;87:5;89:9,
18;91:22;92:14;
101:14;107:5;108:2,
4,15
much (2)
35:12;85:5
multiple (1)
52:23
N
NA (1)
60:7
name (10)
Min-U-Script
7:6;16:24;20:1;
22:10;29:12;35:4;
40:16;59:2;60:8;85:5
named (1)
32:17
narrative (27)
21:2;22:13,21;
23:19;28:8;45:22;
47:9,12,13,22;48:5;
55:1;69:7;70:5,11;
72:11;90:20;98:16,
18,20;101:16;107:9,
10,12,22;108:11,25
narratives (3)
20:25;22:3;27:14
nature (1)
49:1
near (1)
22:10
necessarily (5)
35:17;59:15;80:5;
84:21;85:18
need (7)
73:24;74:3;75:7;
91:6;93:1;101:12;
105:9
needs (1)
59:20
nevertheless (1)
63:20
new (1)
33:25
next (7)
24:13;48:14;67:20;
69:16;72:14,14;98:12
nice (1)
18:12
ninth (1)
68:8
Nnadi (3)
17:1;39:1;40:15
Nnadi's (1)
22:10
Noncredit (1)
68:1
none (4)
58:2,3;65:15,17
nonindividual (1)
67:24
nor (4)
18:20;63:15;87:14;
101:3
normal (4)
12:8,12;30:3;35:25
notated (2)
23:18;28:1
notation (2)
13:21;94:17
notes (1)
46:25
Notice (5)
8:19,21;55:13;
58:20,23
number (39)
9:14,16;16:8,20;
23:25;24:23;28:13;
32:8,17;42:22;51:19;
54:20;58:23;60:4;
61:23;63:24;64:6;
65:1;78:21;83:7;
86:16,17,18,18;87:8;
89:3;90:3,24;97:8,9,
10,12,21;98:22;100:9,
11,15,16,18
Numbers (3)
9:10;20:23;66:1
67:7;68:11;74:6;75:3;
76:12,16;78:16,18;
79:17;85:25;88:8,13,
18;89:2,23;90:11,24;
91:9,10;96:12;97:12;
100:5;104:4;106:15
one-page (1)
108:22
ones (2)
65:13,16
one's (1)
53:16
online (2)
17:25;75:22
only (24)
O
34:2;42:7;52:16;
58:4;60:25;62:15;
Object (16)
63:2;64:10;77:14;
19:18;30:14;31:12;
79:16;80:22;88:17,
36:19;37:16;51:23;
21;89:2,9,25;90:7,15;
52:4;59:23;64:21;
91:4,8;92:1;96:1;
80:18;88:3;94:1,14;
103:9;108:13
102:9,21;103:12
onward (1)
objected (1)
45:25
59:6
open (5)
Objection (6)
78:15;79:6,9,23;
14:16,18;31:20;
89:7
37:6;64:7;65:3
opened (5)
objectionable (1)
89:12;90:5;99:15,
36:24
20,25
obtain (2)
open-ended (1)
99:12;100:9
12:16
obtained (1)
opens (1)
48:3
12:21
obviously (1)
operations (2)
42:9
12:9,13
Off (14)
opposed (2)
22:23;31:1;49:21;
20:11;63:14
52:3;58:11;72:4;
74:16;80:11;84:4,7; option (1)
88:17
91:20;96:19;104:9;
order (6)
108:19
66:4,11,12,15;
offends (1)
95:24;109:17
59:23
ordinary (1)
office (1)
50:3
11:20
organization (1)
offline (1)
88:16
30:1
organizer (1)
off-the-record (2)
14:14
58:13;74:18
original (2)
often (1)
24:3,9
51:25
originates (1)
Once (7)
50:13
13:3;19:23;61:25;
originating (1)
78:20;82:25;91:2;
36:15
108:10
others (1)
one (48)
48:24
10:14;11:9,19;
otherwise (2)
13:19;24:5;26:24;
8:14;18:18
35:12;36:1;40:20;
out (21)
41:7;42:6,8,23,23;
17:13;19:7;36:21;
46:21;50:20;51:2,21;
45:10;61:8;63:23;
52:18;54:10,10;
64:2;66:4,16;73:11,
60:25;64:24;66:8;

12,14,14;75:13;
79:12;85:12;105:20,
21,22;106:2,24
outlines (1)
10:22
outside (1)
30:3
over (7)
41:3;50:16;75:14,
25;83:21;91:19;98:13
own (1)
52:19
owned (1)
64:3
P
P-12 (1)
96:10
P-13 (1)
96:22
page (50)
8:25;20:24,24;
26:14;29:20;32:15;
33:9,12;43:8,12,15;
44:1,8,24;48:23,24;
53:18,18,20;54:3,5,9,
18;56:25;57:7;66:21,
23,25;67:3,4;68:5,6,8,
13,14;69:17,19;
70:25;73:2,5;78:2;
83:20,21;85:8,19;
86:12;93:7,10;95:7;
97:7
pages (21)
10:16,18,21;42:4;
43:12,23,25;44:3,5;
46:10,12,20;48:25;
49:3;67:24;83:19,20;
84:15;86:1;92:1;95:6
paginated (1)
43:11
paid (19)
21:3;33:21;34:9,9,
13,14,17,17;55:18;
76:24,24;77:23,24;
90:20,21;93:8,21;
98:9,18
PAMELA (2)
7:1,8
paper (3)
16:2;74:9;75:12
paragraph (1)
23:23
paralegal (1)
7:16
part (7)
41:23;42:3;43:19;
48:22;70:23;77:9;
107:12
partial (3)
48:16,20;49:2
particular (7)
(7) missing - particular

September 9, 2014

8:18;12:18;50:9;
53:16;61:8;97:4;
99:12
parts (1)
41:23
party (1)
20:7
passes (1)
20:6
past (7)
26:7;32:7;77:5,12;
78:19,20,22
paying (8)
24:15;27:2;87:15;
88:23;89:17;90:1,16;
91:7
payment (21)
24:17;77:7,8,15,16;
78:7,12;80:22;81:4,5,
7,16,18;83:5;87:9;
88:1,12,25;89:6,19;
90:8
people (1)
24:24
per (1)
10:23
percent (2)
33:1;63:3
perfect (7)
21:23,25;22:7,12,
16;70:8;75:15
perhaps (2)
21:25;106:3
person (6)
14:12;17:4;20:1,2;
40:14;65:18
personally (2)
11:15;76:3
pertinent (1)
104:8
phone (7)
14:12;17:25;32:17;
53:11;75:10,10,12
phonetic (3)
25:25;32:11;96:5
phrase (2)
52:14;109:4
physical (1)
74:9
piece (2)
16:2;75:12
place (3)
85:24;88:19;107:19
placed (1)
38:17
plaintiff (7)
23:9,10,13;24:19,
25;25:1,8
Plaintiff's (4)
95:11,17;96:10,22
plastic (1)
66:21
players (1)
Min-U-Script
36:9
please (16)
7:7;8:18;31:13;
37:21;42:22;48:15;
51:8;74:25;75:18;
83:10,14;91:21;
96:24;102:5;104:5,11
pm (1)
109:19
point (2)
22:20;54:14
pointing (1)
106:24
policies (1)
13:8
portion (5)
16:15;34:14;47:12;
99:25;104:8
portrait (1)
46:15
position (1)
7:11
possibility (3)
58:4;60:21;82:25
possible (4)
12:15;28:4;30:13;
105:15
possibly (3)
53:4,13;80:6
potential (1)
28:22
practice (1)
50:3
prefaced (1)
52:13
prehistoric (1)
60:20
premarked (2)
23:5;38:20
present (1)
92:16
presented (3)
102:13,14;103:15
pretty (2)
12:16;35:12
previous (2)
55:6,7
print (1)
50:6
printed (1)
95:1
printout (3)
10:9,10;41:22
prior (17)
22:1,1;24:4,14;
27:2;41:2;59:11;
79:17;87:14;88:23;
89:17;90:1,16;91:7;
102:1,6,11
pro (1)
18:7
probably (6)
16:2;63:16;79:23,
24;84:13;98:5
problem (1)
59:25
process (30)
12:17;13:25;18:3;
19:10,22;23:8;30:21;
31:2;35:10,10;40:25;
41:10,24;44:15;45:2,
8;48:2;50:15;57:3;
62:19;71:13;73:20;
74:13;84:23;88:17;
92:13;101:14;102:11,
15,24
processes (1)
85:24
produce (6)
7:21;9:6;58:10;
62:10,18;63:12
produced (15)
9:2;11:22,25;39:5;
49:11;57:19,23;
62:11;65:13,16,22;
76:3;92:20;95:7;
103:24
production (1)
50:4
proof (1)
71:20
provide (10)
14:23;24:22;53:8;
61:11,12;89:22;
91:16,23;92:14;93:2
provided (27)
13:12;17:5,9;20:2,
14;21:8,17;24:2;
26:23;27:10;28:16;
42:1;44:21,23;47:6;
55:7;67:13,14;69:3,8,
25;70:23;73:15;
86:25;91:12;92:8;
99:14
provides (10)
10:10;16:7,9;29:16;
35:5;36:4;39:1;41:25;
42:2;107:6
providing (2)
28:6;71:10
public (1)
92:9
pull (2)
28:23,23
pulled (4)
72:6;97:15;98:24;
104:25
purpose (3)
15:13,15;29:24
put (3)
16:2;31:4;55:15
putting (2)
73:13,14
queue (1)
12:22
quick (1)
74:6
quite (1)
44:5
R
Rachel (3)
29:13;32:17;35:5
rare (1)
53:7
rate (1)
91:5
rather (4)
41:7;46:15,23;
66:11
reached (2)
34:10,12
reaches (1)
83:1
read (14)
19:6;24:8,25;26:20,
23;78:14,16,24;
87:21;104:5,7;
107:14;109:12,15
reading (2)
73:4;91:3
real (3)
21:15;26:16;43:6
really (2)
38:13;85:1
reason (12)
28:1;35:17;45:21;
49:2;50:20;69:6,10,
12,14;87:24;88:22;
103:25
reasons (1)
28:6
recall (3)
75:20;101:13,24
receipt (1)
12:23
receive (3)
13:3;40:7;76:17
received (16)
16:12;20:16,19;
23:15;27:5;39:12;
41:14;46:6;47:3;48:7;
49:22;56:2;60:24;
71:15;86:20;101:18
receives (1)
12:23
recess (4)
22:24;74:4;96:20;
105:10
record (25)
7:7;18:19;22:23;
33:6;40:19;58:12;
59:5;64:20;69:10;
70:6;74:9,10,16;84:4,
6,7,19;92:10;96:19;

101:21;102:3;104:8,
9,11,21
records (15)
9:7;12:4,7;51:2;
58:7,24;60:6;69:13;
76:5;101:1;102:7;
103:21;105:25,25;
106:4
reel (3)
61:1,2,2
RE-EXAMINATION (1)
105:11
refer (4)
25:5,8,12;77:19
reference (22)
22:2;25:11;26:10;
27:15;55:3,17;56:5;
57:14;60:10;67:17;
68:16,22;69:2,20;
71:5,17;73:8;95:7;
97:8;98:1,23;103:2
references (1)
55:2
referencing (1)
13:21
referred (1)
51:13
referring (7)
17:7;27:6;42:3;
52:21;70:4;86:11;
99:22
refers (1)
23:20
reflect (19)
69:11,22;77:2,5,8,
11,13,14;81:7;82:8;
93:21;97:19;98:6,9;
99:15;101:19;102:16,
20;103:21
reflected (4)
35:16;44:23;71:19;
72:15
reflecting (3)
81:15;98:21;102:7
reflects (9)
23:14;44:9,11;47:3,
4;55:5;71:2;78:12;
93:7
regard (2)
51:18;90:24
regarding (10)
24:20;27:5;38:17;
39:2,23;89:19;94:19;
100:9;101:4;103:8
regards (17)
9:16;10:7,20;29:14;
39:14;43:2;50:25;
56:21,23;71:12,13;
84:9,13,22,22;86:12;
94:20
regular (2)
20:11;30:3
reinvestigation (20)
(8) parts - reinvestigation

September 9, 2014

9:18;10:13;18:2;
23:8;27:23;30:21;
31:2;39:15;40:2,25;
41:10,24;44:15;
56:23;57:3;71:13;
84:23;88:16;92:12;
101:14
related (4)
18:23;39:19,21;
87:25
relates (10)
37:10;58:25;82:2;
87:6,12;90:4;91:18;
92:16;105:13,16
relating (7)
42:13;46:8;60:6;
64:5;91:13,17,23
relation (2)
40:2;41:14
relevant (2)
16:10;88:20
reliable (3)
105:23;106:4,5
remember (2)
18:13;49:21
removed (4)
29:6;103:3,10;
108:12
Removes (2)
21:3;55:9
repeat (3)
19:6;91:20;102:5
rephrase (12)
7:23;12:2;14:20;
19:7;27:18;31:13,25;
37:11,22;42:7;52:3;
65:10
rephrasing (1)
52:5
report (83)
10:15;11:6;12:18;
13:20;14:4,25;15:21;
17:8;22:3,19;23:11,
12;26:4;27:16,19;
28:19,24,25;44:18;
45:20,23;47:14,24;
48:17;49:12,15,19,24;
50:5,14,22,23;53:2,
16,24;54:24;55:5,7,7,
15,17;65:12;66:7,17;
67:12,21;68:8,13;
69:18,21;70:9;71:3,9,
18;72:7,9,14,25;73:7;
80:21;81:6,8,10,13;
87:6,18;90:5;91:11;
92:5,6,17,24;93:6,14;
94:10;95:6;97:2,19;
99:9;103:5;105:19,
19,22
reported (60)
13:13;14:8;15:2;
16:6,7;22:6;26:2;
33:25;34:2;42:10;
Min-U-Script
44:12;45:13;55:4,12,
22;57:1,11;58:8;61:9,
9;62:6,16;64:19;
67:10,15;69:5;70:1,
13,15;71:3;72:18;
73:2;77:6;78:4;79:7,
11;85:16;87:12,23;
93:11,13;94:5,12,17,
20;98:5,23;99:10;
100:3,6,8;101:3;
102:4,12;103:7,9,19;
106:9,14,19
reporter (2)
19:6;104:7
reporting (49)
21:10;24:16,18;
25:14;27:4;28:12;
30:4;36:5,10,25;37:5;
43:4;49:7;51:1,11;
54:17;56:22;67:16;
68:1;70:2;74:14;75:1,
17,23;76:20;79:13;
83:25;84:1,3,7,14;
85:18,20;87:18;
88:24,25;90:17;93:8;
100:2,23;101:8,16,22;
102:8,24;103:8,22;
105:1;106:8
reports (10)
14:24;15:1;16:4;
36:2;44:13;45:18;
52:24;66:16;71:24;
73:11
represent (2)
79:6;80:6
representative (3)
7:25;11:17;53:5
representing (1)
80:15
represents (5)
78:8,23;80:6,17,19
request (14)
9:1;10:24;13:7;
49:17,20,23;50:7;
53:6;61:23;63:24;
64:25;65:21;93:5;
101:18
requested (1)
89:21
requesting (1)
29:16
required (1)
107:19
reschedule (1)
8:13
research (1)
108:14
researched (1)
23:24
resolution (6)
21:14;26:15;43:6;
107:13,23;109:2
respond (3)
13:3;19:16;59:20
responded (5)
22:9,11,12,13;59:5
responder (5)
16:24;20:1;29:13;
38:25;40:11
responder's (1)
35:4
response (42)
9:5;13:4;14:1;17:9;
19:9;21:11,19;22:2;
25:18;26:3;27:10,19;
28:8;30:6,8;31:4,20;
45:1;46:6;48:4,6;
49:25;56:1,2;57:19,
24;62:11,12,23;
65:14;66:6;70:17,24;
71:14;72:4;91:9;
92:21,24;93:5;
101:17;107:5;108:25
responses (2)
13:5;16:12
responsive (6)
61:23;63:24;64:6,
25;76:6,9
rest (4)
21:4;27:13;32:23,
24
restate (1)
37:20
result (3)
35:9;44:9;84:20
results (17)
10:10;13:11,18;
23:7,11,18,20;24:1;
27:23;41:25;45:6,7;
56:21;71:14;95:6;
97:20;107:25
review (12)
11:21,24;12:21,24;
13:5;42:18;76:4;
86:17;100:18;101:12;
107:24;108:10
reviewed (3)
38:7;40:23;72:17
reviewer (1)
13:4
reviewing (3)
67:4;72:23;98:22
revised (4)
13:11,15,19;23:24
right (33)
14:15;15:9;16:20;
20:25;22:9,14;34:5;
47:10,20;49:21;
59:14,16;61:6;63:24;
65:1;68:15,17;69:4,
14;72:3,22;73:16;
81:5;83:22;85:11,14;
91:1;95:9,22,23;
104:19;106:1;109:6
right-hand (3)
33:14;99:2,7
rights (1)
49:1
role (1)
14:13
room (1)
14:11
route (1)
12:22
run (3)
36:7,10;51:6
separate (2)
10:17,17
September (15)
11:2,10;48:19;
53:23;55:5,10,17,19;
56:18;72:24;92:25;
93:4,6;94:3;103:6
sequential (1)
95:13
servers (2)
61:18,19
S
service (1)
97:16
Services (1)
same (18)
7:10
13:19;31:5,5,7;
set (2)
35:9,12;40:2;46:8;
79:23,24
56:5;76:25;77:23;
setting (1)
82:1,5;95:24;96:7;
53:12
97:13;100:20;109:1
settlement (5)
saw (1)
34:10,11,21;59:8,
36:24
18
saying (3)
several (2)
30:24;39:21;57:13
11:20;98:3
scenario (1)
(16)
30:22
9:19,23;10:1,3,6;
scope (4)
11:2;15:19;29:17;
12:8;38:13,18;59:6
39:2;48:19;49:14;
screen (2)
60:8,9;64:18;78:13;
66:14;75:12
96:13
second (25)
sheet (4)
10:14;21:15;23:22;
10:21;43:19;46:11;
24:5;32:15;46:21,22;
86:2
57:10;58:12;67:11;
68:11,13;73:4;74:17; sheets (1)
48:25
75:3;76:12;78:2;
shot (1)
79:23;86:16;98:4;
51:21
99:23;100:1,13;
show (13)
104:4;107:10
8:10;23:4;34:22;
seconds (1)
38:20;48:14;58:16;
33:3
81:6;93:18;98:23;
section (8)
104:25;106:1,2,14
20:22;41:25;47:9,
13,22;86:5;107:6,10 Showing (4)
27:21;29:8;46:23;
sections (1)
102:3
48:9
shown (1)
Secure (1)
81:9
75:22
shows (7)
seeing (1)
46:23,24;47:1;
67:23
93:16;96:5;103:19;
seem (1)
106:18
18:6
shut (1)
seems (2)
18:18
18:22;75:11
side (6)
sense (1)
19:9,10;34:5;51:10;
60:18
57:10;85:13
sent (10)
sign (2)
12:25;13:10;29:11;
109:13,15
31:6;33:5,8;39:11;
silent (1)
94:23;95:25;96:15
31:22
sent/submitted (1)
similar (2)
35:2
35:10;39:3
sentence (2)
simple (1)
24:8,13

(9) related - simple

September 9, 2014

13:25
simply (2)
14:13;82:23
single (2)
30:2;84:17
situations (1)
41:4
six (1)
78:21
sixes (1)
78:15
SMITH (5)
7:1,8;74:23;96:24;
104:13
snapshot (1)
45:4
sole (1)
87:24
solely (1)
109:5
somebody (1)
18:13
someone (1)
71:23
Sometimes (3)
30:17;53:8;84:24
somewhere (4)
64:2,24;80:2;81:22
sorry (21)
18:2;24:6,12;25:22;
37:20;40:18;52:2,2;
56:3,9;60:3;68:10;
77:9;85:1,5;86:18;
91:22;94:11;100:1;
101:23;108:19
sort (6)
18:6;20:24;46:24;
53:11;54:15;62:22
sought (1)
9:2
source (5)
24:3,9;35:19,21;
71:19
south (1)
63:16
SPAULDING (66)
11:9;14:16,18;
19:18;27:22;30:14;
31:12,17,21;36:19,22;
37:3,16;43:18,22;
44:2,6;51:23;52:4,6,
10;53:22,25;54:3,6;
56:7,9,20;59:4,11,19;
66:24;74:2,21;75:5,7,
14,16;76:15;80:23;
83:16;85:2;88:6;94:6,
22,25;95:3,9,14,19,
25;96:4,13,17,23;
102:18;103:1,16;
104:2,10,20,23;105:7;
106:17,23;109:10
Spaulding-White's (1)
68:4
Min-U-Script
speak (3)
8:5,5;75:10
speaker (1)
75:4
speaking (1)
86:6
special (4)
34:6,15;76:21,23
specialist (1)
85:23
specialized (5)
51:10;60:23;62:1;
74:12;97:18
specific (2)
52:7;67:24
specifically (2)
55:24;56:14
speculate (4)
62:15;63:2;88:21;
91:8
speculating (2)
58:5;108:13
speed (1)
66:20
spoke (1)
91:19
stand (1)
29:22
standard (1)
78:17
stands (10)
33:19,21;34:7,8;
75:19,21;76:23;
77:22;83:24,25
start (5)
41:1;74:3;75:14;
80:10;95:8
started (3)
39:13;47:19;79:20
starting (5)
21:14;28:14;29:15;
32:25;107:8
starts (1)
79:17
state (36)
7:6;14:6;30:7;33:6,
7;34:1,15,20;40:22;
48:6;55:10,21;60:25;
61:25;62:3;64:9;
71:12;79:20,21;
81:11,14,16;84:13,21;
89:15;90:15;91:4;
93:10;94:2,15;
100:25;101:11;
102:10,22;108:3,3
stated (5)
44:2;49:2;97:6;
103:6;105:4
statement (3)
25:17;106:22;
108:12
states (11)
23:23;24:1,3,13;
26:14,15,16;73:2;
87:8;98:18;107:22
stating (8)
30:10;34:16;39:22;
62:14;77:22;81:17;
107:20;108:7
status (28)
24:15;25:14,21;
26:1,4,5;27:2;33:15,
20;34:5;43:4;77:18,
20,20;82:5;83:6;
86:10;87:11,14;
88:23,25;89:12,17;
90:1,16;91:7;92:6;
101:16
still (7)
8:14;31:17;34:5;
42:8;94:13;107:25;
108:15
stipulated (1)
65:20
stop (2)
10:14;24:5
storage (3)
60:15;61:23;64:25
stored (2)
12:12;64:4
subject (5)
66:8;68:5,14;69:19;
107:7
submissions (1)
52:23
submit (7)
16:11;30:2,19;51:6;
85:17;94:18;107:17
submitted (17)
9:19;10:2;18:1;
27:25;49:17;61:1;
62:2;72:20;77:21;
81:17;89:10;90:10;
92:2,19;94:10,13;
108:6
Subpoena (19)
8:12,12,19;9:2,5;
11:15;49:25;57:20;
58:17,18;59:7;62:11,
12,24;65:14,21;92:21,
25;93:5
subpoenaed (1)
50:4
subscriber (4)
16:9;29:12;38:24;
97:12
substantive (1)
107:11
suggest (1)
34:11
summary (6)
10:21;40:13;43:19;
46:11;83:11;86:2
support (2)
7:12,21
supporting (6)
53:9;91:12,17,23;
92:11,15
suppose (1)
16:19
supposed (1)
97:25
supposedly (1)
87:24
sure (12)
30:12;31:23;33:1,4;
39:25;40:18;42:21;
47:8;54:13;68:15;
71:16;95:23
sworn (1)
7:2
synopses (1)
12:17
system (7)
13:5;18:1;51:12;
60:24;61:3,4;80:14
testing (1)
55:13
theoretically (4)
14:12;17:3;35:14;
45:21
therefore (8)
49:18;58:8;61:3,11;
62:16;81:13;84:12;
92:12
Thereupon (13)
8:7;9:9;22:24;23:1;
58:13;65:25;74:4,18;
96:9,20,21;104:7;
105:10
thinking (1)
90:14
third (7)
20:7,23;21:15;
24:14;52:20;80:16;
86:18
third-from-the-bottom (1)
16:23
third-party (1)
99:11
tab (1)
though (6)
66:22
15:18;39:7;89:9;
tabbed (3)
90:19;94:9,11
66:21,25;68:3
thought (2)
table (1)
27:22;43:18
66:13
thousands (3)
talked (3)
61:5,5;64:11
50:10,14;53:15
three (9)
talking (15)
27:13;36:9;41:22;
18:17,18;42:16,16;
45:9;49:3;78:16;
43:24;46:8;47:17,18;
83:22;95:6,25
48:12;52:8;54:11;
three-page (2)
64:23;66:9,23;67:7
95:15;96:1
tape (22)
throughout (1)
30:3;51:1,6,11,25;
17:8
52:21;58:8;61:1,1;
62:16;64:2,24;74:8, tie (2)
39:19;57:25
13;83:25;84:1,3,7,14;
tied (1)
85:16,18,20
62:13
tapes (14)
timeframe (14)
51:7,8,13;60:12;
13:2;79:11,18;80:2,
61:21;62:25;63:14,
7;81:19,22;82:24;
18,20,21,23;64:3;
93:13,13;105:4,13;
76:6;84:20
106:11;108:9
TD (2)
timeframes (1)
54:18;67:10
106:15
telephone (1)
timeline (2)
24:23
105:16,22
tells (1)
times (2)
86:24
91:14;92:7
terms (1)
timing (1)
47:18
78:24
testified (3)
title (1)
7:3;17:9;37:13
85:9
testify (1)
titled (1)
8:2
15:8
testimony (9)
today (16)
15:21;20:17;21:13;
7:23,24;8:12,14,22;
37:10;38:14;41:16;
9:3;50:1;58:18;66:17;
68:15;105:23,25

(10) simply - today

September 9, 2014

101:5;102:14;104:3;
105:24;106:5,8;
107:15
today's (2)
79:1;100:16
took (1)
83:4
top (11)
29:20;43:15;44:8,
23;47:12;49:21;57:6;
68:13;73:5;97:7;99:7
topics (1)
8:22
towards (3)
33:13;36:24;75:10
trade (49)
15:20;16:15;26:9,
10;27:21;28:13;29:1;
42:9,16;44:18;45:4;
46:24;48:5;49:4,5;
50:9,25;51:20;53:3,
16;54:9,24;55:19;
57:6;64:5;65:12;66:8,
22;67:6,18;68:5,7,14,
17;69:7,19;70:3,23;
71:1;72:2,11;73:4;
74:7;80:22;90:6;92:9;
94:21;107:7;109:4
transmitted (6)
19:14,24;20:16,18;
39:15;41:2
transpired (2)
62:7;83:4
TransUnion (2)
35:22;101:4
try (1)
25:11
trying (2)
79:12;92:3
turn (4)
8:19,25;53:18;
66:23
two (42)
8:20;10:16,18,20;
21:5;32:11;36:1;
40:21;42:4;46:10,12,
20;48:9;50:21;54:8;
57:6;62:7,7;78:16,17,
19;79:17;82:12,21;
86:1;88:5,8,10,11,13,
18;89:10,23;92:1;
94:20;95:4,5,22;96:6;
98:12;99:16,18
two-minute (1)
73:25
two-page (1)
29:18
type (11)
25:25;29:24;36:13;
60:14;61:4,12;63:21;
83:3;84:14;91:5;97:2
types (1)
63:7
Min-U-Script
typesetting (2)
16:5,11
typical (1)
60:18
typing (1)
18:13
upon (1)
12:22
U
Ultimately (5)
20:4;31:5;44:17,24;
45:13
unable (2)
19:22;100:8
under (12)
32:16;33:12,13,19;
34:5;77:15;98:3;
99:24;107:16,20;
108:7,25
underneath (4)
54:18;67:10;85:9;
98:4
understood (2)
19:3;37:10
Universal (3)
9:21;29:10,23
Unless (2)
29:5;73:15
unlikely (1)
63:8
up (7)
18:13,18;81:6;
93:13;105:5;106:12;
107:16
up- (1)
13:25
update (19)
13:6;22:19,20;28:5;
30:1;45:13;50:5;51:2;
55:6;57:25;62:13,25;
70:9;71:10;72:14;
74:10;86:22;89:22;
92:5
updated (32)
14:1,4;23:12;24:4,
14,15;27:21;29:5,17;
44:18;45:21;46:1;
50:19,21;51:7;53:2,4,
7,9,16;55:24;56:1,16;
58:7;63:5,6;72:10;
86:19;91:11;92:10;
101:20;106:2
updates (10)
10:23;23:16;28:25;
44:12;51:16;52:21;
53:6;70:14;73:13;
74:7
updating (2)
13:25;85:24
uploaded (3)
33:5;60:24;61:2
uploads (3)
17:22;51:25;74:8
50:8,21,24;53:3,14
website (1)
upon-conclusion-of-the-dispute (1)
97:16
13:9
week (1)
upper (4)
63:10
16:14,16;22:10;
Wells (130)
29:21
9:19,22;10:3,7;
use (2)
15:20;16:13;17:4,17;
49:9;89:1
18:23;19:9,11,15,23;
used (3)
20:7,14;21:17;22:1,8,
32:5;90:25,25
18;23:13;24:10,22;
user (4)
25:2,9,12,12;26:3,12,
95:7;97:8,9,10
23;27:3,10,25;28:6,
using (3)
12;29:12,14;31:7;
19:13;88:17;100:12
35:2;36:3;37:1,5;
usually (4)
38:24;39:15;40:14;
13:24;79:17;85:7;
41:3;42:14;43:2;
107:16
44:23;45:12;46:4,18;
48:3;51:18,20;52:7,8,
V
11,13,14,16;53:5;
54:8,16,17;56:22;
57:6;58:6;59:1,1;
validate (8)
60:7,7;62:2;63:22;
51:11;62:2;63:25;
64:5,19;66:8,22;67:6,
72:19;90:14;97:17;
9;68:5,14;69:3,8,19;
101:1,2
70:2,9,22;71:10,15,
value (1)
23;72:14;73:15,18;
21:4
76:18;79:20;81:14;
various (1)
83:21;84:9,12;85:19;
32:4
86:12;87:8;89:11,16,
vendor (2)
21;90:10;93:8;94:4,
12:20;28:23
19;97:9,11,21;99:16,
vendors (1)
18,22,23,24;100:1,13;
99:11
101:7,18,21;102:7;
Verification (7)
103:17,21;104:25;
9:17,25;12:25;15:9;
108:2,4;109:1,5
27:1;35:1;48:2
what's (5)
verified (5)
29:8;36:20;58:16;
14:4;22:17;48:3;
72:15;97:6
72:18;86:19
whenever (2)
verify (14)
45:25;89:1
19:17,22;27:3;
WHITE (67)
30:10;38:19;51:11;
11:9;14:16,18;
63:2;73:21;89:4,7,17;
19:18;27:22;30:14;
91:3;100:19;102:11
31:12,17,21;36:19,22;
verifying (1)
37:3,16;43:18,22;
90:17
44:2,6;51:23;52:4,6,
version (1)
10;53:22,25;54:3,6;
40:13
56:7,9,20;59:4,11,19;
66:24;74:2,21;75:5,7,
W
14,16;76:15;80:23;
83:16;84:25;85:2;
wait (2)
88:6;94:6,22,25;95:3,
18:16,17
9,14,19,25;96:4,13,
waive (1)
17,23;102:18;103:1,
109:13
16;104:2,10,20,23;
way (21)
105:7;106:17,23;
18:4;27:15;36:22;
109:10
44:17,25;45:10;51:7;
whose (1)
52:16,18,20;53:1,8,
50:14
10;54:13;66:7;71:8;
wish (1)
72:1;73:15;79:25;
24:21
94:4;103:17
within (9)
ways (5)

11:20;13:1,2;38:17;
42:12;57:5,22,22;
88:15
without (1)
51:18
WITNESS (1)
104:19
word (34)
16:15;18:14;19:13;
21:21;22:13;28:5,6,7;
29:3;44:22;45:22;
46:3;48:4;49:9;55:3,
9,11;69:22;70:6,10,
14;71:5,11;72:10;
73:13,13,14;78:6;
80:20;85:9;87:22;
105:17,21;106:9
words (2)
52:13;54:25
work (5)
7:13;51:9;60:22;
74:12;97:17
works (1)
45:10
workstation (1)
61:16
world (8)
14:13;21:23;22:1,7,
12,16;45:15;70:8
worry (1)
59:18
write (2)
25:25;75:24
written (5)
12:19,23;17:24;
58:25;60:5
wrong (3)
19:13;36:20;56:3
Y
year (5)
32:24;79:21,22;
80:6;105:5
yesterday's (1)
8:13
you-all (1)
31:17
yo-yo (1)
105:21
Z
zero (4)
33:22;43:4;83:1;
90:21
0
007 (6)
89:1,24,25,25;
90:11,25
016 (4)
(11) today's - 016

September 9, 2014

89:3,24;90:3,9
092 (1)
32:25
098 (1)
90:20
54:5,18;57:1,2,14;
58:1;62:13;68:6;
72:17;73:2;93:7,10,
24;94:7;103:3,11
16th (3)
58:8;62:6;103:7
17th (3)
1
39:14;41:1;102:15
18 (1)
1 (16)
98:25
8:11,19;58:17,19;
70:25;77:3;82:14,18; 180 (2)
77:12;78:21
83:20;85:8;86:16;
1-84 (1)
87:8;95:8,11,17;
77:16
99:25
1,000 (1)
2
51:19
1:18 (1)
2 (48)
109:19
9:16;11:13;12:1,3;
10 (22)
41:15;47:19;53:18,
15:5;16:1;25:22,24;
27:7;28:9;35:8,11,15,
18,20;54:5,18;56:25;
18;36:15;38:11;
57:7;66:5;67:20;
39:20;40:1;41:8,12;
69:16,17;70:19;73:2;
42:24;44:10,21,22;
87:3;91:18,24;93:7,
47:7,10;54:12;56:1;
10;94:11;103:23
58:23;60:2,4;61:24;
100 (2)
63:24;64:6;65:1;
33:1;63:3
70:25;71:21;86:17,
10th (1)
18;88:7;89:3,16;90:3,
39:12
9;94:16;100:18;
11 (35)
102:2;108:21
9:21;23:5,7,21;
26:11;27:16;28:1,11; 20 (5)
59:9;92:15;103:22;
29:2,13;33:5;44:25;
105:1,4
45:2,6;48:24;55:15,
2003 (1)
19,23,25;56:17,21;
100:1
66:5;67:16;69:4;70:3,
10,16,16,22;71:13,19; 2010 (1)
94:9
72:4,15;107:4;109:5
2012 (9)
11th (2)
77:3;79:25;80:1,16;
32:22;33:8
81:21;82:14,18;
12 (11)
93:19;98:13
10:4;39:9;40:6;
95:21,22;96:8,25;
2013 (17)
59:9;66:18;67:12,
97:7;98:22;99:2;
16;68:12;69:4;79:24;
106:18
80:12;92:16;98:25;
12th (1)
99:25;101:9;103:20,
40:24
22;105:5;106:12,19
13 (8)
33:17,19;80:15;
2014 (75)
96:18;99:3;101:9;
9:22;10:1,4,6;11:2;
21:25,25;22:11;28:5,
103:20;106:19
14 (3)
12;29:13;32:22,24;
55:19;67:4;105:5
33:5,8;35:4;39:9;
40:6,25;41:15;45:25;
14th (2)
47:19;48:19;53:24;
39:12;40:8
15 (1)
55:5,14,17,19;56:16,
18;57:2,14;58:1;
103:10
62:13;67:21;69:18;
150 (1)
70:3,10,17,19;71:18;
26:7
72:2,9,17,24;78:1;
158 (1)
79:15,23;80:10,10,11,
90:21
16 (19)
15;81:13;87:3;91:18,
24;92:25;93:5,7,25;
48:23,24;53:20;
Min-U-Script
94:3,7,11;101:10,13,
78:19
23;102:6;103:3,7,10,
10,11,23;106:12;
6
107:4
20th (1)
6 (6)
10:6
10:5;87:1,3,4;
92:11;93:11
3
6/06/2014 (1)
85:12
3 (13)
6/12/2014 (1)
9:20;29:9,10;33:11;
38:25
37:9,11;66:18;67:12, 60 (1)
21;68:12;69:17;94:9;
78:20
95:8
68 (3)
3/30/2014 (1)
77:18,22;82:6
99:10
30 (4)
7
13:2;78:1,19;
100:22
7 (21)
30-day (1)
10:9,15,16,19,20;
13:1
41:19,21;42:12;43:9;
30th (4)
44:9,24;45:7;46:7,12;
10:1;35:4;79:15;
48:9;83:10,15,17,18;
81:13
84:22;86:2
312,500 (3)
7/13/2013 (1)
82:9;93:16;98:7
97:25
3rd (1)
7/16/2014 (2)
22:11
73:3;93:12
4 (42)
8 (29)
9:24;11:2;28:5;
11:1,5,14;12:1,3;
34:23,25;35:7,12,16,
48:15,16;49:4;53:18,
18,25;37:9,12,23;
19,22,23;55:11;56:6,
38:1,15,18;39:4;44:1;
19,20,25;57:5;62:5;
45:25;48:23;53:23;
66:5;67:4;68:13;
55:5,17;56:16,18;
72:22,23;92:23;93:2,
70:17;71:18;72:2,9,
4,11;103:4
24;76:11,14;83:21;
89 (1)
85:19;92:25;93:6;
78:20
101:10,23,25;102:6;
103:10;107:4
9
4/11/2014 (1)
70:1
9 (5)
4th (13)
66:5,17;68:6,12;
11:10;27:18;28:12,
69:17
24;29:1;48:19;55:10,
14;58:6;62:5;93:4;
94:3;103:6
5
5 (17)
10:2;26:6;38:21,23;
39:3,17,24;40:6,11,
17,20,24;41:7,17;
81:24,25;82:3
512004209 (2)
28:14;54:20
(1)
29:15
59 (1)

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Equifax Pamela Smith Deposition

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Equifax Pamela Smith Deposition

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30(b)(6) Equifax (Pamela Smith)

Wells Fargo Bank, N.A. v.

30(b)(6) teleconference deposition of

INDEX TO EXHIBITS (Continued)

Equifax Report results,

Report of Credit Cards, Loans

(All original exhibits retained by Attorney Berman and

Examination by Mr. Berman

Examination by Ms. Spaulding White

Examination by Mr. Berman

Automated Consumer Dispute Verification

Automated Universal Data Form,

Automated Consumer Dispute Verification,

Automated Consumer Dispute Verification,

Dispute letter to Wells Fargo

Partial copy of Disclosure/Credit

Credit dispute response and/or

Credit report, dated 6/3/2014

Reinvestigation process results

REPORTER DISCLOSURE OF NO CONTRACT

I, G. Paige Alexander, Certified Court

D'Amico Gershwin, Inc.

30(b)(6) Equifax (Pamela Smith)

Wells Fargo Bank, N.A. v.

FIRM DISCLOSURE OF NO CONTRACT

I, Kelly D'Amico, do hereby disclose

KELLY D'AMICO, CEO

On behalf of the Plaintiff:

On behalf of the Defendants:

On behalf of the Deponent:

(Appearing via teleconference)

D'Amico Gershwin, Inc.

30(b)(6) Equifax (Pamela Smith)

Wells Fargo Bank, N.A. v.

the document request, have you seen this list of

A. Exhibit 8 is a disclosure, dated

March 30th, 2014, on behalf of

D'Amico Gershwin, Inc.

30(b)(6) Equifax (Pamela Smith)

Wells Fargo Bank, N.A. v.

to the disputed data furnishers, and within a 30-day

A. What Equifax reports is the information

getting the information, updated based on the response

information on this -- on Exhibit 2 was compiled or

D'Amico Gershwin, Inc.

30(b)(6) Equifax (Pamela Smith)

Wells Fargo Bank, N.A. v.

Q. It says Christine Nnadi?

getting the -- would be downloading -- and if I'm

submitted through the system by the agent -- I'm

responder name, that person that's filled in is the

D'Amico Gershwin, Inc.

30(b)(6) Equifax (Pamela Smith)

Wells Fargo Bank, N.A. v.

(Thereupon, marked for identification,

world, prior to this dispute or prior to Wells Fargo's

goes into the results, and what it states is that the

D'Amico Gershwin, Inc.

30(b)(6) Equifax (Pamela Smith)

Wells Fargo Bank, N.A. v.

case -- this was a foreclosure case, so the plaintiff

Consumer Dispute Verification, we were disputing the

of dispute, that is the status that was being

reason why it's notated on Exhibit 11 on that very