equifax pamela smith deposition

8/10/2019 Equifax Pamela Smith Deposition

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Wells Fargo Bank, N.A. v.Itzhak Benson, et al

30(b)(6) Equifax (Pamela SmiSeptember 9, 2

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, ) CASE NO.:

) 2009-CACE-62642 vs. ) ) ITZHAK BENSON, et al., ) ) Defendants. ) ________________________________)

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

1 INDEX TO EXAMINATION 2

3 Examination by Mr. Berman 7 4 Examination by Ms. Spaulding White 74

5 Examination by Mr. Berman 105

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8 INDEX TO EXHIBITS 9

10 Defendants' Description Marked/First Exhibit Identified 11

D-1 Subpoena 812

D-2 Automated Consumer Dispute Verification 913

D-3 Automated Universal Data Form, 914 Dated 4/11/2014 15 D-4 Automated Consumer Dispute Verification, 9 Dated 3/30/2014

16 D-5 Automated Consumer Dispute Verification, 917 Dated 6/12/2014 18 D-6 Dispute letter to Wells Fargo 9 Home Mortgage from19 dated 6/20/2014 20 D-7 ACIS printout 9 21 D-8 Partial copy of Disclosure/Credit 9 Report, dated 9/4/201422

D-9 Credit dispute response and/or 6523 credit report, dated 7/3/2013 24 D-10 Credit report, dated 6/3/2014 65 25 D-11 Reinvestigation process results 23

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1 INDEX TO EXHIBITS (Continued) 2

3 Plaintiff's Description Marked/First Exhibit Identified 4

P-12 Equifax Report results, 96 5 dated 7/18/2013 6 P-13 Report of Credit Cards, Loans 96

& Other debt of7 dated 3/30/2014

8 (All original exhibits retained by Attorney Berman an

9 no copies are attached hereto.) 10

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1 REPORTER DISCLOSURE OF NO CONTRACT 2

3 I, G. Paige Alexander, Certified Court Reporter, do hereby disclose pursuant to 4 Article 10.B of the Rules and Regulations of

the Board of Court Reporting of the Judicial 5 Council of Georgia that I am a Georgia Certified Court Reporter. D'Amico Gershwin/I 6 was contacted by the party taking the deposition to provide court reporting services 7 for this deposition; D'Amico Gershwin/I will not be taking this deposition under any 8 contract that is prohibited by O.C.G.A. 15-14-37(a) and (b) or Article 7C of the Board 9 and I am not disqualified for a relationship o interest under the provisions of O.C.G.A.10 9-11-28(c). There is no contract to provide reportin11 services between myself or any person with who I have a principal and agency relationship nor12 any attorney at law in this action, party to this action, party having a financial interest13 in this action, or agent for an attorney at la in this action, party to this action, or party14 having a financial interest in this action. Any and all financial arrangements beyond 15 my/D'Amico Gershwin's usual and customary rate have been disclosed and offered to all parties

16 This, the 4th day of December, 2014. 17

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19 ________________________________ G. PAIGE ALEXANDER, CCR-B-211520

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Min-U-Script® D'Amico Gershwin, Inc.

www.AtlantaCourtReporter.com

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1 FIRM DISCLOSURE OF NO CONTRACT 2

3 I, Kelly D'Amico, do hereby disclose pursuant to Article 10.B of the Rules and 4 Regulations of the Board of Court Reporting of the Judicial Council of Georgia that D'Amico 5 Gershwin, Inc. was contacted by the taking attorney to provide court reporting services 6 for this deposition and there is no contract that is prohibited by O.C.G.A. 15-14-37(a) and 7 (b) or Article 7C of the Rules and Regulations

of the Board for the taking of this deposition. 8 There is no contract to provide reporting services between D'Amico Gershwin, Inc. or any 9 person with whom D'Amico Gershwin, Inc. has a principal and agency relationship nor any10 attorney at law in this action, party to this action, party having a financial interest in11 this action, or agent for an attorney at law in this action, party to this action, or party12 having a financial interest in this action. Any and all financial arrangements beyond 13 D'Amico Gershwin's usual and customary rates have been disclosed and offered to all parties.14 This, the 4th day of December, 2014. 15

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17 KELLY D'AMICO, CEO D'AMICO GERSHWIN, INC.18

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1 APPEARANCES OF COUNSEL: 2

3 On behalf of the Plaintiff: (Appearing via teleconference) 4

LINDA SPAULDING WHITE 5 Attorney at Law Broad and Cassel 6 One Financial Plaza 100 S.E. 3rd Avenue 7 Suite 2700 Fort Lauderdale, Florida 33394 8 Phone: 954.764.7060 Fax: 954.761.8135 9 [email protected] 10

11 On behalf of the Defendants: 12 JEFFREY N. BERMAN Attorney at Law13 The Berman Law Firm 1111 Brickell Avenue14 Suite 2050 Miami, Florida 3313115 Phone: 305-371-8223 Fax: 305-371-8159

16 [email protected] 17

18 On behalf of the Deponent: 19 JASON F. ESTEVES Attorney at Law20 Equifax, Inc. 1550 Peachtree Street, NE21 Atlanta, Georgia 30309 Phone: 404-885-891022 [email protected] 23

24 Also present:(Appearing via teleconference)

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Page

1 PAMELA SMITH,

2 having been first duly sworn, was examined and

3 testified as follows:

4 EXAMINATION

5 BY MR. BERMAN:

6 Q. Can you state your full name for the

7 record, please.

8 A. Pamela Smith.

9 Q. And where are you employed?

10 A. Equifax Information Services, LLC.

11 Q. And your position there?

12 A. Legal support associate.

13 Q. So you work in the legal department, in

14 the in-house legal department?

15 A. Yes, I do.

16 Q. Are you a lawyer, a paralegal?

17 A. I am not.

18 Q. Are you like a legal assistant kind of

19 thing or more of like an information manager for the

20 legal department?

21 A. Legal support, where I produce documents.

22 Q. And are you aware that you're here

23 today -- or let me rephrase the question.

24 Are you here today as the corporate

25 representative of Equifax?

Page

1 A. Yes, I am.

2 Q. To testify on its behalf?

3 A. Yes.

4 Q. Because you understand a legal entity 5 can't speak, so you're here to speak for it?

6 A. That is correct.

7 (Thereupon, marked for identification,

8 Defendants' Exhibit D-1.)

9 BY MR. BERMAN:

10 Q. Okay. I'm going to show you a copy of

11 the document that we've marked as Exhibit 1, which

12 the Subpoena for the deposition today. The Subpoen

13 has yesterday's date, but we agreed to reschedule the

14 deposition for today; but otherwise, it's still in

15 effect.

16 Have you seen this document before?17 A. Yes, I have.

18 Q. And in particular, if you would, please,

19 turn to -- so Exhibit 1 to the Subpoena is the Notice

20 of Taking Deposition. There are two exhibits to the

21 Notice itself, Exhibit A and Exhibit B. Exhibit A is

22 a list of the topics that we may go into today.

23 Have you seen this list before?

24 A. Yes, I have.

25 Q. And if you turn to the page to Exhibit B,



(2) Pages 5





Page 9

1 the document request, have you seen this list of

2 documents sought to be produced through the Subpoena

3 before today?

4 A. Yes, I have.

5 Q. And in response to the Subpoena, your

6 company, through Jason, was gracious enough to produce

7 some records to us ahead of the deposition.

8 MR. BERMAN: I appreciate that.


10 Defendants' Exhibit Numbers D-2, D-3, D-4, D-5,

11 D-6, D-7, and D-8.)

12 BY MR. BERMAN:

13 Q. I just want to go through them, mark

14 them, and have you identify them by exhibit number and

15 just describe the document.

16 A. In regards to Exhibit Number 2, this is

17 the Automated Consumer Dispute Verification. This is

18 the electronic reinvestigation dispute; that it was

19 submitted to Wells Fargo on behalf of

20 Exhibit 3 is an AUD, which is an

21 Automated Universal Data Form. It is dated April 11,

22 2014, and it was generated from Wells Fargo Home

23 Mortgage, on behalf of

24 Exhibit 4 is an ACDV, which is the

25 Automated Consumer Dispute Verification. It is dated

Page 10

1 March 30th, 2014, on behalf of

2 Exhibit 5 is another ACDV, submitted to

3 Equifax, on behalf of from Wells Fargo

4 Home Mortgage, and it is dated June 12, 2014. 5 Exhibit 6 appears to be a dispute letter,

6 dated June 20th, 2014, from a in

7 regards to a dispute at Wells Fargo Home Mortgage

8 account.

9 Exhibit 7 is the ACIS printout, and the

10 ACIS printout provides the results of the

11 investigation, the actions taken by each agent, and

12 also how the credit file appeared after the

13 reinvestigation was completed.

14 Q. And let me just stop you for one second.

15 And that's Exhibit 7, the ACIS report.

16 We've included in Exhibit 7 the last two pages as a17 separate -- what appears to be a separate document.

18 Can you describe that, the last two pages of Exhibit

19 7?

20 A. In regards to Exhibit 7 and the last two

21 pages, which is the maintenance sheet summary, it

22 outlines all of the actions that were taken by the

23 agents, any updates or deletions that were made per

24 their data furnisher's request or by Equifax.

25 Q. Okay.

Page

1 A. Exhibit 8 is a disclosure, dated

2 September 4, 2014, on behalf of

3 And those are all of the documents I have

4 in front of me.

5 Q. And Exhibit 8 is -- for a layman, it's a

6 credit report?


8 Q. Okay.

9 MS. SPAULDING WHITE: That's the one

10 dated September 4th?

11 MR. BERMAN: Yes.

12 BY MR. BERMAN:

13 Q. So we've just gone through Exhibits 2

14 through 8. Did you compile these documents in an

15 effort to comply with the Subpoena, you personally?

16 A. I am not the agent that, or the

17 representative that, compiled those documents.

18 Q. Okay. Who did?

19 A. To my understanding, it may have been one

20 of several other agents within our office.

21 Q. I see. Okay. Did you review them, or at

22 least glance at them, before they were produced to us

23 in advance of this deposition?

24 A. I was able to review them after they were

25 produced.

Page

1 Q. And for Exhibits 2 through 8, can you --

2 let me rephrase the question.

3 Are Exhibits 2 through 8 the business

4 records of Equifax? 5 A. Except for the dispute letter, yes, they

6 are.

7 Q. And were those records generated during

8 the normal course and scope of Equifax's business

9 operations?

10 A. Yes, they are.

11 Q. And are they kept and maintained and

12 stored by Equifax during its normal business

13 operations?

14 A. Yes, they are.

15 Q. Can you give me, as brief as possible --

16 this is a pretty open-ended question, but a brief 17 synopses of the process of a consumer disputing any

18 particular item in their credit report.

19 A. If a consumer contacts Equifax by written

20 correspondence, we have a vendor, or a contractor,

21 that goes through, opens the mail, review the

22 information and route it to a certain queue. And upo

23 receipt, the indicator receives the written

24 correspondence, review it, analyze it, and initiate a

25 dispute verification. It is then sent electronically



(3) Pages 9 -





Page 13

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

2 timeframe, the data furnishers have within 30 days to

3 respond back to Equifax. Once we receive the

4 response, the maintenance reviewer or either the

5 system will review all of the responses, either

6 update, modify, or delete the information, either

7 based on the data furnishers' request or based on

8 Equifax's internal policies.

9 Q. And the upon-conclusion-of-the-dispute

10 investigation is something sent to the consumer?

11 A. Yes. The revised copies of the results

12 of the investigation is provided to the consumer, if

13 the current address is being reported on the credit

14 file.

15 Q. And by the -- you said revised copy?

16 A. Yes.

17 Q. By that, you mean --

18 A. The results of the investigation or

19 revised copy, which means one and the same.

20 Q. Does it look like a credit report, with

21 the little notation at the beginning of it referencing

22 the dispute?

23 A. Yes, it does.

24 Q. And it usually says something like it's

25 been up- -- if it's a simple process of updating and

Page 14

1 getting the information, updated based on the response

2 from the information furnisher, it would just say

3 something like, you know, the information has been

4 verified and updated, and then here's your report, 5 here's the current information?

6 A. Yes, it would state something to that

7 degree.

8 Q. And that would be as reported by the

9 information furnisher?


11 Q. And I know everybody in the room and the

12 person on the phone knows this, but theoretically,

13 Equifax's role in the credit world is just to simply

14 be a middleman, an organizer and middleman, for

15 information, right, to get information --

16 MS. SPAULDING WHITE: Objection to form.17 MR. BERMAN: What?

18 MS. SPAULDING WHITE: I said objection to

19 form.

20 MR. BERMAN: Okay. I'll rephrase the

21 question.

22 BY MR. BERMAN:

23 Q. Does Equifax itself provide any

24 information on any of the loans that it reports in an

25 individual's credit report?

Page

1 A. What Equifax reports is the information

2 that has been reported in to us by the data

3 furnishers.

4 Q. I'm going to hand you what we've marked

5 as Exhibit 2, and we'll go into this document in a

6 little bit more detail than we did a few minutes ago.

7 You identified this document, I believe,

8 earlier as -- it's titled Automated Consumer Dispute

9 Verification; right?


11 Q. Who generates this document?

12 A. Equifax.

13 Q. And the purpose of this document is to do

14 what?

15 A. The purpose of this document is to

16 initiate or to forward the disputed information to a

17 disputed data furnisher on behalf of a consumer.

18 Q. And in this case, it appears as though

19 my client, disputed something in a

20 Wells Fargo Home Mortgage trade line in her credit

21 report. And if I understand your testimony, Equifax

22 would take that information, that dispute, and

23 generate this ACDV?


25 Q. So is it fair to say that all the

Page

1 information on this -- on Exhibit 2 was compiled or

2 put on this piece of paper, electronically, probably,

3 by an Equifax employee or agent?

4 A. Most of the information reports in the 5 light typesetting is the information of how the

6 account was being reported or the information being

7 reported at the time of dispute. It also provides the

8 Equifax control number, the date that it was created,

9 the subscriber code. It also provides the disputed

10 information, any FCRA relevant information that the

11 agent will submit. And the bold typesetting is the

12 responses that we received back from the disputed dat

13 furnisher; which, in this case, is Wells Fargo.

14 Q. And in the first, or in the upper,

15 portion of this document, there is the word "trade,"

16 upper left-hand corner?17 A. Yes.

18 Q. And below that are a bunch of black

19 boxes, I suppose identifying the information intende

20 to go to the right; the control number, the date that

21 the dispute was created, and things like that?

22 A. Yes.

23 Q. Do you see the third-from-the-bottom

24 responder name?

25 A. Yes, I do.



(4) Pages 13 -





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1 Q. It says Christine Nnadi?

2 A. Yes.

3 Q. Theoretically, or as far as you know, is

4 that the person from Wells Fargo who would have

5 provided the information that's in bold?

6 A. Yes.

7 Q. And the information in bold I'm referring

8 to is the information throughout the report, which you

9 just testified is information provided in response to

10 the ACDV by the information furnisher?


12 Q. Now, is this -- this ACDV form when it's

13 generated by Equifax to go out to the information

14 furnisher, is it done on a computer?

15 A. It is done electronically, yes.

16 Q. It is done electronically. And this

17 form -- how does that information get to Wells Fargo?

18 A. Electronically.

19 Q. Is that through e-OSCAR?

20 A. Yes, it is.

21 Q. Is it an Equifax employee that

22 electronically generates the ACDV and uploads it to

23 e-OSCAR?

24 A. If it is through written correspondence,

25 yes, it is, or by phone. If it's online, it is

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

2 sorry, by the consumer initiating the reinvestigation

3 process.

4 Q. Okay. And by the way, I forgot to ask 5 you some other background questions, or to give you

6 some sort of guidelines for the deposition. You seem

7 like a pro, but I'll go through it anyway.

8 Have you been deposed before?

9 A. Yes, I have.

10 Q. So you know the drill?

11 A. Yes.

12 Q. We're having a nice conversation, but we

13 have to remember that there's somebody typing up every

14 word, so we can't interrupt each other.

15 A. Yes.

16 Q. So if I interrupt you, you say, wait,17 wait; I was talking. You can do that. You can tell

18 me to shut up; I was talking. Because, otherwise, the

19 record is a mess.

20 I don't want you to guess, nor does Jason

21 want you to guess. So if you don't know the answer to

22 a question, if I ask you something that maybe seems

23 more Wells Fargo related and you know, you can answer.

24 If you don't know the answer, then just tell me you

25 don't know. Okay?

Page

1 A. Yes.

2 Q. If I ask a question and you answer it,

3 I'm going to assume you understood the question. If

4 you don't understand a question or it's a little

5 confusing to you, just ask me to -- we can have the

6 court reporter repeat the question; she can read it

7 out loud; or I can rephrase it. Okay?

8 A. Yes.

9 Q. So on the response side, on the Wells

10 Fargo side of the dispute, and how they process an

11 ACDV, do you know if a Wells Fargo employee would b

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

13 using the wrong word, tell me -- but would be gettin

14 the information transmitted through the ACDV, throug

15 e-OSCAR, if it would be a Wells Fargo employee th

16 would get it and then respond?

17 A. I cannot verify --

18 MS. SPAULDING WHITE: Object to the form;

19 lack of foundation.

20 BY MR. BERMAN:

21 Q. And the answer was?

22 A. I am unable to verify the process that is

23 handled through Wells Fargo once the information is

24 transmitted from Equifax.

25 Q. Okay. But as far as you understand, the

Page

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

2 person that provided the information?

3 A. Based on the information, yes.

4 Q. Ultimately? 5 A. Yes.

6 Q. Whether it passes from e-OSCAR through

7 some third party before it gets to Wells Fargo?

8 A. Yes.

9 Q. Okay. Is there anywhere in this ACDV

10 that deviates from your general description that item

11 in regular font, as opposed to bold, was information

12 that would have been generated by Equifax, and

13 conversely, that anything in bold would have been

14 generated or provided by, in this case, Wells Fargo?

15 A. There's no other information other than

16 what was transmitted and what was received.17 Q. And your understanding and your testimony

18 is that transmitted; that is, information by Equifax,

19 is not in bold, and anything that Equifax received

20 back from the information furnisher is in bold?


22 Q. Let's go to the -- there's no section

23 numbers, but if you go to the third grouping of -- on

24 the page, sort of in the middle of the page, on the

25 right it says narratives.



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1 A. Yes.

2 Q. The information in the first narrative

3 box: Removes compliance condition codes, account paid

4 for less than full value -- and the rest -- the other

5 two lines --

6 A. Yes.

7 Q. -- that's information that would have

8 been provided by Equifax?

9 A. That is the information that was

10 reporting on the credit file at the time of dispute.

11 Q. Ah, okay. And so, then, the response

12 below that -- or the information below that -- if I

13 understand your testimony, the information in bold,

14 starting with consumer disputes after resolution;

15 second line, foreclosure; third line, real estate

16 mortgage; fourth line, conventional mortgage, all that

17 information would have been provided by Wells Fargo?


19 Q. As its response to the ACDV?

20 A. Yes.

21 Q. Including the word "foreclosure"?


23 Q. So in a perfect world, we can look at

24 this ACDV and we can see that in and around the months

25 of June of 2014, perhaps early July 2014, in a perfect

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

2 response to this dispute, there was no reference to

3 foreclosure in the narratives of the credit report?

4 A. Based on the information I have here in 5 front of me, there was no indication of foreclosure

6 being reported.

7 Q. And, again, in a perfect world, we can

8 extrapolate from this ACDV that when Wells Fargo

9 responded, which it indicates right just in the area

10 in the upper left-hand corner near Miss Nnadi's name,

11 that they responded on July 3rd, 2014. When they

12 responded, it appears, in a perfect world, that they

13 responded, including in the narrative the word

14 "foreclosure"; is that right?

15 A. Yes.

16 Q. And so what, in a perfect world, should17 have happened is, based on this verified information

18 coming back from Wells Fargo, Equifax would then

19 update credit report, and at that

20 point, after the update, it would include in the

21 narrative "foreclosure"?


23 MR. BERMAN: Off the record.

24 (Thereupon, a recess was taken.)

25 / / /

Page


2 Defendants' Exhibit D-11.)

3 BY MR. BERMAN:

4 Q. I am now going to show you what has been

5 premarked as Exhibit 11 to your deposition. Can yo

6 identify this document for me?

7 A. Exhibit 11 is the results of the

8 reinvestigation process, initiated on behalf of the

9 plaintiff.

10 Q. When you say on behalf of the plaintiff,

11 you mean the results were added to the credit report

12 or the credit report was updated based on the

13 information furnished by the plaintiff, Wells Fargo?

14 A. This reflects the information that we

15 received from the data furnisher, and whether or not

16 there was any updates that may have been made or

17 deletions that may have made, it would have been

18 notated in the results column.

19 Q. So is there a narrative in there that

20 refers to the results of the investigation, in Exhibit

21 11?

22 A. Yes, there is. Maybe the second

23 paragraph from the bottom. It states, We have

24 researched the credit account and revised the accoun

25 number, excluding the last four digits. And then it

Page

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

2 additional information has been provided from the

3 original source, and it also states that the date

4 closed has been updated and a prior -- 5 Q. Can I -- let me stop you for one second.

6 Sorry.

7 A. Yes.

8 Q. This first sentence that you read, you

9 said the original source.

10 That would be Wells Fargo here?


12 Q. Okay. I'm sorry. Go on.

13 A. And the next sentence states that the

14 date closed has been updated. The third is the prior

15 paying history has been updated, and the status is

16 reporting correctly.17 The last payment date and date of last

18 activity are reporting correctly. And we also

19 advised, or informed, the consumer, or the plaintiff,

20 if you have any additional questions regarding this

21 item, at their discretion, they may wish to contact

22 Wells Fargo directly themselves; and provide the

23 address and telephone number if applicable.

24 Q. Just so there's no confusion when people

25 read this deposition later, the plaintiff in this



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Page 25

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

2 is actually Wells Fargo Bank, as the foreclosure

3 lender.

4 A. I apologize.

5 Q. That's okay. So if you want to refer to

6 the individual, the borrower, in this case, you can

7 just call her or the borrower, or

8 however you want to refer to her. But the plaintiff

9 is Wells Fargo.

10 A. I apologize.

11 Q. And for ease of reference, let's try to

12 just refer to Wells Fargo as Wells Fargo.

13 A. Okay.

14 Q. And so it says the status is reporting

15 correctly?

16 A. Yes, that is correct.

17 Q. And that statement is made because of the

18 response to the ACDV?

19 A. That is correct; there was no change --

20 Q. Which we went --

21 A. -- in the status.

22 Q. I'm sorry. Which is Exhibit 2, and we

23 went through that?

24 A. That is correct. On Exhibit 2 where it

25 has type and write (phonetic), it has M5. At the time

Page 26

1 of dispute, that is the status that was being

2 reported.

3 In response from Wells Fargo, they

4 continued to ask Equifax to report the M5 status. 5 Q. And M5 status means?

6 A. The M means mortgage and the 5 means that

7 the account is 150 days or more past due.

8 Q. And can you correlate -- actually, let's

9 go down to the actual trade line. Do you see a

10 reference to foreclosure in the trade line anywhere?

11 A. On Exhibit 11 -- bear with me for just a

12 moment. At the bottom where it has the Wells Fargo

13 Home Mortgage account information, on the last line

14 above the bold line across the page, it states

15 consumer disputes after resolution. Then it states

16 foreclosure; then it states real estate mortgage and17 then conventional mortgage.

18 Q. And that information, that all follows in

19 all caps, "additional information," on the line above,

20 everything you just read?

21 A. Yes, it does.

22 Q. And so all that additional information

23 that you just read was provided by Wells Fargo and no

24 one else?

25 A. According to the ACDV, or the Automated

Page

1 Consumer Dispute Verification, we were disputing th

2 status and the prior paying history on behalf of

3 as well as have Wells Fargo verify a

4 of the dates reporting; and that is the information

5 that we received back regarding that information.

6 Q. And you're looking at and referring to

7 Exhibit 2, the ACDV?

8 A. Yes, that's correct.

9 Q. And included in the bold, which is the

10 information provided by Wells Fargo in response to th

11 ACDV, is foreclosure; correct?

12 A. Yes.

13 Q. And the rest of the -- the other three

14 items included in the narratives and the foreclosure

15 reference, do you see where all those made their way

16 into the report, which has been marked as Exhibit 11

17 A. Yes.

18 Q. The July 4th -- and let me rephrase.

19 It's not a report. It's a response to a dispute.


21 Q. Showing the updated trade line.

22 MS. SPAULDING WHITE: I thought she said

23 it was the results of the reinvestigation.

24 A. This is the information that was

25 submitted back from Wells Fargo, and that is the

Page

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

2 last line.

3 BY MR. BERMAN:

4 Q. Is it possible that Equifax included the 5 word "foreclosure" in the update, dated July 4, 2014

6 for reasons other than Wells Fargo providing the wo

7 "foreclosure" -- including the word "foreclosure" in

8 their narrative response to the ACDV, that's marked

9 Exhibit 2?

10 A. Not that I am aware of.

11 Q. And so as of -- based on Exhibit 11, as

12 of July 4th, 2014, Equifax was reporting for the Wel

13 Fargo Home Mortgage trade line, for account numbe

14 starting with 512004209, that that loan was in

15 foreclosure, or had been foreclosed?

16 A. That is the information that was provided17 to Equifax.

18 Q. And that information, as of that date,

19 would have been included in the full credit report of

20 with Equifax?

21 A. Yes, at that time.

22 Q. So that if any potential lender were to

23 pull, or any vendor were to pull,

24 credit report on July 4th, and through such time that

25 any updates were done to credit repo



(7) Pages 25 -





Page 29

1 after July 4th, they would see in this trade line that

2 we're discussing on Exhibit 11 -- they would see the

3 word "foreclosure"?

4 A. Yes.

5 Q. Unless and until it got updated and that

6 information was removed?


8 Q. Okay. I'm showing you what's marked as

9 Exhibit 3. Can you identify this document for me?

10 A. Exhibit 3 is a Universal Data Form that

11 was sent electronically to Equifax. It is -- the

12 subscriber name is Wells Fargo Home Mortgage. It was

13 created on April 11, 2014. The responder is a Rachel

14 Howard. It is in regards to a Wells Fargo Home

15 Mortgage account, starting with and it

16 provides account information that they are requesting

17 to have updated on credit file.

18 Q. And this is a two-page document?

19 A. Yes, it is.

20 Q. And at the top of the first page, in the

21 upper left-hand corner are the initials AUD. What

22 does that stand for?

23 A. Automated Universal Data Form.

24 Q. And what is the purpose of this type of

25 document?

Page 30

1 A. This is an offline update that a data

2 furnisher can submit in on behalf of a single

3 consumer, outside of their regular, or normal, tape

4 reporting. 5 Q. And can you tell if this was done in

6 response to a dispute by

7 A. I cannot state whether or not this was in

8 response to a dispute by

9 Q. It could have been?

10 A. I'm stating I cannot verify whether or

11 not this is.

12 Q. But it's -- not that you know for sure,

13 but it's possible that it was?

14 MS. SPAULDING WHITE: Object to form.

15 BY MR. BERMAN:

16 Q. You can answer.17 A. Sometimes AUDs are generated based on the

18 consumer disputing information directly with the data

19 furnisher. And they would submit an AUD.

20 This is not generated based on a

21 reinvestigation process that's initiated by Equifax.

22 Q. This scenario that you just described?

23 A. Yes.

24 Q. Or are you saying that this document, you

25 can tell it wasn't a dispute with Equifax?

Page

1 A. An AUD is not generated based off of a

2 reinvestigation process. What is generated is an

3 ACDV.

4 Q. And then there's a response put on the

5 same AC- -- ultimately, on the same form. It's the

6 information being sent by Equifax, through e-OSCAR,

7 the furnisher -- here, Wells Fargo -- and the same

8 document comes back with additional information on it

9 A. Yes.

10 Q. That's the ACDV?

11 A. Yes, it is.


13 Can you please rephrase?

14 MR. BERMAN: No. She already answered

15 it. If it's a bad question, it won't come in

16 at the evidentiary hearing.

17 MS. SPAULDING WHITE: Are you-all still

18 there?

19 MR. BERMAN: Yes, we're here. Did you

20 hear my response to your objection?

21 MS. SPAULDING WHITE: Yes, but then

22 everything went silent, so I just wanted to

23 make sure.

24 MR. BERMAN: Yeah, if it's a bad

25 question -- I'm not going to rephrase it. If

Page

1 it's a bad question, then it won't come in at

2 the evidentiary hearing, the answer.

3 BY MR. BERMAN:

4 Q. Are you familiar with the various codes 5 that are used by Equifax and information furnishers?

6 A. Yes.

7 Q. So to code foreclosure or past due a

8 certain number of days, you would be able to look at

9 document and see if that code is on there?

10 A. Yes. But let me just emphasize, there

11 are many, many, metro two (phonetic) codes, and I d

12 not know all of them by heart.

13 Q. Okay.

14 A. But, yes, I am familiar with those.

15 Q. Okay. Now, on the second page of that

16 document, under authorization, it has an individual17 named Rachel Howard and her phone number, it loo

18 like, and then it says date created?

19 A. Yes.

20 Q. Can you tell what the date of this AUD

21 is?

22 A. April the 11th, 2014.

23 Q. And what is the rest of the -- what are

24 the rest of the digits following the year 2014,

25 starting with 092?



(8) Pages 29 -





Page 33

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

2 that is the time: The hour, the minute, and the

3 seconds.

4 Q. But you are absolutely sure that this AUD

5 was uploaded or sent on April 11, 2014?

6 A. Yes. What I can state for the record is

7 that it was created. I can't state exactly when it

8 was sent, but it was created on April the 11th, 2014.

9 Q. I got you. Do you know on the first page

10 of Exhibit --

11 A. 3.

12 Q. Thank you. On the first page, under --

13 towards the bottom, under account information, the

14 right-hand column about halfway down, it says account

15 status.

16 A. Yes.

17 Q. And there's a 13.

18 A. Yes.

19 Q. Do you know what 13 stands for, under

20 status?

21 A. I believe it stands for paid and closed

22 account with a zero balance.

23 Q. Can you tell from this AUD what

24 information was changed through it or just what the

25 new reported information is?

Page 34

1 A. I cannot state what information was

2 changed, only the information that was reported in to

3 us.

4 Q. A little bit down below the account 5 status, still on the right side under account

6 information, it says special comment code, AU.

7 Do you know what that stands for?

8 A. AU, to my understanding, stands for

9 account paid in full, paid for less than full balance.

10 Q. So some form of settlement was reached?

11 That code would suggest that some form of settlement

12 was reached between the borrower and the lender,

13 through which not the entire balance was paid, but

14 some portion was paid?

15 A. What I can state is based on that special

16 comment code is that it is stating that there was a17 balance that was paid in full, but it was paid for

18 less than the full balance.

19 Q. Okay.

20 A. And we cannot state whether or not it was

21 through a settlement agreement or what have you.

22 Q. Okay. Fair enough. I'm going to show

23 you what is marked as Exhibit 4. Can you identify

24 this document?

25 A. Yes, Exhibit 4 is an ACDV, Automated

Page

1 Consumer Dispute Verification Form. It is

2 sent/submitted to Equifax on behalf of -- from Wells

3 Fargo Home Mortgage. And the date that it was create

4 was March 30th, 2014, and the responder's name is

5 Rachel Howard. And it provides us with some accoun

6 information.

7 Q. How is this document, Exhibit 4,

8 different than the ACDV we marked as Exhibit 2? D

9 those documents come about as a result of the same

10 dispute process, or similar dispute process?

11 A. Well, an ACDV from Exhibit 2 and Exhibit

12 4 are pretty much one and the same. They're just in

13 different formats.

14 Q. Should Equifax, theoretically, have an

15 ACDV document in the form of Exhibit 2 for the ACD

16 that we see reflected in Exhibit 4?

17 A. Not necessarily. And the reason being is

18 that Exhibit 2 was initiated by Equifax. Exhibit 4

19 may have been initiated by another source.

20 Q. Interesting. Okay. So by another

21 source, do you mean it could have been a dispute wi

22 TransUnion or a dispute with Experian?

23 A. Yes.

24 Q. Okay. And you would get something like

25 what Exhibit 4 looks like in the normal course when a

Page

1 individual disputes information on one of the two

2 other major credit bureaus reports for them?

3 A. If Wells Fargo or the data furnisher

4 provides that information to the other credit 5 reporting agencies.

6 Q. I see. Is that because these ACDVs all

7 run through e-OSCAR?

8 A. Yes.

9 Q. And the three big players in the credit

10 reporting industry run e-OSCAR?

11 A. Yes.

12 Q. And so is it fair to say, then --

13 conversely, is it fair to generalize that the type of

14 ACDV in the form that we see that's marked as Exhib

15 2 would be an Equifax -- an ACDV originating throug

16 Equifax?17 A. That's correct.

18 Q. I see. Okay.


20 MR. BERMAN: What's wrong with the form,

21 just out of curiosity?

22 MS. SPAULDING WHITE: Well, the way you

23 ended the question, it may not be

24 objectionable. But I saw you going towards

25 information from other credit reporting



(9) Pages 33 -





Page 37

1 agencies or Wells Fargo.

2 MR. BERMAN: Okay.

3 MS. SPAULDING WHITE: But to the extent

4 that the question was asking and to that -- and

5 to those credit reporting agencies or Wells

6 Fargo, objection.

7 MR. BERMAN: Okay.

8 BY MR. BERMAN:

9 Q. Exhibit 4 looks a lot like Exhibit 3 in

10 that, if I understood your testimony as it relates to

11 Exhibit 3, you can't tell what -- let me rephrase.

12 On Exhibit 4, this ACDV, which you've

13 testified appears to be from a different credit

14 bureau, or through a different credit bureau, can you

15 see what information is being disputed?

16 MS. SPAULDING WHITE: Object to form;

17 lack of foundation.

18 BY MR. BERMAN:

19 Q. You can answer.

20 A. I'm sorry, can you restate the question

21 again, please?

22 Q. I will rephrase it. Can you tell from

23 Exhibit 4 what information was being disputed in that

24 ACDV by the individual, by

25 A. I cannot.

Page 38

1 Q. Can you tell from Exhibit 4 which credit

2 bureau initiated this ACDV?

3 A. I cannot.

4 Q. But you're fairly confident it was not 5 Equifax?

6 A. Based on the documents that I have

7 reviewed, it was not generated by Equifax.

8 Q. Okay. Which, again, explains why we

9 don't have a more detailed ACDV?

10 A. That's correct.

11 Q. Like Exhibit 2?

12 A. Yes.

13 Q. So it would really be beyond the scope of

14 your testimony here on behalf of Equifax to go into

15 the details of Exhibit 4?

16 A. I mean, I am able to answer questions17 regarding the information that's placed within Exhibit

18 4, but the scope of it and what generated that, I

19 would not be able to verify that.

20 Q. Let me show you what we have premarked as

21 Exhibit 5, and if we can just go through this briefly,

22 in a little more detail.

23 A. Exhibit 5 is another ACDV. The

24 subscriber is Wells Fargo Home Mortgage. It was

25 generated, or created, on 6/12/2014. The responder is

Page

1 Christine Nnadi. And it provides account history

2 regarding an account being held by

3 Q. And is this Exhibit 5, the ACDV, similar

4 to what we just discussed for Exhibit 4, the other

5 ACDV that you produced?

6 A. Yes, it is.

7 Q. Does it appear to you as though this ACDV

8 was not generated, or not initiated, by Equifax?

9 A. This was created on June 12, 2014. I

10 believe, according to the dispute letter that

11 has sent in, her letter was dated

12 June the 10th. Equifax received it June the 14th, and

13 her investigation was initiated and started on

14 June the 17th. So this was not in regards to a

15 reinvestigation that was transmitted to Wells Fargo b

16 Equifax.

17 Q. Does that ACDV, Exhibit 5 --

18 A. Yes.

19 Q. -- tie in to or is it related to the more

20 detailed form of ACDV that's Exhibit 2? Is that wha

21 you're saying, that they're related?

22 A. I am stating, according to the

23 information that I have here in front of me regarding

24 Exhibit 5 -- and if you don't mind.

25 Q. Sure. Of course.

Page

1 A. -- and Exhibit 2, these are not in

2 relation to the same reinvestigation initiated by

3 Equifax.

4 Q. I see. Okay. 5 A. As I mentioned, the date that the ACDV in

6 Exhibit 5 says it was created on June 12, 2014;

7 however, Equifax did not receive

8 dispute letter until June 14th.

9 Q. I see. Okay. I apologize for not

10 understanding that.

11 Now, the responder on Exhibit 5 --

12 A. Yes.

13 Q. -- the more summary version of the ACDV,

14 is that -- apparently, the person from Wells Fargo is

15 Christine Nnadi?

16 A. That is the name that's listed.17 Q. For Exhibit 5.

18 And, I'm sorry, but I want to make sure

19 the record is clear. Do you believe that this ACDV,

20 which is Exhibit 5, was initiated by Equifax or by on

21 of the other two bureaus?

22 A. What I can state is based on the

23 information and the documents that I have reviewed,

24 the date that Exhibit 5 was created was June 12th,

25 2014; however, Equifax's reinvestigation process on



(10) Pages 37 -





Page 41

1 behalf of did not start until June 17th.

2 So this was prior to the date that we transmitted the

3 dispute over to Wells Fargo.

4 Q. Are there situations where there is an

5 Equifax dispute through e-OSCAR that's generated by

6 Equifax that you would have something -- an ACDV form

7 that looks like Exhibit 5, rather than one that looks

8 like Exhibit 2?

9 A. To my understanding, if Equifax initiates

10 a reinvestigation process, it would be in the

11 format -- the ACDV would be in the format of Exhibit

12 2.

13 Q. So based on the format and based on the

14 date in relation to the date that Equifax received

15 June 10, 2014 dispute letter, is it

16 your testimony that the ACDV that's been marked as

17 Exhibit 5 was not initiated by Equifax?

18 A. Yes.

19 Q. Okay. Let's go into Exhibit 7 in a

20 little bit more detail.

21 A. Exhibit 7 is the -- what we call the ACIS

22 printout. That's A-C-I-S. It consists of three

23 parts. The first part consists of how the credit file

24 looked after the reinvestigation process had been

25 completed. The other section provides the results, or

Page 42

1 the comments, that we provided to the consumer, and it

2 also provides the actions taken by the Equifax agents.

3 Q. That other part you're referring to is

4 the last two pages? 5 A. Yes.

6 Q. One of the issues in this lawsuit, I

7 guess the only -- let me rephrase that.

8 One of the issues still lingering in this

9 lawsuit is how -- obviously, is how this trade line is

10 being reported to Equifax and to other major credit

11 bureaus.

12 Can you tell me within Exhibit 7 if you

13 see any information relating to foreclosure?

14 A. On the Wells Fargo Home Mortgage account?

15 Q. Correct, on the account that we've been

16 talking about, the trade line we've been talking17 about.

18 A. May I review the ACDV just so that I --

19 Q. Oh, of course.

20 A. -- have the correct --

21 Q. Sure.

22 A. -- account number, please?

23 Q. Absolutely. This one, the detailed one,

24 Exhibit 2?

25 A. Yes. Thank you.

Page

1 Q. Yes.

2 A. In regards to the disputed Wells Fargo

3 Home Mortgage account, at the time the investigatio

4 was completed, it was reporting an M5 status, a zero

5 balance. It indicates the consumer disputes after

6 resolution, foreclosure, real estate mortgage and

7 conventional mortgage.

8 Q. Are you looking at the fourth page of

9 Exhibit 7?

10 A. Yes, I am.

11 Q. It's not paginated, but counting the

12 pages, it's page four?

13 A. Yes.

14 Q. And it's the first complete entry on the

15 top of that page?

16 A. Yes, it is.

17 Q. Okay. And --

18 MS. SPAULDING WHITE: Jeff, I thought you

19 did the maintenance sheet summary as part of

20 this exhibit.

21 MR. BERMAN: I did.

22 MS. SPAULDING WHITE: It's not just four

23 pages; is that correct?

24 MR. BERMAN: No. I'm talking about the

25 fact that she counted four pages into the

Page

1 document, which is how she knows it's page 4.

2 MS. SPAULDING WHITE: You stated the

3 exhibit is four pages.

4 MR. BERMAN: Then I made a mistake. The 5 exhibit is quite a bit longer than four pages.

6 MS. SPAULDING WHITE: Okay.

7 BY MR. BERMAN:

8 Q. So this top line of the fourth page of

9 Exhibit 7 reflects the final result of the ACDV marke

10 as Exhibit 2?

11 A. It reflects how the account was being

12 reported. Whether or not there was any updates or

13 deletions made, it reports how the account will appea

14 on credit file at the time the

15 reinvestigation process was closed.

16 Q. So it's an internal look at the data that17 will ultimately make its way into the -- what will be

18 the updated credit report for that trade line?

19 A. Yes, at that time, yes.

20 Q. And so the data that you see being

21 provided in bold on Exhibit 2 on the ACDV marked a

22 Exhibit 2 which includes the word "foreclosure" in

23 bold provided by Wells Fargo, is reflected on the top

24 of the fourth page of Exhibit 7, and ultimately made

25 its way into what we discussed earlier, Exhibit 11,



(11) Pages 41 -





Page 45

1 which is a response to Mrs. to the dispute.

2 That's the end of the dispute process, Exhibit 11?


4 Q. And it gives you a snapshot of the trade

5 line as of that date for that loan?

6 A. Yes, Exhibit 11 is the end results, as

7 well as Exhibit 7 is the end results.

8 Q. And so you can see the process through

9 these three exhibits. You can see how all this

10 information works its way through e-OSCAR, out from

11 Equifax, and then back from the information furnisher,

12 or Wells Fargo here, back to Equifax and then

13 ultimately, reported through an update?

14 A. To the consumer, that is correct.

15 Q. To the consumer. And to the world?

16 A. Yes.

17 Q. Or to whoever is looking at these credit

18 reports?

19 A. Yes, at that given time.

20 Q. And until such time as that report was

21 then updated, for whatever reason, theoretically, the

22 word "foreclosure" would be included in the narrative

23 of that report?

24 A. Yes, it would.

25 Q. From July 4, 2014, onward, until whenever

Page 46

1 it was updated?


3 Q. And that's because -- that word would

4 appear because Wells Fargo indicated it should appear 5 there?

6 A. Based on the response we received, yes.

7 Q. Do you see any other entries in Exhibit 7

8 relating to this same loan that we've been talking

9 about this morning?

10 A. In the last two pages, which is

11 identified as the maintenance sheet summary --

12 Q. The last two pages of Exhibit 7?

13 A. Yes.

14 Q. Which is actually in a landscape format,

15 rather than portrait?

16 A. That is correct.17 Q. Okay.

18 A. -- it identifies the disputed Wells Fargo

19 Home Mortgage account.

20 Q. On the first of those two last pages or

21 the second one?

22 A. On the second.

23 Q. This shows -- rather than showing what

24 this trade line will look like, this shows sort of the

25 back-of-the-house investigation notes for this ACDV?

Page

1 A. What it shows is how the account appeared

2 at the time of dispute. It also demonstrates, or

3 reflects, the information received back. It also

4 reflects the agent and the date that the information

5 was initiated, as well as completed, and any commen

6 that we provided to the consumer on

7 Q. Let's go back to Exhibit 2 for just a

8 minute. I want to make sure that we are clear.

9 If you look at in the narrative section,

10 in the middle on the right of Exhibit 2 --

11 A. Yes.

12 Q. -- the top narrative portion is not in

13 bold, and that's what was on the narrative section of

14 the report before this dispute, or at the time of this

15 dispute?


17 Q. And we keep talking about this dispute,

18 in general terms. What we're talking about is the

19 dispute started by June 10, 2014

20 letter; right?


22 Q. And does the narrative section, not in

23 bold, which is the information that was already on th

24 report at the time include foreclosure?

25 A. It does not.

Page

1 Q. Is it fair to say, then, that through

2 this dispute process and the verification, the

3 verified information obtained by Wells Fargo in

4 response to the dispute, in effect, added the word 5 "foreclosure" to the narrative of this trade line?

6 A. What I can state is that the response we

7 received back from the data furnisher does indicate

8 foreclosure.

9 Q. Other than the two sections of Exhibit 7

10 that we've gone through, do you see any other areas

11 where there is information about this loan that we're

12 talking about this morning?

13 A. No.

14 Q. I will next show you what has been marked

15 as Exhibit 8. Can you identify this document, please

16 A. Exhibit 8 appears to be a partial copy of 17 a disclosure, or a credit file, or credit report.

18 Q. And it's dated?

19 A. September 4th, 2014, for

20 Q. You say a partial copy. Why do you say

21 that?

22 A. Well, this is the actual part of the --

23 credit file, which is page 4 of 16

24 through page 11 of 16. The others have a covershee

25 The additional pages are cover sheets and they are th



(12) Pages 45 -





Page 49

1 consumer's rights and things of that nature. And

2 that's the reason I stated partial copy.

3 Q. So the first three pages that are missing

4 from Exhibit 8 are not -- have no trade lines on them?

5 A. That is correct, no trade line

6 information.

7 Q. Have no credit reporting information?

8 A. That is correct. It's --

9 Q. So -- I don't want to use the word

10 "filler," but what we have in front of you, which is

11 what was produced by Equifax, is the meat of the

12 report?

13 A. This is the actual credit history of

14

15 Q. And can you tell me how this report came

16 about or why it was generated?

17 A. I believe there was a request submitted

18 to Equifax and, therefore, this disclosure, or credit

19 report, was generated.

20 Q. Do you know who made the request?

21 A. I cannot remember, right off the top of

22 my head, because I was not the agent that received the

23 request.

24 Q. Do you believe that this report was

25 generated in response to the Subpoena calling for your

Page 50

1 deposition today?

2 A. Yes, I do believe that.

3 Q. Is that Equifax's ordinary practice when

4 they are subpoenaed for document production and/or for 5 a deposition, that they will do an update report?

6 A. Yes. We will print a copy of the credit

7 file as it appears as of the date of request.

8 Q. Explain to me the different ways through

9 which information can change on a particular trade

10 line. We've already talked about the fact that you

11 could have an ACDV --

12 A. Yes.

13 Q. -- which is a dispute that originates

14 with the individual whose report it is, and we talked

15 in length about that process. You explained to me

16 through our discussion over some of the other exhibits17 that you could have an AUD, which is just a thing that

18 comes -- something that comes more information,

19 updated information, that comes from the information

20 furnisher, for one reason or another.

21 Other than those two ways to get updated

22 information into a credit report or to change the

23 information in a credit report, are there any other

24 ways that that could happen?

25 A. In regards to a trade line, there is the

Page

1 tape reporting, where a credit or a data furnisher

2 will update all of their records at one time with

3 Equifax.

4 Q. Like in a bulk manner?

5 A. Yes. They may have that information on a

6 tape; they submit that information to Equifax; we run

7 our tapes and the information is updated that way.

8 Q. Describe these tapes for me, please.

9 A. Well, I apologize, Jeff, I do not work on

10 that side. I'm not specialized in that area, so I

11 cannot validate or verify how that tape reporting

12 information is loaded into the system.

13 Q. But it's referred to as tapes?

14 A. Yes, it is.

15 Q. And you understand that to be bulk

16 updates?

17 A. Yes.

18 Q. Like Wells Fargo dumps -- without regard

19 to the number, but let's say, for example, 1,000

20 individuals' trade lines from Wells Fargo get loaded

21 in one shot, or however many it is?

22 A. Yes, that is correct.


24 BY MR. BERMAN:

25 Q. How often do the tape uploads happen?

Page

1 A. Well, it depends --

2 Q. I'm sorry. Let me -- I'm sorry to cut

3 you off. Let me rephrase the question.

4 MS. SPAULDING WHITE: Object to form. 5 MR. BERMAN: I'm rephrasing it.

6 MS. SPAULDING WHITE: Are you making this

7 specific for Wells Fargo or just in general?

8 MR. BERMAN: I'm talking about Wells

9 Fargo.

10 MS. SPAULDING WHITE: Well, you didn't

11 say Wells Fargo.

12 MR. BERMAN: Okay. Every question will

13 now be prefaced with the words "for Wells

14 Fargo" -- the phrase "for Wells Fargo." Okay?

15 BY MR. BERMAN:

16 Q. So for Wells Fargo, the only other way17 besides an ACDV; that is, a dispute generated throug

18 Equifax by the consumer, or the AUD, which is, one w

19 or another, information coming on their own from th

20 information furnisher, the third way is for -- what

21 you're referring to as tape updates?

22 A. Yes.

23 Q. Which are bulk submissions of multiple

24 individuals' reports.




(13) Pages 49 -





Page 53

1 Q. Is there a fourth or fifth way that a

2 credit report could be updated?

3 A. There are other ways that a trade line

4 may be possibly updated. It could be that an agent or

5 representative of Wells Fargo may contact Equifax's

6 business department and request updates. That's very

7 rare, that creditors will have information updated

8 that way. Or sometimes consumers may provide

9 supporting documents to have information updated.

10 Q. And the fourth way that you described,

11 would that be by phone or email, in that sort of

12 informal kind of setting?

13 A. It could possibly be in that form.

14 Q. Do you know which of the five ways we've

15 talked about this morning that information could be

16 updated in one's credit report for a particular trade

17 line? Do you know -- let me actually ask you first to

18 turn to in Exhibit 8 to page 10. So we're on page 10

19 of Exhibit 8.

20 A. Okay. Page 10 of 16?

21 Q. Correct.

22 MS. SPAULDING WHITE: What is Exhibit 8?

23 MR. BERMAN: Exhibit 8 the September 4,

24 2014 Equifax report.

25 MS. SPAULDING WHITE: Thank you.

Page 54

1 BY MR. BERMAN:

2 Q. Can you --

3 MS. SPAULDING WHITE: And what page are

4 you on? 5 MR. BERMAN: We are on page 10 of 16.

6 MS. SPAULDING WHITE: Okay. Thank you.

7 BY MR. BERMAN:

8 Q. It appears there are two Wells Fargo Home

9 Mortgage trade lines on this page. Can you identify

10 which -- can you tell which one is the one that we've

11 been talking about this morning?

12 A. If I can look at Exhibit 2?

13 Q. Sure. And by the way, you can look at

14 any of these exhibits at any point you'd like just to

15 sort of get your bearings.

16 A. Thank you. The Wells Fargo Home Mortgage17 account that's reporting as the first Wells Fargo Home

18 Mortgage account on page 10 of 16 underneath the TD

19 Auto Finance account.

20 Q. Account Number 512004209?

21 A. Yes, it is.

22 Q. And whatever follows?

23 A. Yes.

24 Q. In this report, on this trade line that

25 you've just identified, following the words

Page

1 "additional information" in the narrative, do you see

2 any references to foreclosure?

3 A. There is no reference to the word

4 "foreclosure" being reported.

5 Q. So the September 4, 2014 report reflects

6 an update or different information than the previous

7 report, at least the previous report that was provided

8 to us through Equifax -- or by Equifax, insofar as it

9 removes the word "foreclosure"?

10 A. I can state that as of September 4th, in

11 Exhibit 8, the word "foreclosure" is not being

12 reported.

13 Q. And do you also notice -- testing your

14 memory, or if you want to look at the July 4th, 2014

15 report, Exhibit 11 -- I can put it in front of you --

16 that also another change, apparent change, is that the

17 reference in the September 4, 2014 report to account

18 paid for less than full balance was added, because it

19 was not in Exhibit 11, the September 14, 2014 trade

20 line?

21 A. I can state that it was not being

22 reported at that time.

23 Q. Can you tell from Exhibit 11 itself how

24 and why specifically this information was updated?

25 A. Well, in Exhibit 11, this information was

Page

1 updated based on the response from Exhibit 2, the ACDV

2 response that we received.

3 Q. I'm sorry. I meant -- I asked the wrong

4 question. 5 Same question with reference to Exhibit

6 8; that as compared --

7 MS. SPAULDING WHITE: What --

8 MR. BERMAN: Go ahead.

9 MS. SPAULDING WHITE: I'm sorry, I didn't

10 hear what you said.

11 MR. BERMAN: I will ask the question

12 again.

13 BY MR. BERMAN:

14 Q. Can you tell me specifically the manner

15 in which the information which we just identified as

16 being updated when comparing the July 4, 201417 document, labeled Exhibit 11, and comparing it to th

18 September 4, 2014 document, that's marked as Exhib

19 8?

20 MS. SPAULDING WHITE: 8.

21 A. In regards to Exhibit 11, the results of

22 the reporting of the Wells Fargo Home Mortgage accou

23 is in regards to the reinvestigation that was

24 initiated by Equifax.

25 From looking at Exhibit 8 on page 10 of



(14) Pages 53 -





Page 57

1 16, it appears that the items as of the date reported

2 is July 16, 2014, and this is after the

3 reinvestigation process by Equifax.

4 BY MR. BERMAN:

5 Q. So within Exhibit 8, on the first of the

6 two, the top Wells Fargo Home Mortgage trade line on

7 page 10 --

8 A. Yes.

9 Q. -- you just indicated -- oh, I see. On

10 the left side, second item on the left, items as of

11 date reported?

12 A. Yes.

13 Q. And so what you're saying is that as of

14 July 16, 2014, that you no longer have a reference to

15 foreclosure?


17 Q. But the doc- -- have I marked all the

18 documents that -- have I marked all the documents that

19 have been produced by Equifax in response to the

20 Subpoena as exhibits?

21 A. To my understanding, yes.

22 Q. And within those exhibits, within those

23 documents produced by Equifax, are there included an

24 AUD, an ACDV response, or any other documentation

25 which you can tie to an update done apparently on or

Page 58

1 around July 16, 2014?

2 A. There are none that have been located.

3 Q. There are none that have been located?

4 A. No. It's a possibility -- and I'm only 5 speculating -- that from the time this investigation

6 was completed on July the 4th and the last time Wells

7 Fargo updated their records with Equifax was on

8 July 16th; therefore, it could have been tape reported

9 and there would not be any manual hard copies to

10 produce.

11 MR. BERMAN: Okay. Let's go off the

12 record for a second.

13 (Thereupon, an off-the-record discussion

14 was held.)

15 BY MR. BERMAN:

16 Q. I'm going to show you again what's been17 marked as Exhibit 1, which is the Subpoena for the

18 deposition today. And the Subpoena has attached to it

19 an exhibit. I believe it's also Exhibit 1, which is

20 the Notice of Deposition.

21 A. Yes.

22 Q. Attached to that is Exhibit A to the

23 Notice and item number 2 basically asks for all

24 records of any kind that you have, electronic or

25 written, however they're kept, basically, that relates

Page

1 to any Wells Fargo Bank or Wells Fargo Home Mortgag

2 accounts that are in the name of Mrs.

3 And so --

4 MS. SPAULDING WHITE: And I want to go on

5 the record -- because you never responded to my

6 email -- that I objected to the time, the scope

7 of time in your Subpoena and that it should be

8 limited to the approval of the settlement on

9 June 20, 2013, forward --

10 MR. BERMAN: I'm not asking.

11 MS. SPAULDING WHITE: -- nothing prior --

12

13 MR. BERMAN: I understand. And although

14 I didn't say, yes, you're absolutely right, I

15 won't ask any questions, I don't necessarily

16 know if you're right, but I'm not asking

17 questions about anything before the date of the

18 settlement agreement. So don't worry.

19 MS. SPAULDING WHITE: Okay. Well, when

20 you're asking her to respond, it needs to be

21 limited to that time, from that day to current.

22 MR. BERMAN: Okay. If I ask a question

23 that offends you, you can object and we can

24 deal with it. But I don't think it's going to

25 be a problem.

Page

1 BY MR. BERMAN:

2 Q. So essentially, item 2 in the documents

3 that are -- I'm sorry, Exhibit B -- not Exhibit A --

4 Exhibit B, number 2 asks for all documents in 5 electronic -- all written and electronic documents an

6 records of any kind relating to any accounts with

7 Wells Fargo Bank, N.A., a/k/a Wells Fargo Home

8 Mortgage, in the name of Defendant

9 formerly And it indicates her date o

10 birth and has a reference to some external

11 information.

12 The tapes that you're describing, do you

13 understand them to be some kind of -- arcane as they

14 may be, some kind of computer data type of device o

15 storage method?

16 A. Yes.17 Q. So they would be electronic? Maybe not

18 electronic in the typical sense of these days with a

19 laptop or a hard drive or something, but electronic in

20 a very prehistoric form?

21 A. It's a possibility. And as I mentioned,

22 Jeff, I do not work in that area and I'm not

23 specialized in it to understand the format that's

24 received, how it's uploaded into the system. I can

25 only state that at one time, it was actually an actual



(15) Pages 57 -





Page 61

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

2 reel to reel and it downloaded, uploaded into the

3 system. And, therefore, we would not be able to -- I

4 mean, what type of system would you have to be able to

5 go and look at thousands and thousands of --

6 Q. Right.

7 A. -- consumers by any data furnisher to get

8 to this particular consumer and be able to find out

9 what was being reported or what they reported in to

10 us.

11 Therefore, we just do not provide that

12 type of information. We do provide all of the

13 documents that you have in front of you.

14 Q. In the modern electronic form?


16 Q. Like the computer at your workstation?

17 A. Yes.

18 Q. And the servers that Equifax has, the

19 modern servers?

20 A. Yes.

21 Q. So is it fair to say that the tapes

22 you're describing being in some form of electronic

23 storage would be responsive to document request number

24 2?

25 A. What I can state is that, once again,

Page 62

1 I'll not specialized in that area, so I cannot

2 validate how Wells Fargo submitted their information

3 in to us. I can just state that based on the

4 documents I have our investigation was completed 5 July the 4th. And according to the Exhibit 8, the

6 last date reported was July the 16th. So something

7 transpired between those two dates or on those two

8 dates.

9 Q. And you have no documents that you

10 could -- Equifax has no documents that it can produce

11 in response to the Subpoena -- or Equifax has produced

12 no documents in response to the Subpoena which could

13 be tied to the July 16, 2014 update?

14 A. That is what I'm stating, that there has

15 not been any documents. I can only speculate that it

16 may have been tape reported and, therefore, we would17 not have a hard copy or manual copy or a document to

18 produce.

19 Q. Okay. So it's basically a process of

20 elimination or deduction. I understand it's

21 definitely not something you know for certain, but

22 it's a sort of best guess based on all the information

23 you have and the information gathered in response to

24 the Subpoena that it's very likely, or most likely,

25 that this update was done through these tapes, as

Page

1 you're describing them?

2 A. I can only speculate. I cannot verify

3 100 percent --

4 Q. Okay.

5 A. -- how the information was updated.

6 Q. But if the information was updated

7 through the types of documents we were going throug

8 earlier, like the AUD, or it's unlikely, but another

9 dispute from the consumer through an ACDV

10 immediately -- like a week after the conclusion of th

11 investigation, there would be documents that you wou

12 be able to produce to me?

13 A. Yes.

14 Q. As opposed to the tapes; which I

15 understand I -- I have no equipment, nor would I

16 probably be able to find any in south Florida that

17 would be able to let me see the information on the

18 tapes?


20 Q. But nevertheless, those tapes are -- if

21 there are any tapes of the type you're describing with

22 information on it, furnished by Wel

23 Fargo, such tapes would be -- assuming they're out

24 there, would be responsive to request number 2; righ

25 A. I cannot validate that, but, yes.

Page

1 Q. But, again, assuming that there are --

2 that there's some tape out there somewhere in a

3 facility owned by Equifax, or where Equifax's tapes

4 are stored, if it has information on 5 it relating to a Wells Fargo trade line, then it would

6 be responsive to number 2?

7 MR. ESTEVES: Objection to form. She's

8 asked and answered.

9 A. Well, what I can state is that it would

10 not only include information, it woul

11 also include -- there are thousands of other --

12 BY MR. BERMAN:

13 Q. Of course.

14 A. -- consumers' information as well; which

15 I do not believe -- as I mentioned, I don't know if

16 you would even have the equipment to be able to go17 through and to go through all of the information to

18 come to information to see how i

19 was being reported by Wells Fargo.

20 Q. I understand. But just so the record is

21 clear -- and your lawyer is going to object again, but

22 I want you to answer.

23 If the data we're talking about is on a

24 tape somewhere at Equifax or in one of Equifax's

25 storage facilities, it would be responsive to request



(16) Pages 61 -





Page 69

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

2 So there's a reference to foreclosure,

3 and that is information provided by Wells Fargo to

4 Equifax as of March 11, 2013; right?

5 A. Yes, as of last date reported.

6 Q. There's no other reason why foreclosure

7 would be included in the narrative on this trade line,

8 other than Wells Fargo provided that information to

9 Equifax; correct?

10 A. I have no record of any other reason why

11 the account information would reflect foreclosure.

12 Q. And you're not aware of any other reason

13 either? Other than not having records, you're not

14 aware of any other reason; right?

15 A. I am not aware.

16 Q. So next, let's go back to Exhibit 10, and

17 again, we are on page 9; Exhibit 10 being the June 3,

18 2014 credit report. You have at the bottom of the

19 page, Wells Fargo Home Mortgage; the subject trade

20 line. And do you see a reference to foreclosure on

21 this credit report?

22 A. It does not reflect the word

23 "foreclosure."

24 Q. And the information is indicated that it

25 was provided on what date?

Page 70

1 A. Item as of date reported, 4/11/2014.

2 Q. So Wells Fargo is reporting to Equifax

3 for this trade line as of April 11, 2014 was such that

4 they were no longer referring to foreclosure in the 5 narrative.

6 A. There's no record of the word

7 "foreclosure."

8 Q. And so in a perfect world, that would be

9 because Wells Fargo did an update to the credit report

10 as of April 11, 2014, which did not include the word

11 "foreclosure" in the narrative?

12 A. Based on that information in front of me,

13 as of that date reported, they had not made any

14 additional updates, and the word "foreclosure" is not

15 being reported.

16 Q. Let's go to Exhibit 11. So Exhibit 11 is17 the July 4, 2014 response from Equifax to

18 Mrs. letting her know of the conclusions of

19 the investigation following her June 10, 2014 dispute

20 letter; is that correct?

21 A. Yes.

22 Q. And in Exhibit 11, do you see the Wells

23 Fargo trade line that's provided as part of the

24 response from Equifax?

25 A. Yes, on page 1 of 2 at the bottom.

Page

1 Q. And this trade line, just, again, it

2 reflects what would have been -- at the time, been

3 reported in her full credit report?

4 A. Yes.

5 Q. And does it include reference to the word

6 "foreclosure"?

7 A. Yes, it does.

8 Q. And would that have made its way back

9 into Mrs. credit report in any manner oth

10 than Wells Fargo providing an update which added bac

11 in the word "foreclosure"?

12 A. What I can state in regards to Exhibit

13 11, this was in regards to a reinvestigation process,

14 and based on the results or the response that we

15 received from Wells Fargo at that time.

16 Q. And we know for sure that this

17 foreclosure reference was added back in to

18 Mrs. credit report as of July 4, 2014, as

19 reflected in Exhibit 11, because the source or the

20 proof of that would be the document marked as Exhib

21 2, which is the detailed ACDV?

22 A. Yes, it is.

23 Q. In which we see that someone from Wells

24 Fargo in bold reports foreclosure?

25 A. Yes.

Page

1 Q. And there's no other way that foreclosure

2 made it into this trade line as of July 4, 2014;

3 right?

4 A. Exhibit 11 is based off of the response 5 to the ACDV.

6 Q. And so, then, anybody that pulled

7 Mrs. credit report that was considering

8 loaning her money or giving her some form of credit a

9 of July 4, 2014, until such time as the report was

10 updated, would have seen the word "foreclosure" in th

11 narrative of this trade line?

12 A. Yes.

13 Q. And do we know -- do we know when the

14 next credit report was or the next update from Wells

15 Fargo, following what's reflected in Exhibit 11?

16 A. I believe, based on the other documents17 that I reviewed, it's dated July 16, 2014, was another

18 date reported; and as I had verified, that I cannot

19 validate the method and how the account information

20 was submitted in to Equifax.

21 Q. And what you just described is you know

22 from looking at Exhibit 8; right?

23 A. From reviewing Exhibit 8.

24 Q. Which is the September 4, 2014 credit

25 report?



(18) Pages 69 -





Page 77

1 believe, as the -- I apologize.

2 Q. And does it reflect that the date closed

3 was February 1, 2012?

4 A. Yes, it does.

5 Q. Does it reflect how many days past due it

6 was being reported?

7 A. According to the payment history, it does

8 reflect some late payment history. As far as -- and,

9 I'm sorry, Linda. What was the other part of the

10 question?

11 Q. Does it anywhere reflect on there whether

12 it was 180 days past due, or is there any code on here

13 that would reflect that?

14 A. The only code that would reflect that it

15 had some late payment history would be under the

16 payment history 1-84 months; however, it does not

17 indicate that anywhere else that I can see.

18 Q. The account status 68, what does that

19 refer to?

20 A. The account status means the status of

21 the account at the time that the ACDV was submitted in

22 to us. And what it's stating, 68, I believe, stands

23 for the same thing as AU, account paid in full and

24 paid for less than full balance.

25 Q. Thank you. And this was as of -- what

Page 78

1 date; was it March 30, 2014?

2 A. Yes; according to the second page, that

3 is the date that it was created.

4 Q. So it's not being reported as a 5 foreclosure at that time?

6 A. The word "foreclosure" does not appear at

7 that time; however, in the payment history grid, the

8 letter H represents foreclosure.

9 Q. The letter H?

10 A. Yes. It would not --

11 Q. And what does that grid mean?

12 A. It reflects the late payment history for

13

14 Q. But how do you read that grid? Because

15 there's open marks. There's sixes, there's four,

16 three, two, one. How do you read this grid?17 A. Well, according to the standard metro two

18 format, the one just means that the account is

19 anywhere from 30 to 59 days past due. The two would

20 be 60 days to 89 days past due, and so forth. Once

21 you get to the number six, it means that it's 180 days

22 or more past due. And then there's the letter H,

23 which represents foreclosure. And that would --

24 Q. But how do you read this as far as timing

25 goes?

Page

1 A. It goes back from today's date that it

2 was created and it goes backwards. So the first

3 line --

4 Q. The (indecipherable) --

5 A. Yes, the first line --

6 Q. What do the open boxes represent?

7 A. There's no information being reported at

8 that time.

9 Q. And what does open box mean?

10 A. It just means there's nothing being

11 reported during that timeframe.

12 Q. Well, I'm just trying to figure out where

13 the H falls in with this reporting.

14 A. If you look at the date created, which

15 was March 30th, 2014, the agent is going back. The

16 cannot go forward, but they can only go back. And

17 usually starts maybe one or two months prior to that

18 timeframe.

19 So there's no information -- I can't

20 state when they started this on Wells Fargo's end. I

21 can just state that the first would be the first year,

22 the current year that we're in, and that would be

23 2014. The second open set of boxes would probably

24 generate 2013. The other set would probably genera

25 2012; and it would go all the way back.

Page

1 Q. So the H appears in the 2012?

2 A. Somewhere in or around that timeframe,

3 that's correct.

4 Q. Okay. 5 A. But it doesn't necessarily mean that it

6 represents the full year. It could possibly represent

7 the timeframe that the agent created this document a

8 go back.

9 So March -- this was created in March of

10 2014. They may start from February 2014 and go back

11 which that first line may cut off from February 2014

12 or February or March or January of 2013. It just

13 depends on what the agent was entering into the

14 system.

15 Q. So in 2014 and '13, it's not representing

16 foreclosure. In 2012, in the third box in, it17 represents foreclosure?

18 MR. BERMAN: Object to form.

19 A. The letter H represents foreclosure;

20 however, it does not mean that the word "foreclosure

21 will report on a consumer's credit file or on that

22 trade line. That will only be in the payment history.

23 BY MS. SPAULDING WHITE:

24 Q. This ACDV and the -- this -- what do you

25 call this?



(20) Pages 77 -





Page 81

1 A. It is an ACDV.

2 Q. I mean this box with boxes in it. What

3 is it called?

4 A. A payment history grid.

5 Q. Right. That payment history grid, does

6 that show up in a credit report?

7 A. The late payment history will reflect on

8 a consumer's credit report, yes.

9 Q. But is this grid shown on the credit

10 report?

11 A. Well, what I can state to you,

12 Miss Berman [sic], is that I do not have a credit

13 report dated for January 30th, 2014; therefore, I

14 cannot state whether or not the account, the Wells

15 Fargo Home Mortgage account, was reflecting the late

16 payment history. What I can state is what was

17 submitted in to us. They are stating that there were

18 late payment history and that there -- during this

19 certain timeframe, foreclosure, the account went into

20 foreclosure.

21 Q. In 2012?

22 A. Somewhere in or around that timeframe.

23 Q. I'm looking for the other ACDV here

24 that's Exhibit 5.

25 A. And I have Exhibit 5 in front of me.

Page 82

1 Q. Is it correct that this has the same

2 comment code, AU, that we just discussed as it relates

3 to Exhibit 5?

4 A. Yes, it does. 5 Q. And it also has the same account status,

6 68?

7 A. Yes, it does.

8 Q. Does it also reflect the high credit as

9 312,500?

10 A. Hold on just a moment.

11 Yes; they both do.

12 Q. And there are two different dates here.

13 There's a date closed and an activity date.

14 The date closed is February 1, 2012,

15 correct --

16 A. That's correct.17 Q. -- on each?

18 And the activity code is January 1, 2012;

19 correct?


21 Q. What is the difference between those two

22 dates?

23 A. Well, the date closed just simply means

24 the timeframe that the account was closed. There's a

25 possibility on a mortgage account, once an account

Page

1 reaches a zero balance, the account is automatically

2 considered as closed.

3 And activity date could be any type of

4 activity that took -- that transpired. It could be a

5 payment that was made; it could be that the account

6 went -- the status of the account changed. It could

7 be a number of things that generates that activity

8 date.

9 Q. Okay. Thank you. If we can go to

10 Exhibit 7 for a moment, please. It's the ACIS

11 summary; correct?

12 MR. BERMAN: Hold on.

13 A. If you can hold for just a moment,

14 please.

15 MR. BERMAN: Which exhibit again; 7?


17 Q. 7.

18 A. Yes, I have Exhibit 7 in front of me.

19 Q. On the pages that -- actually, on the

20 bottom of page 1 and on all the pages that follow,

21 including page 4, the Wells Fargo Home Mortgage, ove

22 on the right there are three letters, "AUI."

23 Can you tell me -- I don't know what that

24 stands for. Do you?

25 A. AUI stands for tape reporting.

Page

1 Q. Tape reporting?

2 A. Yes.

3 Q. Is that the kind of tape reporting that

4 we were just discussing off the record? 5 A. To my understanding, it is.

6 Q. So would this actually be a record of the

7 tape reporting that we were discussing off the record

8 earlier?

9 A. In regards to the Wells Fargo account?

10 Q. Yes.

11 A. It does have AUI listed alongside the

12 Wells Fargo Home Mortgage account, so, therefore,

13 will state that probably this is maybe in regards to

14 some type of tape reporting.

15 Q. So if you can look at all of the pages

16 for all of the creditors, there's the code AUI for17 every single creditor on here.

18 A. Yes.

19 Q. So is this maybe a record that is

20 generated as a result of those tapes?

21 A. Not necessarily. I can state that in

22 regards to this Exhibit 7, this is in regards to a

23 reinvestigation process. If I'm not mistaken,

24 Miss Berman, sometimes there's a --

25 MR. BERMAN: Miss White.



(21) Pages 81 -





Page 85

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


3 Q. Just call me Linda, like you were doing.

4 A. Okay, Linda; because that's my best

5 friend's name. I'm sorry. But thank you so much,

6 Linda.

7 Usually, there's an asterisk. If you

8 look just, say, for example, on page 1 for American

9 Express, underneath the word -- the title American

10 Express, it has DFD/DLA and it has --

11 Q. Right.

12 A. -- 6/06/2014, there is an asterisk out to

13 the side --

14 Q. Right.

15 A. -- if I'm not mistaken, Linda, that

16 indicates it was tape reported in to us. The AUI

17 indicates that these creditors submit information in

18 to us by tape reporting. It doesn't necessarily mean

19 that on page 4, this information came in from Wells

20 Fargo through a tape reporting; because the asterisk

21 is not there.

22 But as I had mentioned earlier, I am not

23 a specialist in that area, so I do not know all of the

24 processes that take place with the creditors updating

25 bulk information at one time.

Page 86

1 Q. Thank you. The last two pages of Exhibit

2 7, the maintenance sheet summary --

3 A. Yes.

4 Q. -- can you tell me what the comments 5 section means here?

6 A. Are you speaking of consumer comments?

7 Q. Is that what this -- yes, where it says

8 consumer comments; and then you have codes, and then

9 it comes down and there's the comments with the dash

10 and it says disputes current/previous account status?

11 A. I believe you are referring to the last

12 page in regards to the Wells Fargo Home Mortgage

13 account.

14 Q. Yes, I am.

15 A. The comments indicate the first line, and

16 the second line indicates dispute code number 1 and17 dispute code number 2, if you would review Exhibit

18 Number 2. Exhibit Number -- I'm sorry, the third line

19 where it has updated information verified by grantor,

20 that is the information that we received back. It

21 identifies IHA, identifies the agent, and it

22 identifies the date that the update was made.

23 The consumer comments that's listed below

24 maintenance action, it tells the information that we

25 provided to Mrs. at that time.

Page

1 Q. Thank you. Let's go back to Exhibit 6,

2 which is dispute letter, dated

3 June 10, 2014; Exhibit 6.

4 A. I have Exhibit 6 in front of me.

5 Q. What is it that Mrs. is

6 disputing as it relates to her credit report?

7 A. It appears from this letter, where it

8 states number 1, the Wells Fargo Mortgage account,

9 she's disputing the date of last payment as incorrect

10 and that the date of first delinquency is incorrect.

11 Q. She's not disputing the account status as

12 it relates to a foreclosure being reported, is she?

13 A. According to this letter, it does not

14 appear that she is disputing the status, nor the prior

15 paying history.

16 Q. And if you look at the document attached,

17 which it appears she enclosed a copy of her credit

18 report, is it reporting this as a foreclosure?

19 A. Bear with me just a moment.

20 Q. It's a little blurry, but I think you can

21 read it.

22 A. It does not appear that the word

23 "foreclosure" is being reported.

24 Q. So the sole reason she's supposedly filed

25 this dispute was as it related to the date of the last

Page

1 payment and the date of the first delinquency;

2 correct?


4 A. According to the letter, it does appear 5 that those are the two items that she is disputing.


7 Q. Then if we look at your Exhibit 2 for

8 your dispute one and dispute two --

9 A. Yes.

10 Q. -- the two disputes, how do we get from

11 what she is disputing in her letter, the two things,

12 date of last payment and date of first delinquency,

13 how is it that you code these disputes one and two,

14 based on her letter?

15 A. Well, here within the Equifax

16 organization, when we initiate a reinvestigation or17 dispute process, we only have the option of using

18 dispute code one or dispute code two. If there's any

19 additional information, we will place that in the FCR

20 relevant information field.

21 According to -- and I can only speculate

22 what the agent -- the reason they also disputed the

23 status and the prior paying history, is based on at

24 the time of dispute, the account was reporting an M5

25 status; however, it was not reporting any late paymen



(22) Pages 85 -





Page 89

1 history. And whenever we use dispute code 007, it

2 covers not only one, but it will cover both. And in

3 dispute code number 2, 016, we're asking any data

4 furnisher to verify all of the dates, not just the

5 date that the account was closed, but the date of last

6 payment, the date of first delinquency, the date that

7 it was open. We're asking them to verify all dates as

8 it indicates.

9 Q. So even though Mrs. is only

10 disputing two things, when you submitted this dispute

11 to Wells Fargo, you included all aspects, including

12 the account status, the date it was opened, the date

13 it's closed, all the information, not just the

14 information she was disputing; correct?

15 A. Well, I can state that based on the

16 information in Exhibit 2, we did ask Wells Fargo to

17 verify the status and the prior paying history. But

18 the agent did address Mrs. concerns

19 regarding the date of last payment and the date of

20 first delinquency.

21 Q. But you also requested Wells Fargo to

22 provide an update on all of the other line items on

23 your form, the dispute one and dispute two. All

24 that's covered in 007 and 016?

25 A. Well, 007, dispute code 007, only

Page 90

1 correlates with the status and the prior paying

2 history.

3 Dispute code number 2, which is 016,

4 relates to all of the dates: The date closed, the 5 date opened, all of those dates that may report on any

6 given trade line.

7 Q. But she was only disputing the date of

8 last payment and the date of first delinquency, which

9 would be covered by dispute 2, 016.

10 Why would the ACDV be submitted to Wells

11 Fargo, including dispute one, 007, when she was not

12 disputing that?

13 A. And I understand, Linda. I cannot

14 validate what the agent was thinking at that time. I

15 can just only state that the agent went ahead and

16 disputed the status and prior paying history, in17 addition to verifying the late -- the dates reporting

18 on the account.

19 Q. Even though the current code was as it's

20 in your narrative 098, account paid for less than full

21 balance, and also 158, closed or paid account, zero

22 balance?

23 A. If I understand you correctly, Linda,

24 you're asking me in regard to dispute number one where

25 we used a dispute code 007, why the agent used that?

Page

1 Q. Right.

2 A. Once again -- and I apologize, I cannot

3 verify what the agent was reading or looking at at

4 that time. I can just only state that according to

5 the type and rate field where it has an M5, the agent

6 may have felt the need to go ahead and dispute the

7 status and the prior paying history as well. But I

8 can only speculate.

9 Q. In response to one of Mr. Berman's

10 questions, you indicated that one of the other manne

11 in which a credit report would be changed or update

12 is if a consumer provided supporting documents

13 relating to their dispute --

14 A. Yes; there are times that --

15 Q. -- correct?

16 Did ever provide any

17 supporting documents relating to her dispute as it

18 relates to this June 10, 2014 dispute?

19 A. I apologize. I had over spoke and you

20 got cut off. Can you repeat the question again,

21 please?

22 Q. Yes. I'm sorry. Did Mrs. ever

23 provide any supporting documents relating to this

24 June 10, 2014 dispute?

25 A. There were no other additional documents

Page

1 that were filed, only the two pages that were

2 submitted in to Equifax.

3 Q. And I was just trying to confirm. You

4 said that would be another manner in which Equifax m 5 update its credit report, or another manner in which

6 they would investigate the status of the report?

7 A. Well, there have been times where

8 consumers have provided information in directly

9 themselves and information on a trade line or a publi

10 record item has been updated; however, according to

11 Exhibit 6, there were no supporting documents;

12 therefore, the agent initiated the reinvestigation

13 process.

14 Q. Did Mrs. ever provide any

15 supporting documents at any other time from June 20

16 2013, to the present as it relates to her credit17 report?

18 A. Not that I am aware of, no.

19 Q. If they had been submitted, would you

20 have those documents and would they have been produc

21 in response to the Subpoena?

22 A. Yes.

23 Q. And based on the Exhibit 8, which is the

24 credit report that you generated in response to the

25 Subpoena on September 4, 2014; correct?



(23) Pages 89 -





Page 93

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

2 to provide me with Exhibit 8.

3 Q. Certainly.

4 A. Exhibit 8, which is dated September 4th,

5 2014, is in response to the Subpoena request.

6 Q. So as of September 4, which report

7 reflects that as of June 16, 2014, on page 10, that

8 Wells Fargo is reporting this as closed or paid

9 account/zero balance; correct?

10 A. Yes. I can state on page 10 of 16 of

11 Exhibit 8 that item as of date reported is 6 --

12 7/16/2014. And that is the information that has been

13 reported since that timeframe up until the timeframe

14 this disclosure, or credit file or credit report, was

15 created.

16 Q. And it shows the high credit of 312,500?

17 A. Yes, it does.

18 Q. Does it show the date closed as

19 January 2012?

20 A. Yes, it does.

21 Q. Does it also reflect it as account paid

22 for less than full balance?

23 A. Yes, it does.

24 Q. And there's been no change since July 16,

25 2014; correct?

Page 94


2 A. What I can state is as of the date of

3 this document, which is September 4th, 2014, that is

4 the way the Wells Fargo Home Mortgage account was 5 being reported.


7 Q. Back to July 16, 2014?

8 A. Yes.

9 Q. And even though as of June 3, 2010, when

10 submitted her report -- her dispute

11 letter -- I'm sorry -- June 10, 2014, even though her

12 loan was not being reported as for foreclosure, she

13 still submitted a dispute; correct?


15 A. What I can state is that according to

16 Exhibit 2, at the time of dispute, the account was not17 being reported -- did not have a notation of

18 foreclosure; however, did submit a

19 dispute letter in to Equifax regarding her Wells Fargo

20 account in regards to two other items being reported

21 on that trade line.

22 MS. SPAULDING WHITE: The documents that

23 I sent to you, Jeff --

24 MR. BERMAN: Yes.

25 MS. SPAULDING WHITE: -- that were

Page

1 printed --

2 MR. BERMAN: Yes.

3 MS. SPAULDING WHITE: -- I would like to

4 mark two of them.

5 MR. BERMAN: Okay. I have two documents,

6 each three pages: Report results, this form

7 produced by Equifax, and a user reference, page

8 1 of 3, is how they both start.

9 MS. SPAULDING WHITE: Right. I would

10 like -- well, I would like to mark that as

11 Plaintiff's Exhibit 1.

12 MR. BERMAN: Do you want to go

13 sequential, or no?

14 MS. SPAULDING WHITE: Well, it's a

15 three-page document.

16 MR. BERMAN: Do you want to mark it --

17 instead of Plaintiff's 1, why don't you just

18 mark it as --

19 MS. SPAULDING WHITE: I am fine to do

20 that. We can do mark that as Exhibit -- what

21 are we, 12?

22 MR. BERMAN: 12, right. There's two of

23 them, so let me make sure I have this right, or

24 the order in which -- they look the same.

25 MS. SPAULDING WHITE: I sent you three

Page

1 documents. This was the only three-page

2 document, I think.

3 MR. BERMAN: Ah.

4 MS. SPAULDING WHITE: On the bottom it 5 shows httpsx4Equifax71813 (phonetic).

6 MR. BERMAN: Yeah, so I got two of the

7 same document.

8 So this will be 12.


10 Plaintiff's Exhibit P-12.)

11 MR. BERMAN: And then what was the other

12 one that you emailed me?

13 MS. SPAULDING WHITE: It's the

14 Credit Cards, Loans and Other Debt,

15 CreditScore.com. It's a document you sent me.

16 MR. BERMAN: Yes, okay.17 MS. SPAULDING WHITE: If we could mark

18 that Exhibit 13.

19 MR. BERMAN: Off the record.



22 Plaintiff's Exhibit P-13.)


24 Q. Miss Smith, could you please look at the

25 document we've identified as Exhibit 12?



(24) Pages 93 -





Page 97

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

2 Q. Do you know what type of report this is?

3 A. I do not. I'm not familiar with this

4 particular document.

5 Q. Is it exported from Equifax.com?

6 A. This is the -- that is what's stated at

7 the bottom and at the top of the page on Exhibit 12.

8 Q. And the user reference number A498306, do

9 you know if that is Wells Fargo's user number?

10 A. I do not know what the user ID number is.

11 But based on other information, as far as Wells Fargo

12 subscriber number with Equifax, they are not one and

13 the same.

14 Q. Do you know if the information that would

15 have been pulled from the Equifax.com electronic

16 service or on their website would be accurate?

17 A. I cannot validate that. I do not work --

18 I'm not specialized in that area as well.

19 Q. This appears to reflect the report

20 results of the account/trade line information for

21 Wells Fargo for loan number; is that

22 correct?

23 A. That is what it indicates.

24 Q. And the date on there that says

25 7/13/2013, do you know what that date is supposed to

Page 98

1 reference?

2 A. And where is that date located?

3 Q. Under the heading -- there are several

4 bold headings. The second heading underneath that. 5 A. It would probably be the reported date.

6 Q. And does it appear to also reflect the

7 high credit of 312,500?

8 A. Yes, it does.

9 Q. Does it reflect that the account is paid

10 and closed?

11 A. It does.

12 Q. The date on there that -- in the next two

13 columns over, the January 2012, is that the closed

14 date?

15 A. It appears to be, yes.

16 Q. And is there any narrative for this17 account?

18 A. The narrative states account paid for

19 less than full balance.

20 Q. Is there any code or narrative on here

21 reflecting foreclosure?

22 A. From reviewing Exhibit Number 12, I do

23 not show any reference to foreclosure being reported.

24 Q. And the date that this was pulled from

25 Equifax.com, is that July 18, 2013?

Page

1 A. That is the date that appears at the

2 bottom right-hand corner of Exhibit 12.

3 Q. Can we now look at Exhibit 13?

4 A. Yes.

5 Q. And this is a document from

6 CreditScore.com; correct?

7 A. It indicates that in the top right-hand

8 corner.

9 Q. And the report is dated as of what date?

10 A. Reported as of 3/30/2014.

11 Q. Do you know how third-party vendors

12 obtain Equifax's information on a particular debtor?

13 A. I do not.

14 Q. Does the information provided by Equifax

15 here reflect a date that it was opened?

16 A. Now, there are two Wells --

17 Q. If you look on --

18 A. There are two Wells --

19 Q. If you look on the far left, it says date

20 opened, and then you have the block for Equifax.

21 A. Yes, I see that.

22 Are we referring to the first Wells Fargo

23 account or the second Wells Fargo account? Becaus

24 the first Wells Fargo account indicates, under the

25 Equifax portion, a date opened of July 1, 2013 -- I'm

Page 1

1 sorry, 2003. On the second Wells Fargo Home Mortgag

2 account, there's not a date reporting. As a matter of

3 fact, there's no account history being reported at

4 all. 5 Q. So whatever account, that one is not even

6 being reported; correct?

7 A. According to this document, it's not

8 being reported by Equifax, or they were unable to

9 obtain any information regarding this account numbe

10 from Equifax.

11 Q. And if you look at the account number

12 using the Experian account -- do you see that?

13 A. On the second Wells Fargo account, yes, I

14 do.

15 Q. -- is that the account number, the loan

16 number, that we've been discussing in today's17 deposition?

18 A. If I can review Exhibit Number 2, I can

19 almost verify that for you.

20 It appears that it's the same account,

21 with the last four digits masked.

22 Q. So as of March 30, there doesn't appear

23 to be any reporting by Equifax for this loan, at least

24 through CreditScore.com; correct?

25 A. Well, what I can state is I cannot



(25) Pages 97 -





Page 101

1 validate the records for CreditScore.com. I can just

2 validate that, based on the information in front of

3 me, there's no history being reported by Equifax, nor

4 TransUnion, regarding the account that's been in

5 dispute today.

6 Q. Going through all the exhibits that we've

7 gone through to date, is it correct to say that Wells

8 Fargo, through Equifax, was not reporting this loan as

9 a foreclosure, at least from July 13, 2013, through

10 July 4, 2014?

11 A. Well, what I can state -- and I would

12 need to go back and review the documents. But what I

13 can recall, Linda, is that in June 2014, we initiated

14 a reinvestigation process on behalf of Mrs.

15 And at the time of dispute, the account was not

16 reporting the status of, or the narrative of, being in

17 foreclosure; however, based on the ACDV response that

18 we received back from Wells Fargo, they did request

19 that the account reflect foreclosure, of which we did

20 and updated accordingly.

21 Q. So the first record we have of Wells

22 Fargo, through Equifax, reporting it as a foreclosure

23 was June -- I'm sorry, July 4, 2014; correct?

24 A. From what I can recall, yes, from Exhibit

25 4.

Page 102

1 Q. Prior to that date --

2 A. I mean Exhibit 2.

3 Q. -- you don't have record showing it being

4 reported as a foreclosure; correct? 5 A. Can you repeat that, please.

6 Q. Prior to the date of July 4, 2014, you

7 don't have records reflecting Equifax, through Wells

8 Fargo, reporting her loan as in foreclosure?


10 A. Well, what I can state, Linda, is that

11 prior to the dispute process, I cannot verify how the

12 account was being reported, based on the documents

13 that have been presented; however, the documents that

14 have been presented today, it does indicate that we

15 initiated a dispute process on June the 17th, and at

16 the time of dispute, the account did not reflect17 foreclosure.


19 Q. So until she filed her dispute, the

20 account did not reflect foreclosure?


22 A. I can state between the time that we

23 initiated the dispute and the time that the dispute

24 process was completed, the account was not reporting

25 foreclosure.

Page 1


2 Q. And then the foreclosure reference was

3 removed on July 16, 2014; correct?

4 A. I believe that was Exhibit 8, the credit

5 file, or the credit report, that was dated

6 September the 4th. It stated as of the date of last

7 reported, it was July the 16th, 2014, and that it was

8 not reporting any information regarding foreclosure.

9 Q. So it reported foreclosure only from July

10 4, 2014, through July 15, 2014; because it was remove

11 on July 16, 2014; correct?


13 A. Based on the information I have here in

14 front of me and the documents that have been

15 presented, that is correct.


17 Q. Is there a way for Wells Fargo to go

18 back -- you know, we have this document from

19 Equifax.com that shows it being reported not as a

20 foreclosure as far back as July 13, 2013.

21 Are there records to reflect how Wells

22 Fargo was reporting this from June 20, 2013, until sh

23 filed her dispute on June 10, 2014?

24 A. There are documents that can be produced.

25 Q. And is there a reason we don't have --

Page 1

1 MR. BERMAN: Hold on, Linda.


3 Q. -- those today?

4 MR. BERMAN: Linda, one second. 5 Can you please read back the last

6 question and the answer.

7 (Thereupon, the court reporter read the

8 pertinent portion of the record.)

9 MR. ESTEVES: Can we go off the record?

10 MS. SPAULDING WHITE: No. I want this on

11 the record, please.

12 MR. ESTEVES: Okay. Well, I just want to

13 clarify, and Miss Smith can clarify, that those

14 documents have to be created.

15 A. That's what I was going to say.

16 MR. ESTEVES: They're not --17 MR. BERMAN: They're not existing?

18 MR. ESTEVES: They're not existing.

19 THE WITNESS: Right.

20 MS. SPAULDING WHITE: Okay. And that we

21 should have on the record.

22 MR. ESTEVES: Okay.


24 Q. But there are documents that can be

25 pulled or created to show how Wells Fargo was



(26) Pages 101 -





Page 105

1 reporting the loan from June 20 through the date of

2 her dispute?

3 A. There are documents that can be created,

4 I believe the timeframe that you stated, from June 20,

5 2013, up until her dispute in June '14, a year later.

6 Q. We may ask for those to be created.

7 MS. SPAULDING WHITE: I have no further

8 questions.

9 MR. BERMAN: I just need a minute.


11 RE-EXAMINATION

12 BY MR. BERMAN:

13 Q. As relates to any timeframe -- I have a

14 couple of follow-up questions. I will be as brief as

15 possible.

16 As relates to creating a timeline where

17 we just are looking at the word "foreclosure" and we

18 want to say from X date to X date it was in the

19 report, foreclosure was in the report, and then it

20 came out and then it went back in and then it came

21 out, and this yo-yo of the word "foreclosure" in and

22 out of the report, to create a timeline, the most

23 reliable information would not be your testimony, but,

24 in fact, would be from what we have today, your

25 testimony and these records, would be these records;

Page 106

1 right? Because they will show you the date it was

2 updated and they will show you when it's in and out.

3 And perhaps this other document that you might be able

4 to create would be even more reliable, but the records 5 that we have before us today are the most reliable;

6 correct?

7 A. Well, the documents that we have before

8 us today indicate when foreclosure was reporting and

9 when the word "foreclosure" was not being reported.

10 Q. Okay.

11 A. I believe Linda was -- had a timeframe

12 between June 2013 up until June 2014. Those are the

13 additional documents that would have to be created

14 that would show how the account was being reported for

15 each one of those additional timeframes.

16 Q. Okay.17 MS. SPAULDING WHITE: And we do have

18 Exhibit 12 that is from Equifax.com that shows

19 on July 13, 2013, it was not being reported as

20 a foreclosure.

21 MR. BERMAN: Okay. Is that a question or

22 just a statement?

23 MS. SPAULDING WHITE: I mean, I'm

24 pointing out this document that is from their

25 Equifax.

Page 1

1 MR. BERMAN: Okay.

2 BY MR. BERMAN:

3 Q. I want to ask you a brief follow-up

4 question on Exhibit 11, which is the July 4, 2014

5 response to the credit dispute by Mrs.

6 And in the section that provides the

7 subject trade line, in the additional information at

8 the end -- starting at the end of the line -- the

9 first narrative of the -- the first line of the

10 narrative section and then it goes on to the second

11 line, the first actual substantive information in that

12 part of the narrative says consumer disputes after

13 resolution.

14 What does that mean to you, as you read

15 it today?

16 A. Usually, up under the Fair Credit Billing

17 Act, they submit -- when a consumer disputes

18 information directly with the creditor, or data

19 furnisher, they are required to place that

20 information, stating that the account is under

21 dispute.

22 That narrative that states consumer

23 disputes after resolution is that their investigation,

24 or their internal review, has been completed;

25 although, the consumer still disputes the results of

Page 1

1 their findings. Just say, for example, if

2 Mrs. had contacted Wells Fargo -- and I can

3 state this is what happened. But just state, for

4 example, that Mrs. had contacted Wells Farg 5 Home Mortgage, disputing the information directly wit

6 them; that they submitted the information to Equifax

7 stating that this account is under -- is being

8 disputed by the consumer. They have a certain

9 timeframe before their investigation is completed, or

10 their internal review is completed. Once it's

11 completed, then they can either have that narrative

12 statement removed altogether -- but it appears based

13 on this -- and I'm only speculating -- is that they

14 did complete their research, or their internal

15 investigation; however, Mrs. still disputed

16 the information --17 Q. Okay. And we can --

18 A. -- or their findings.

19 Q. I'm sorry to cut you off.

20 A. That's okay. Go ahead.

21 Q. And so if we go back to Exhibit 2, which

22 is the very detailed one-page ACDV --

23 A. Yes.

24 Q. -- we can actually see where, in bold,

25 under the narrative, the response that you got from



(27) Pages 105 -





Page 109

1 Wells Fargo was that exact same information that the

2 consumer disputes after resolution?


4 Q. So that phrase is in the trade line

5 included in Exhibit 11 solely because Wells Fargo

6 asked that it be included; right?


8 MR. BERMAN: That's all the questions I

9 have.

10 MS. SPAULDING WHITE: I have nothing

11 further.

12 MR. BERMAN: Would you like to read and

13 sign or waive?

14 MR. ESTEVES: Yes, I think we want to

15 read and sign.

16 MR. BERMAN: Okay. I'll let you know if

17 I want to order it, but it certainly won't be

18 expedited.

19 (Deposition concluded at 1:18 p.m.)

20

21 - - -

22

23

24

25

Page 110

1 C E R T I F I C A T E 2

3 I hereby certify that the foregoing transcript was reported, as stated in the caption; 4 that the witness was duly sworn and elected to reserve

signature in this matter; that the colloquies, 5 questions and answers were reduced to writing under my direction; and that the foregoing pages 1 through 109 6 represent a true, correct, and complete record of the evidence given. 7 I further certify that I am not disqualified for a relationship of interest under 8 O.C.G.A. 9-11-28(c); that I am a Georgia Certified Court Reporter here as a representative of D'Amico 9 Gershwin, Inc.; that I/D'Amico Gershwin was contacted by the party taking the deposition to provide court10 reporting services for this deposition; that I will not be taking this deposition under any contract that11 is prohibited by O.C.G.A. 15-14-37(a) and (b) or Article 7C of the Rules and Regulations of the Board;12 and by the attached disclosure forms I confirm that I/D'Amico Gershwin is not a party to a contract13 prohibited by O.C.G.A. 15-14-37 or Article 7C of the Rules and Regulations of the Board.14 The above certification is expressly withdrawn and denied upon the disassembly or15 photocopying of the foregoing transcript, unless said disassembly or photocopying is done under the auspices

16 of D'Amico Gershwin, Inc. and the signature and original seal is attached thereto.17 This, the 4th day of December, 2014. 18

19

20

21 ________________________________ G. PAIGE ALEXANDER, CCR-B-211522

23

24

25

Page 1

1 E R R A T A S H E E T 2 Pursuant to Rule 30(e) of the Federal Rules

of Civil Procedure and/or O.C.G.A. 9-11-30(e), any 3 changes in form or substance which you desire to make to your deposition testimony shall be entered upon th 4 deposition with a statement of the reasons given for making them. 5

6 To assist you in making any such corrections, please use the form below. If 7 supplemental or additional pages are necessary, pleas

furnish same and attach them to this errata sheet. 8

9 - - - 10

I, the undersigned, PAMELA SMITH, do hereby11 certify that I have read the foregoing deposition and that said transcript is true and accurate, with the12 exception of the following changes noted below, if any:13

14 Page_____/Line_____/Should Read:_____________________ 15 _____________________________________________________ 16 Reason:______________________________________________ 17

18 Page_____/Line_____/Should Read:_____________________ 19 _____________________________________________________

20 Reason:______________________________________________ 21


Page 1

1 2 Page_____/Line_____/Should Read:_____________________

3 _____________________________________________________

4 Reason:______________________________________________

5

6 Page_____/Line_____/Should Read:_____________________ 7 _____________________________________________________

8 Reason:______________________________________________

9


14 Page_____/Line_____/Should Read:_____________________ 15 _____________________________________________________ 16 Reason:______________________________________________

17

18 Page_____/Line_____/Should Read:_____________________ 19 _____________________________________________________ 20 Reason:______________________________________________ 21 ______________________________ PAMELA SMITH22

Sworn to and subscribed before me,23

______________________________, Notary Public.24

This___________day of__________, 20_____.25 My Commission Expires:



(28) Pages 109 -





[

[sic] (1) 81:12

A

a/k/a (1) 60:7A498306 (1) 97:8able (13) 11:24;32:8;38:16, 19;61:3,4,8;63:12,16, 17;64:16;76:8;106:3above (2) 26:14,19absolutely (3) 33:4;42:23;59:14AC- (1) 31:5According (14) 26:25;39:10,22; 62:5;77:7;78:2,17; 87:13;88:4,21;91:4; 92:10;94:15;100:7accordingly (1) 101:20account (94) 10:8;16:6;21:3; 23:24,24;26:7,13; 28:13;29:15,16; 33:13,14,22;34:4,5,9; 35:5;39:1,2;42:14,15, 22;43:3;44:11,13; 46:19;47:1;54:17,18, 19,20;55:17;56:22; 67:10;68:1;69:11; 72:19;76:24;77:18, 20,21,23;78:18;81:14, 15,19;82:5,24,25,25; 83:1,5,6;84:9,12; 86:10,13;87:8,11; 88:24;89:5,12;90:18, 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

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31:14;64:8;65:4,7,7apologize (10) 25:4,10;40:9;51:9; 68:20,24;77:1;85:1; 91:2,19apparent (1) 55:16apparently (2) 40:14;57:25appear (11) 39:7;44:13;46:4,4; 67:5;78:6;87:14,22; 88:4;98:6;100:22appeared (2)

10:12;47:1appears (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;108:12applicable (1) 24:23appreciate (1) 9:8approval (1)

59:8April (7) 9:21;29:13;32:22; 33:5,8;70:3,10arcane (1) 60:13area (7) 22:9;51:10;60:22; 62:1;74:13;85:23;

97:18areas (1) 48:10around (5) 21:24;58:1;66:13; 80:2;81:22aspects (1) 89:11assistant (1) 7:18associate (1) 7:12assume (1) 19:3

assuming (2) 63:23;64:1asterisk (3) 85:7,12,20attached (3) 58:18,22;87:16AU (6) 34:6,8;76:22,23; 77:23;82:2AUD (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;65:11AUI (5) 83:22,25;84:11,16; 85:16authorization (1) 32:16Auto (2) 54:19;67:10Automated (7) 9:17,21,25;15:8; 26:25;29:23;34:25automatically (1) 83:1

avoid (1) 66:11aware (8) 7:22;28:10;69:12, 14,15;73:18,21;92:18away (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 65:18;66:15;68:11 69:16;71:8,10,17; 73:10,14;75:25;79: 15,16,25;80:8,10; 86:20;87:1;94:7; 101:12,18;103:18,2 104:5;105:20;108:2

background (1) 18:5back-of-the-house (1 46:25backwards (1) 79:2bad (3) 31:15,24;32:1balance (16) 33:22;34:9,13,17, 18;43:5;55:18;76:2 25;77:24;83:1;90:2 22;93:9,22;98:19Bank (3)

25:2;59:1;60:7based (35) 13:7,7;14:1;20:3; 22:4,17;23:12;28:1 30:17,20;31:1;34:1 38:6;40:22;41:13,1 46:6;56:1;62:3,22; 70:12;71:14;72:4,1 73:1;88:14,23;89:1 92:23;97:11;101:2, 17;102:12;103:13; 108:12basically (3) 58:23,25;62:19

bear (2) 26:11;87:19bearings (1) 54:15beginning (1) 13:21behalf (15) 8:2;9:19,23;10:1,3 11:2;15:17;23:8,10 27:2;30:2;35:2;38: 41:1;101:14below (5) 16:18;21:12,12; 34:4;86:23

benefit (1) 68:4Benson (3) 9:23;60:9;94:10Benson's (2) 29:17;97:21BERMAN (95) 7:5;8:9;9:8,12; 11:11,12;14:17,20,2 19:20;22:23;23:3; 28:3;30:15;31:14,1 24;32:3;36:20;37:2



(1) [sic] - BERM





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; 109:8,12,16Berman's (1) 91:9besides (2) 52:17;65:16best (2) 62:22;85:4beyond (1)

38:13big (1) 36:9Billing (1) 107:16birth (1) 60:10bit (4) 15:6;34:4;41:20; 44:5black (1) 16:18block (1) 99:20

blue (1) 66:21blurry (1) 87:20bold (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; 108:24borrower (3) 25:6,7;34:12both (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;99:2box (4) 21:3;79:9;80:16; 81:2boxes (4) 16:19;79:6,23;81:2break (2) 73:25;74:3brief (4)

12:15,16;105:14; 107:3briefly (2) 38:21;74:25bulk (4) 51:4,15;52:23; 85:25bunch (1) 16:18

bureau (3) 37:14,14;38:2bureaus (3) 36:2;40:21;42:11business (4) 12:3,8,12;53:6

C

call (4) 25:7;41:21;80:25; 85:3called (1) 81:3

calling (2) 49:25;75:21came (4) 49:15;85:19; 105:20,20Can (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, 17,24caps (1) 26:19Cards (1) 96:14case (6) 15:18;16:13;20:14; 25:1,1,6

certain (5) 12:22;32:8;62:21; 81:19;108:8Certainly (2) 93:3;109:17change (6) 25:19;50:9,22; 55:16,16;93:24changed (4)

33:24;34:2;83:6; 91:11Christine (3) 17:1;39:1;40:15chronological (2) 66:11,15clarify (2) 104:13,13clear (3) 40:19;47:8;64:21client (1) 15:19close (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; 98:10,13code (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; 98:20codes (4)

21:3;32:4,11;86:8column (2) 23:18;33:14columns (1) 98:13coming (2) 22:18;52:19comment (5) 34:6,16;76:21,23; 82:2comments (8) 42:1;47:5;86:4,6,8, 9,15,23company (1)

9:6compared (1) 56:6comparing (2) 56:16,17compile (1) 11:14compiled (4) 11:17;16:1;65:19; 76:3complete (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, 10,11compliance (1) 21:3comply (1) 11:15

computer (4) 17:14;60:14;61:16; 74:10concerns (1) 89:18concluded (1) 109:19conclusion (1) 63:10conclusions (1) 70:18condition (1) 21:3confident (1)

38:4confirm (1) 92:3confusing (1) 19:5confusion (2) 24:24;66:11considered (1) 83:2considering (1) 72:7consists (2) 41:22,23Consumer (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;109:2consumers (3) 53:8;61:7;92:8consumers' (1) 64:14consumer's (3)

49:1;80:21;81:8contact (2) 24:21;53:5contacted (2) 108:2,4contacts (1) 12:19continued (1) 26:4contractor (1) 12:20control (2)

16:8,20conventional (3) 21:16;26:17;43:7conversation (1) 18:12conversely (2) 20:13;36:13copies (2) 13:11;58:9

copy (10) 8:10;13:15,19; 48:16,20;49:2;50:6 62:17,17;87:17corner (5) 16:16;22:10;29:21 99:2,8corporate (1) 7:24correctly (4) 24:16,18;25:15; 90:23correlate (1) 26:8

correlates (1) 90:1correspondence (3) 12:20,24;17:24corresponding (1) 74:8counted (1) 43:25counting (1) 43:11couple (1) 105:14course (5) 12:8;35:25;39:25;

42:19;64:13court (2) 19:6;104:7cover (2) 48:25;89:2covered (2) 89:24;90:9covers (1) 89:2coversheet (1) 48:24create (2) 105:22;106:4created (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;106:13creating (1) 105:16credit (82) 10:12;11:6;12:18; 13:13,20;14:13,25; 15:20;21:10;22:3,1



(2) Berman's - cre





23:11,12,24;28:19,24, 25;29:17;36:2,4,9,25; 37:5,13,14;38:1; 41:23;42:10;44:14, 18;45:17;48:17,17, 23;49:7,13,18;50:6, 22,23;51:1;53:2,16; 65:12;66:6,7;67:21; 68:13;69:18,21;70:9;

71:3,9,18;72:7,8,14, 24;75:1,17,22;80:21; 81:6,8,9,12;82:8;87:6, 17;91:11;92:5,16,24; 93:14,14,16;96:14; 98:7;103:4,5;107:5, 16creditor (2) 84:17;107:18creditors (4) 53:7;84:16;85:17, 24CreditScorecom (4) 96:15;99:6;100:24;

101:1curiosity (1) 36:21current (5) 13:13;14:5;59:21; 79:22;90:19current/previous (1) 86:10cut (4) 52:2;80:11;91:20; 108:19

D

D-1 (1) 8:8D-10 (1) 66:1D-11 (1) 23:2D-2 (1) 9:10D-3 (1) 9:10D-4 (1) 9:10D-5 (1) 9:10

D-6 (1) 9:11D-7 (1) 9:11D-8 (1) 9:11D-9 (1) 66:1dash (1) 86:9Data (24) 9:21;10:24;13:1,2,

7;15:2,17;16:12; 23:15;29:10,23;30:1, 18;36:3;44:16,20; 48:7;51:1;60:14;61:7; 64:23;74:14;89:3; 107:18date (89) 8:13;16:8,20;24:3, 14,17,17;28:18;32:18,

20;35:3;40:5,24;41:2, 14,14;45:5;47:4;50:7; 57:1,11;59:17;60:9; 62:6;66:17;67:13,15, 15;69:5,25;70:1,13; 72:18;73:2,3;77:2; 78:1,3;79:1,14;82:13, 13,14,23;83:3,8; 86:22;87:9,10,25; 88:1,12,12;89:5,5,6,6,

12,12,19,19;90:4,5,7, 8;93:11,18;94:2; 97:24,25;98:2,5,12, 14,24;99:1,9,15,19,

25;100:2;101:7; 102:1,6;103:6;105:1, 18,18;106:1dated (15) 9:21,25;10:4,6; 11:1,10;28:5;39:11; 48:18;72:17;81:13; 87:2;93:4;99:9;103:5dates (10) 27:4;62:7,8;82:12, 22;89:4,7;90:4,5,17day (1) 59:21days (10)

13:2;26:7;32:8; 60:18;77:5,12;78:19, 20,20,21deal (1) 59:24Debt (1) 96:14debtor (1) 99:12deduction (1) 62:20Defendant (1) 60:8Defendants' (4)

8:8;9:10;23:2;66:1definitely (1) 62:21degree (1) 14:7delete (1) 13:6deletions (3) 10:23;23:17;44:13delinquency (6) 87:10;88:1,12;89:6, 20;90:8

demonstrates (1) 47:2department (4) 7:13,14,20;53:6depends (3) 52:1;65:20;80:13deposed (1) 18:8deposition (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; 109:19describe (3) 9:15;10:18;51:8described (3) 30:22;53:10;72:21describing (4) 60:12;61:22;63:1, 21description (1) 20:10

detail (3) 15:6;38:22;41:20detailed (5) 38:9;39:20;42:23; 71:21;108:22details (1) 38:15determine (1) 76:5deviates (1) 20:10device (1) 60:14DFD/DLA (1)

85:10difference (1) 82:21different (7) 35:8,13;37:13,14; 50:8;55:6;82:12digits (3) 23:25;32:24;100:21directly (5) 24:22;30:18;92:8; 107:18;108:5disclosure (4) 11:1;48:17;49:18; 93:14

discretion (1) 24:21discussed (3) 39:4;44:25;82:2discussing (4) 29:2;84:4,7;100:16discussion (3) 50:16;58:13;74:18Dispute (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;107:5,21disputed (14) 13:1;15:16,17,19; 16:9,12;37:15,23; 43:2;46:18;88:22; 90:16;108:8,15disputes (12) 21:14;26:15;36:1;

43:5;86:10;88:10,13; 107:12,17,23,25; 109:2disputing (14) 12:17;27:1;30:18; 87:6,9,11,14;88:5,11; 89:10,14;90:7,12; 108:5doc- (1) 57:17document (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; 106:3,24documentation (1) 57:24documents (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;106:7,13done (8) 17:14,15,16;28:25;

30:5;57:25;62:25; 73:25down (5) 26:9;33:14;34:4; 75:24;86:9downloaded (1) 61:2downloading (1) 19:12

drill (1) 18:10drive (1) 60:19due (7) 26:7;32:7;77:5,12; 78:19,20,22duly (1) 7:2dumps (1) 51:18during (4) 12:7,12;79:11; 81:18

E

earlier (7) 15:8;44:25;63:8; 65:21;74:11;84:8; 85:22early (1) 21:25ease (2) 25:11;66:20effect (2) 8:15;48:4effort (1)

11:15either (7) 13:4,5,6;66:6,7; 69:13;108:11electronic (11) 9:18;58:24;60:5,5, 17,18,19;61:14,22; 75:22;97:15electronically (7) 12:25;16:2;17:15, 16,18,22;29:11elimination (1) 62:20else (2)

26:24;77:17email (2) 53:11;59:6emailed (1) 96:12emphasize (1) 32:10employed (1) 7:9employee (4) 16:3;17:21;19:11, 15



(3) creditor - emplo





enclosed (1) 87:17end (6) 45:2,6,7;79:20; 107:8,8ended (1) 36:23enough (2) 9:6;34:22

entering (1) 80:13entire (1) 34:13entity (2) 8:4;73:19entries (1) 46:7entry (2) 43:14;67:11e-OSCAR (12) 17:19,23;19:15; 20:6;31:6;36:7,10; 41:5;45:10;73:20;

75:18,21Equifax (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; 108:6Equifaxcom (5)

97:5,15;98:25; 103:19;106:18Equifax's (9) 12:8;13:8;14:13; 40:25;50:3;53:5;64:3, 24;99:12equipment (2) 63:15;64:16essentially (1) 60:2estate (3) 21:15;26:16;43:6

ESTEVES (8) 64:7;65:3;104:9,12, 16,18,22;109:14even (7) 64:16;89:9;90:19; 94:9,11;100:5;106:4everybody (1) 14:11evidentiary (2)

31:16;32:2exact (2) 65:24;109:1exactly (1) 33:7EXAMINATION (2) 7:4;74:20examined (1) 7:2example (4) 51:19;85:8;108:1,4Except (1) 12:5excluding (2)

23:25;76:6Exhibit (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, 25;45:2,6,7;46:7,12; 47:7,10;48:9,15,16; 49:4;53:18,19,22,23; 54:12;55:11,15,19,23, 25;56:1,5,17,18,21, 25;57:5;58:17,19,19, 22;60:3,3,4;62:5; 66:1,4,17;67:20; 68:12;69:16,17; 70:16,16,22;71:12,19,

20;72:4,15,22,23; 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

exhibits (12) 8:20;11:13;12:1,3; 45:9;50:16;54:14; 57:20,22;66:5,12; 101:6existing (2) 104:17,18expedited (1) 109:18

Experian (2) 35:22;100:12expert (1) 75:1Explain (2) 50:8;74:25explained (1) 50:15explains (1) 38:8exported (1) 97:5Express (2) 85:9,10

extent (1) 37:3external (1) 60:10extrapolate (1) 22:8

F

facilities (1) 64:25facility (1) 64:3fact (4)

43:25;50:10;100:3; 105:24fair (7) 15:25;34:22;36:12, 13;48:1;61:21;107:16fairly (1) 38:4falls (1) 79:13familiar (3) 32:4,14;97:3far (10) 17:3;19:25;65:18; 75:6,7;77:8;78:24;

97:11;99:19;103:20Fargo (125) 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, 18;23:13;24:10,22; 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; 109:1,5Fargo's (3) 22:1;79:20;97:9farthest (1)

66:16FCRA (2) 16:10;88:19February (5) 77:3;80:10,11,12; 82:14felt (1) 91:6few (1) 15:6field (3) 74:12;88:20;91:5fifth (1) 53:1

figure (1) 79:12file (12) 10:12;13:14;21:10; 29:17;41:23;44:14; 48:17,23;50:7;80:21; 93:14;103:5filed (4) 87:24;92:1;102:19; 103:23filled (1) 20:1filler (2) 49:10;67:24

final (1) 44:9Finance (2) 54:19;67:11find (3) 61:8;63:16;76:8findings (2) 108:1,18fine (1) 95:19first (34) 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; 57:5;67:9,23;79:2,5 21,21;80:11;86:15; 87:10;88:1,12;89:6 20;90:8;99:22,24; 101:21;107:9,9,11five (1)

53:14five-minute (1) 74:3Florida (1) 63:16follow (1) 83:20following (4) 32:24;54:25;70:19 72:15follows (3) 7:3;26:18;54:22follow-up (3) 74:6;105:14;107:3

font (1) 20:11foreclosed (1) 28:15foreclosure (85) 21:15,21;22:3,5,14 21;25:1,2;26:10,16 27:11,14;28:5,7,7,1 29:3;32:7;42:13;43 44:22;45:22;47:24 48:5,8;55:2,4,9,11; 57:15;67:17;68:16, 22;69:2,6,11,20,23 70:4,7,11,14;71:6,1

17,24;72:1,10;73:8 78:5,6,8,23;80:16,1 19,20;81:19,20;87:1 18,23;94:12,18;98:2 23;101:9,17,19,22; 102:4,8,17,20,25; 103:2,8,9,20;105:1 19,21;106:8,9,20foreclosures (4) 73:11,11,12,12forgot (1) 18:4Form (38) 9:21;14:16,19;

17:12,17;19:18; 29:10,23;30:14;31: 12;34:10,11;35:1,1 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;103:12format (6) 41:11,11,13;46:14;



(4) enclosed - form





item (10) 12:18;24:21;57:10; 58:23;60:2;67:15; 70:1;73:1;92:10; 93:11items (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;98:13Jason (2) 9:6;18:20Jeff (4) 43:18;51:9;60:22; 94:23July (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; 107:4June (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) 47:17kept (2) 12:11;58:25kidding (1) 68:25kind (7) 7:18;53:12;58:24;

60:6,13,14;84:3knows (2) 14:12;44:1

(37) 9:19;10:1,3,6;11:2; 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;

94:18;96:14;101:14; 107:5;108:2,4,15

(18) 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

L

labeled (1) 56:17lack (2) 19:19;37:17landscape (1) 46:14laptop (1) 60:19last (27) 10:16,18,20;23:25; 24:17,17;26:13;28:2;

42:4;46:10,12,20; 58:6;62:6;68:7;69:5; 86:1,11;87:9,25; 88:12;89:5,19;90:8; 100:21;103:6;104:5late (8) 77:8,15;78:12;81:7, 15,18;88:25;90:17later (2) 24:25;105:5lawsuit (2) 42:6,9lawyer (2) 7:16;64:21

layer (1) 73:19layman (1) 11:5least (4) 11:22;55:7;100:23; 101:9left (3) 57:10,10;99:19left-hand (3) 16:16;22:10;29:21Legal (7) 7:12,13,14,18,20, 21;8:4

lender (3) 25:3;28:22;34:12length (1) 50:15less (10) 21:4;34:9,18;55:18; 76:24,25;77:24; 90:20;93:22;98:19letter (20) 10:5;12:5;39:10,11; 40:8;41:15;47:20; 70:20;78:8,9,22;

80:19;87:2,7,13;88:4, 11,14;94:11,19letters (1) 83:22letting (1) 70:18light (1) 16:5likely (2)

62:24,24limited (2) 59:8,21Linda (15) 75:3,20,21;77:9; 85:3,4,6,15;90:13,23; 101:13;102:10;104:1, 4;106:11line (63) 15:20;21:15,15,16; 26:9,10,13,14,19; 27:21;28:2,13;29:1; 42:9,16;44:8,18;45:5; 46:24;48:5;49:5;

50:10,25;53:3,17; 54:24;55:20;57:6; 64:5;65:12;66:8,22; 67:18;68:5,7,14,17; 69:7,20;70:3,23;71:1; 72:2,11;73:4;74:7; 79:3,5;80:11,22; 86:15,16,18;89:22; 90:6;92:9;94:21; 97:20;107:7,8,9,11; 109:4lines (5) 21:5;49:4;51:20; 54:9;67:6

lingering (1) 42:8list (3) 8:22,23;9:1listed (3) 40:16;84:11;86:23little (7) 13:21;15:6;19:4; 34:4;38:22;41:20; 87:20LLC (1) 7:10loaded (2) 51:12,20

loan (11) 28:14;45:5;46:8; 48:11;94:12;97:21; 100:15,23;101:8; 102:8;105:1loaning (1) 72:8loans (2) 14:24;96:14located (3) 58:2,3;98:2longer (3)

44:5;57:14;70:4look (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) 41:24looking (10) 27:6;43:8;45:17; 56:25;67:3;72:22; 75:11;81:23;91:3; 105:17looks (5) 32:17;35:25;37:9; 41:7,7lot (1) 37:9loud (1) 19:7

M

M5 (6) 25:25;26:4,5;43:4; 88:24;91:5mail (1) 12:21maintained (1) 12:11maintenance (6) 10:21;13:4;43:19; 46:11;86:2,24major (2)

36:2;42:10making (1) 52:6manager (1) 7:19manner (5) 51:4;56:14;71:9; 92:4,5manners (1) 91:10manual (2) 58:9;62:17many (4) 32:11,11;51:21;

77:5March (10) 10:1;35:4;67:16; 69:4;78:1;79:15;80:9, 9,12;100:22mark (7) 9:13;95:4,10,16,18, 20;96:17marked (24) 8:7,11;9:9;15:4; 23:1;27:16;28:8;29:8; 34:23;35:8;36:14;

41:16;44:9,21;48:1 56:18;57:17,18; 58:17;65:25;66:12 71:20;96:9,21marks (1) 78:15masked (1) 100:21matter (1)

100:2may (21) 8:22;11:19;23:16, 17;24:21;35:19; 36:23;42:18;51:5; 53:4,5,8;60:14;62:1 66:15;80:10,11;90: 91:6;92:4;105:6maybe (6) 18:22;23:22;60:17 79:17;84:13,19mean (14) 13:17;23:11;35:21 38:16;61:4;78:11;

79:9;80:5,20;81:2; 85:18;102:2;106:23 107:14means (10) 13:19;26:5,6,6; 77:20;78:18,21; 79:10;82:23;86:5meant (1) 56:3meat (1) 49:11memory (1) 55:14mentioned (6)

40:5;60:21;64:15; 65:21;74:11;85:22mess (1) 18:19method (2) 60:15;72:19metro (2) 32:11;78:17middle (2) 20:24;47:10middleman (3) 14:14,14;69:1might (1) 106:3

mind (2) 39:24;75:21minute (3) 33:2;47:8;105:9minutes (1) 15:6Miss (33) 22:10,19;25:7;27:3 28:20,23,25;30:6,8 37:24;39:11;40:7; 41:1,15;44:14;47:6 19;48:23;63:22;64



(6) item - M





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; 101:14related (4) 18:23;39:19,21;

87:25relates (10) 37:10;58:25;82:2; 87:6,12;90:4;91:18; 92:16;105:13,16relating (7) 42:13;46:8;60:6; 64:5;91:13,17,23relation (2) 40:2;41:14relevant (2) 16:10;88:20reliable (3) 105:23;106:4,5

remember (2) 18:13;49:21removed (4) 29:6;103:3,10; 108:12Removes (2) 21:3;55:9repeat (3) 19:6;91:20;102:5rephrase (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) 52:5report (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, 19,22reported (60) 13:13;14:8;15:2; 16:6,7;22:6;26:2; 33:25;34:2;42:10;

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; 106:9,14,19reporter (2) 19:6;104:7reporting (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;106:8reports (10) 14:24;15:1;16:4; 36:2;44:13;45:18; 52:24;66:16;71:24; 73:11represent (2) 79:6;80:6representative (3) 7:25;11:17;53:5

representing (1) 80:15represents (5) 78:8,23;80:6,17,19request (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; 101:18requested (1) 89:21requesting (1) 29:16

required (1) 107:19reschedule (1) 8:13research (1) 108:14researched (1) 23:24resolution (6) 21:14;26:15;43:6; 107:13,23;109:2respond (3)

13:3;19:16;59:20responded (5) 22:9,11,12,13;59:5responder (5) 16:24;20:1;29:13; 38:25;40:11responder's (1) 35:4response (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;108:25responses (2) 13:5;16:12responsive (6)

61:23;63:24;64:6, 25;76:6,9rest (4) 21:4;27:13;32:23, 24restate (1) 37:20result (3) 35:9;44:9;84:20results (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;107:25review (12) 11:21,24;12:21,24; 13:5;42:18;76:4; 86:17;100:18;101:12; 107:24;108:10reviewed (3) 38:7;40:23;72:17reviewer (1) 13:4reviewing (3) 67:4;72:23;98:22revised (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;109:6right-hand (3) 33:14;99:2,7

rights (1) 49:1role (1) 14:13room (1) 14:11route (1) 12:22run (3)

36:7,10;51:6

S

same (18) 13:19;31:5,5,7; 35:9,12;40:2;46:8; 56:5;76:25;77:23; 82:1,5;95:24;96:7; 97:13;100:20;109:1saw (1) 36:24saying (3) 30:24;39:21;57:13

scenario (1) 30:22scope (4) 12:8;38:13,18;59:6screen (2) 66:14;75:12second (25) 10:14;21:15;23:22; 24:5;32:15;46:21,22; 57:10;58:12;67:11; 68:11,13;73:4;74:17; 75:3;76:12;78:2; 79:23;86:16;98:4; 99:23;100:1,13;

104:4;107:10seconds (1) 33:3section (8) 20:22;41:25;47:9, 13,22;86:5;107:6,10sections (1) 48:9Secure (1) 75:22seeing (1) 67:23seem (1) 18:6

seems (2) 18:22;75:11sense (1) 60:18sent (10) 12:25;13:10;29:11; 31:6;33:5,8;39:11; 94:23;95:25;96:15sent/submitted (1) 35:2sentence (2) 24:8,13

separate (2) 10:17,17September (15) 11:2,10;48:19; 53:23;55:5,10,17,1 56:18;72:24;92:25 93:4,6;94:3;103:6sequential (1) 95:13

servers (2) 61:18,19service (1) 97:16Services (1) 7:10set (2) 79:23,24setting (1) 53:12settlement (5) 34:10,11,21;59:8, 18several (2)

11:20;98:3 (16)

9:19,23;10:1,3,6; 11:2;15:19;29:17; 39:2;48:19;49:14; 60:8,9;64:18;78:13 96:13sheet (4) 10:21;43:19;46:11 86:2sheets (1) 48:25shot (1) 51:21

show (13) 8:10;23:4;34:22; 38:20;48:14;58:16 81:6;93:18;98:23; 104:25;106:1,2,14Showing (4) 27:21;29:8;46:23; 102:3shown (1) 81:9shows (7) 46:23,24;47:1; 93:16;96:5;103:19 106:18

shut (1) 18:18side (6) 19:9,10;34:5;51:10 57:10;85:13sign (2) 109:13,15silent (1) 31:22similar (2) 35:10;39:3simple (1)



(9) related - sim





13:25simply (2) 14:13;82:23single (2) 30:2;84:17situations (1) 41:4six (1) 78:21

sixes (1) 78:15SMITH (5) 7:1,8;74:23;96:24; 104:13snapshot (1) 45:4sole (1) 87:24solely (1) 109:5somebody (1) 18:13someone (1)

71:23Sometimes (3) 30:17;53:8;84:24somewhere (4) 64:2,24;80:2;81:22sorry (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;108:19sort (6) 18:6;20:24;46:24;

53:11;54:15;62:22sought (1) 9:2source (5) 24:3,9;35:19,21; 71:19south (1) 63:16SPAULDING (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;109:10Spaulding-White's (1) 68:4

speak (3) 8:5,5;75:10speaker (1) 75:4speaking (1) 86:6special (4) 34:6,15;76:21,23specialist (1)

85:23specialized (5) 51:10;60:23;62:1; 74:12;97:18specific (2) 52:7;67:24specifically (2) 55:24;56:14speculate (4) 62:15;63:2;88:21; 91:8speculating (2) 58:5;108:13speed (1)

66:20spoke (1) 91:19stand (1) 29:22standard (1) 78:17stands (10) 33:19,21;34:7,8; 75:19,21;76:23; 77:22;83:24,25start (5) 41:1;74:3;75:14; 80:10;95:8

started (3) 39:13;47:19;79:20starting (5) 21:14;28:14;29:15; 32:25;107:8starts (1) 79:17state (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;108:3,3stated (5) 44:2;49:2;97:6; 103:6;105:4statement (3) 25:17;106:22; 108:12states (11) 23:23;24:1,3,13;

26:14,15,16;73:2; 87:8;98:18;107:22stating (8) 30:10;34:16;39:22; 62:14;77:22;81:17; 107:20;108:7status (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; 101:16still (7) 8:14;31:17;34:5; 42:8;94:13;107:25; 108:15stipulated (1) 65:20stop (2) 10:14;24:5

storage (3) 60:15;61:23;64:25stored (2) 12:12;64:4subject (5) 66:8;68:5,14;69:19; 107:7submissions (1) 52:23submit (7) 16:11;30:2,19;51:6; 85:17;94:18;107:17submitted (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; 108:6Subpoena (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;93:5subpoenaed (1) 50:4subscriber (4)

16:9;29:12;38:24; 97:12substantive (1) 107:11suggest (1) 34:11summary (6) 10:21;40:13;43:19; 46:11;83:11;86:2support (2) 7:12,21supporting (6)

53:9;91:12,17,23; 92:11,15suppose (1) 16:19supposed (1) 97:25supposedly (1) 87:24sure (12)

30:12;31:23;33:1,4; 39:25;40:18;42:21; 47:8;54:13;68:15; 71:16;95:23sworn (1) 7:2synopses (1) 12:17system (7) 13:5;18:1;51:12; 60:24;61:3,4;80:14

T

tab (1) 66:22tabbed (3) 66:21,25;68:3table (1) 66:13talked (3) 50:10,14;53:15talking (15) 18:17,18;42:16,16; 43:24;46:8;47:17,18; 48:12;52:8;54:11; 64:23;66:9,23;67:7tape (22)

30:3;51:1,6,11,25; 52:21;58:8;61:1,1; 62:16;64:2,24;74:8, 13;83:25;84:1,3,7,14; 85:16,18,20tapes (14) 51:7,8,13;60:12; 61:21;62:25;63:14, 18,20,21,23;64:3; 76:6;84:20TD (2) 54:18;67:10telephone (1) 24:23

tells (1) 86:24terms (1) 47:18testified (3) 7:3;17:9;37:13testify (1) 8:2testimony (9) 15:21;20:17;21:13; 37:10;38:14;41:16; 68:15;105:23,25

testing (1) 55:13theoretically (4) 14:12;17:3;35:14; 45:21therefore (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;74:4,1 96:9,20,21;104:7; 105:10thinking (1) 90:14third (7) 20:7,23;21:15; 24:14;52:20;80:16 86:18third-from-the-bottom

16:23third-party (1)

99:11though (6) 15:18;39:7;89:9; 90:19;94:9,11thought (2) 27:22;43:18thousands (3) 61:5,5;64:11three (9) 27:13;36:9;41:22; 45:9;49:3;78:16; 83:22;95:6,25three-page (2) 95:15;96:1

throughout (1) 17:8tie (2) 39:19;57:25tied (1) 62:13timeframe (14) 13:2;79:11,18;80:2 7;81:19,22;82:24; 93:13,13;105:4,13; 106:11;108:9timeframes (1) 106:15timeline (2)

105:16,22times (2) 91:14;92:7timing (1) 78:24title (1) 85:9titled (1) 15:8today (16) 7:23,24;8:12,14,22 9:3;50:1;58:18;66:



(10) simply - tod





101:5;102:14;104:3; 105:24;106:5,8; 107:15today's (2) 79:1;100:16took (1) 83:4top (11) 29:20;43:15;44:8,

23;47:12;49:21;57:6; 68:13;73:5;97:7;99:7topics (1) 8:22towards (3) 33:13;36:24;75:10trade (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;109:4transmitted (6) 19:14,24;20:16,18; 39:15;41:2transpired (2) 62:7;83:4TransUnion (2) 35:22;101:4try (1) 25:11

trying (2) 79:12;92:3turn (4) 8:19,25;53:18; 66:23two (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;99:16,18two-minute (1) 73:25two-page (1) 29:18type (11) 25:25;29:24;36:13; 60:14;61:4,12;63:21; 83:3;84:14;91:5;97:2types (1) 63:7

typesetting (2) 16:5,11typical (1) 60:18typing (1) 18:13

U

Ultimately (5) 20:4;31:5;44:17,24; 45:13unable (2) 19:22;100:8under (12) 32:16;33:12,13,19; 34:5;77:15;98:3; 99:24;107:16,20; 108:7,25underneath (4) 54:18;67:10;85:9; 98:4understood (2)

19:3;37:10Universal (3) 9:21;29:10,23Unless (2) 29:5;73:15unlikely (1) 63:8up (7) 18:13,18;81:6; 93:13;105:5;106:12; 107:16up- (1) 13:25update (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; 92:5updated (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;106:2updates (10) 10:23;23:16;28:25; 44:12;51:16;52:21; 53:6;70:14;73:13; 74:7updating (2) 13:25;85:24uploaded (3) 33:5;60:24;61:2uploads (3) 17:22;51:25;74:8

upon (1) 12:22upon-conclusion-of-the-dispute (1)

13:9upper (4) 16:14,16;22:10; 29:21use (2) 49:9;89:1

used (3) 32:5;90:25,25user (4) 95:7;97:8,9,10using (3) 19:13;88:17;100:12usually (4) 13:24;79:17;85:7; 107:16

V

validate (8) 51:11;62:2;63:25;

72:19;90:14;97:17; 101:1,2value (1) 21:4various (1) 32:4vendor (2) 12:20;28:23vendors (1) 99:11Verification (7) 9:17,25;12:25;15:9; 27:1;35:1;48:2verified (5)

14:4;22:17;48:3; 72:18;86:19verify (14) 19:17,22;27:3; 30:10;38:19;51:11; 63:2;73:21;89:4,7,17; 91:3;100:19;102:11verifying (1) 90:17version (1) 40:13

W

wait (2) 18:16,17waive (1) 109:13way (21) 18:4;27:15;36:22; 44:17,25;45:10;51:7; 52:16,18,20;53:1,8, 10;54:13;66:7;71:8; 72:1;73:15;79:25; 94:4;103:17ways (5)

50:8,21,24;53:3,14website (1) 97:16week (1) 63:10Wells (130) 9:19,22;10:3,7; 15:20;16:13;17:4,17; 18:23;19:9,11,15,23;

20:7,14;21:17;22:1,8, 18;23:13;24:10,22; 25:2,9,12,12;26:3,12, 23;27:3,10,25;28:6, 12;29:12,14;31:7; 35:2;36:3;37:1,5; 38:24;39:15;40:14; 41:3;42:14;43:2; 44:23;45:12;46:4,18; 48:3;51:18,20;52:7,8, 11,13,14,16;53:5; 54:8,16,17;56:22; 57:6;58:6;59:1,1; 60:7,7;62:2;63:22;

64:5,19;66:8,22;67:6, 9;68:5,14;69:3,8,19; 70:2,9,22;71:10,15, 23;72:14;73:15,18; 76:18;79:20;81:14; 83:21;84:9,12;85:19; 86:12;87:8;89:11,16, 21;90:10;93:8;94:4, 19;97:9,11,21;99:16, 18,22,23,24;100:1,13; 101:7,18,21;102:7; 103:17,21;104:25; 108:2,4;109:1,5what's (5)

29:8;36:20;58:16; 72:15;97:6whenever (2) 45:25;89:1WHITE (67) 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;84:25;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; 109:10whose (1) 50:14wish (1) 24:21within (9)

11:20;13:1,2;38:17 42:12;57:5,22,22; 88:15without (1) 51:18WITNESS (1) 104:19word (34) 16:15;18:14;19:13

21:21;22:13;28:5,6 29:3;44:22;45:22; 46:3;48:4;49:9;55: 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;106:9words (2) 52:13;54:25work (5) 7:13;51:9;60:22; 74:12;97:17works (1)

45:10workstation (1) 61:16world (8) 14:13;21:23;22:1,7 12,16;45:15;70:8worry (1) 59:18write (2) 25:25;75:24written (5) 12:19,23;17:24; 58:25;60:5wrong (3)

19:13;36:20;56:3

Y

year (5) 32:24;79:21,22; 80:6;105:5yesterday's (1) 8:13you-all (1) 31:17yo-yo (1) 105:21

Z

zero (4) 33:22;43:4;83:1; 90:21

0

007 (6) 89:1,24,25,25; 90:11,25016 (4)



(11) today's - 0





89:3,24;90:3,9092 (1) 32:25098 (1) 90:20

1

1 (16)

8:11,19;58:17,19; 70:25;77:3;82:14,18; 83:20;85:8;86:16; 87:8;95:8,11,17; 99:251,000 (1) 51:191:18 (1) 109:1910 (22) 41:15;47:19;53:18, 18,20;54:5,18;56:25; 57:7;66:5;67:20; 69:16,17;70:19;73:2;

87:3;91:18,24;93:7, 10;94:11;103:23100 (2) 33:1;63:310th (1) 39:1211 (35) 9:21;23:5,7,21; 26:11;27:16;28:1,11; 29:2,13;33:5;44:25; 45:2,6;48:24;55:15, 19,23,25;56:17,21; 66:5;67:16;69:4;70:3, 10,16,16,22;71:13,19;

72:4,15;107:4;109:511th (2) 32:22;33:812 (11) 10:4;39:9;40:6; 95:21,22;96:8,25; 97:7;98:22;99:2; 106:1812th (1) 40:2413 (8) 33:17,19;80:15; 96:18;99:3;101:9; 103:20;106:19

14 (3) 55:19;67:4;105:514th (2) 39:12;40:815 (1) 103:10150 (1) 26:71 8 (1)

54:5,18;57:1,2,14; 58:1;62:13;68:6; 72:17;73:2;93:7,10, 24;94:7;103:3,1116th (3) 58:8;62:6;103:717th (3) 39:14;41:1;102:1518 (1)

98:25180 (2) 77:12;78:211-84 (1) 77:16

2

2 (48) 9:16;11:13;12:1,3; 15:5;16:1;25:22,24; 27:7;28:9;35:8,11,15, 18;36:15;38:11; 39:20;40:1;41:8,12;

42:24;44:10,21,22; 47:7,10;54:12;56:1; 58:23;60:2,4;61:24; 63:24;64:6;65:1; 70:25;71:21;86:17, 18;88:7;89:3,16;90:3, 9;94:16;100:18; 102:2;108:2120 (5) 59:9;92:15;103:22; 105:1,42003 (1) 100:12010 (1)

94:92012 (9) 77:3;79:25;80:1,16; 81:21;82:14,18; 93:19;98:132013 (17) 59:9;66:18;67:12, 16;68:12;69:4;79:24; 80:12;92:16;98:25; 99:25;101:9;103:20, 22;105:5;106:12,192014 (75) 9:22;10:1,4,6;11:2; 21:25,25;22:11;28:5,

12;29:13;32:22,24; 33:5,8;35:4;39:9; 40:6,25;41:15;45:25; 47:19;48:19;53:24; 55:5,14,17,19;56:16, 18;57:2,14;58:1; 62:13;67:21;69:18; 70:3,10,17,19;71:18;

94:3,7,11;101:10,13, 23;102:6;103:3,7,10, 10,11,23;106:12; 107:420th (1) 10:6

3

3 (13) 9:20;29:9,10;33:11; 37:9,11;66:18;67:12, 21;68:12;69:17;94:9; 95:83/30/2014 (1) 99:1030 (4) 13:2;78:1,19; 100:2230-day (1) 13:130th (4) 10:1;35:4;79:15;

81:13312,500 (3) 82:9;93:16;98:73rd (1) 22:11

4

4 (42) 9:24;11:2;28:5; 34:23,25;35:7,12,16, 18,25;37:9,12,23; 38:1,15,18;39:4;44:1; 45:25;48:23;53:23;

55:5,17;56:16,18; 70:17;71:18;72:2,9, 24;76:11,14;83:21; 85:19;92:25;93:6; 101:10,23,25;102:6; 103:10;107:44/11/2014 (1) 70:14th (13) 11:10;27:18;28:12, 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;82:3512004209 (2)

78:19

6

6 (6) 10:5;87:1,3,4; 92:11;93:116/06/2014 (1) 85:12

6/12/2014 (1) 38:2560 (1) 78:2068 (3) 77:18,22;82:6

7

7 (21) 10:9,15,16,19,20; 41:19,21;42:12;43:9; 44:9,24;45:7;46:7,12; 48:9;83:10,15,17,18;

84:22;86:27/13/2013 (1) 97:257/16/2014 (2) 73:3;93:12

8

8 (29) 11:1,5,14;12:1,3; 48:15,16;49:4;53:18, 19,22,23;55:11;56:6, 19,20,25;57:5;62:5; 66:5;67:4;68:13;

72:22,23;92:23;93:2, 4,11;103:489 (1) 78:20

9

9 (5) 66:5,17;68:6,12; 69:17

equifax pamela smith deposition

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