Josh Timmons
New member
Posted: Fri Nov 11, 2005 5:59 am Post subject: XPN: WHAT IS CASS [CONSUMER AFFAIRS SPECIAL SERVICES]?
1
1 IN THE UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF TEXAS
2 SHERMAN DIVISION
3 JAMES E. JENSEN, *
*
4 Plaintiff, *
* CIVIL ACTION
5 VS. * NO. 00-CV-0040
*
6 EXPERIAN INFORMATION SOLUTIONS, INC.*
*
7 Defendant. *
8
9 *********************************************************
10 ORAL AND VIDEOTAPED DEPOSITION OF CAROLYN HELM
11 AUGUST 16, 2000
12 VOLUME 1
13 *********************************************************
14
15
16 ANSWERS AND DEPOSITION OF CAROLYN HELM, produced as a
17 witness duly sworn by me at the instance of the Plaintiff,
18 taken in the above-styled and -numbered cause on the 16th
19 day of August, 2000, A.D., beginning at 9:54 a.m. to 2:29
20 p.m., before LISA C. HUNDT, a Certified Shorthand Reporter
21 in and for the State of Texas, reported by machine
22 shorthand, in the offices of Jones, Day, Reavis & Pogue,
23 located at 2727 North Harwood, Dallas, Texas, in accordance
24 with the Federal Rules of Civil Procedure and the
25 agreements hereinafter set forth.
***********
1 BY MR. Szwak:
2 Q. Ms. Helm, briefly, we know each other from the
3 past. And the purpose of the deposition is to get some
4 information from you under oath as if you're in the
5 courtroom. If you answer my question, I assume that you
6 understood it. Is that fair enough?
7 A. Yes.
8 Q. Okay. Under the Eastern District Rules, the only
9 objections that can be made is attorney/client privilege.
10 And so, if at any point in time you need to stop and go
11 visit with your counsel, that's fine with me. Just tell us
12 and we'll take a break. Okay?
13 A. Okay.
14 Q. I'm not here to harass you in any way, and I'm
15 hope that I'm able to carefully word my questions so that
16 we understand each other. Let me start by just getting you
17 to tell us your name and your address.
18 A. My name is Carolyn Helm, and my address is 701
19 Experian Parkway. That's in Allen, Texas, and it's 75013
20 is the ZIP code.
21 Q. Tell me what your title is at Experian.
22 A. I'm now compliance manager.
23 Q. Compliance manager would be over the CASS
24 department?
25 A. It would be over the CASS department, yes.
8
1 Q. You have the appropriate authority to be here
2 today and testify on behalf of Experian?
3 A. Yes.
4 Q. And did you review the deposition notice in
5 connection with this case?
6 A. I have not reviewed the deposition notice.
7 Q. Let me provide it to you and ask you about which
8 areas you're able to testify. Here's a copy.
9 (Witness reviewed document.)
10 A. Okay. I believe I've been specifically brought in
11 to testify regarding our reinvestigation processes.
12 Q. Okay. Let me ask you: Are you familiar with some
13 of the other areas that are listed in that notice?
14 A. I am limitedly familiar with them. My expertise
15 is in reinvestigation because that's what we do.
16 Q. In terms of reinvestigation, would that include
17 fraud files?
18 A. Yes.
19 Q. Mixed files?
20 A. Yes.
21 Q. Basic accuracy issues?
22 A. Yes.
23 Q. Do you -- do you use the super CAP system in
24 connection with doing reinvestigations?
25 A. Yes.
9
1 Q. Are you familiar with the architecture of that
2 system?
3 A. No, I am not.
4 Q. But you do use that system in the course of
5 performing your functions?
6 A. Yes.
7 Q. You also are familiar with a manual record system
8 at Experian?
9 A. Manual record? I'm not familiar with it in those
10 terms.
11 Q. Consumer documentation as well as CDVs, ACDVs,
12 record retention?
13 A. Yes.
14 Q. Okay. If I could, please, get that from you.
15 (Witness handed document to Mr. Szwak.)
16 Q. Thanks.
17 Are you also familiar with CASS activities at the call
18 center?
19 A. Yes.
20 Q. Are you at all familiar with the use of a quota
21 system at the call center?
22 A. We do have a production system.
23 Q. Are you familiar with the employee incentive plan?
24 A. Yes.
25 Q. What about the -- the audit trail of the system
10
1 insofar as retaining copies of different documentation?
2 A. Yes.
3 Q. Okay. Are you somewhat familiar with the
4 relationship between the subscribers and Experian?
5 A. Well, that's not my area of expertise because
6 we're -- the center mostly deals with consumers. But I
7 have a -- a limited familiarity with it.
8 Q. Okay. Are you familiar with the different
9 suppression codes that are used at the call center?
10 A. I am familiar with them.
11 Q. Do you know the difference between a hard delete
12 and a soft delete and -- and other methods of removing data
13 from a person's file?
14 A. Yes.
***********
30
1 A. Yes, that's true.
2 Q. Okay. I want to move into another area now and
3 ask you: Carla Blair, is she still with Experian?
4 A. Yes.
5 Q. Is she still working in -- with the CASS system?
6 A. Yes.
7 Q. When I say the CASS system, the CASS department,
8 the special services department?
9 A. Yes.
10 Q. Special services is different from some of the
11 other departments. I understand that it's a legal liaison
12 department; is that correct?
13 A. You may call it like that. We do some legal work
14 in that department.
15 Q. You handle, perhaps, requests from outside counsel
16 to help with researching issues?
17 A. Yes.
18 Q. You handle governmental and incoming attorney
19 requests or letters?
20 A. Yes.
21 Q. What other activities are performed by the CASS
22 department?
23 A. We handle subpoenas that come in regarding credit
24 reporting. We also handle anything coming in from the
25 Federal Trade Commission.
31
1 Q. Are the members of the CASS department, the
2 employees who are regularly proffered as deponents in
3 lawsuits?
4 A. Some of the CASS members are.
5 Q. Do you know of any employees outside of the CASS
6 department that are ever proffered from the Allen center?
7 A. By "proffered," what do you mean that --
8 Q. Put forth as deponents or corporate
9 representatives for purposes of corporate depositions?
10 A. They're not designated as corporate reps, but
11 other agents have been deposed.
12 Q. When you say other agents of the special services
13 department?
14 A. And of the rest of the national consumer
15 assistance center.
16 Q. Do you know, from your review of the records, who
17 the actual Experian employees who handled Mr. Jensen's
18 disputes and complaints and requests for information from
19 Experian?
20 A. Not from the admin report.
21 Q. Let me see if I can help you with some of the --
22 the various names that have appeared in here and the codes.
23 One is the name of John Sprague. Do you know Mr. Sprague?
24 A. Yes.
25 Q. Who is he?
32
1 A. John Sprague is the vice president of the national
2 consumer assistance center.
3 Q. Does he normally handle consumer complaints?
4 A. No.
5 Q. He would be called in either in a special case or
6 when there's a problem?
7 A. No.
8 Q. Would there ever be a reason for him to become
9 involved in a con -- a particular consumer's dispute?
10 A. Only if requested by plaintiff's attorney.
11 Q. In this case, did the plaintiff's attorney request
12 Mr. Sprague to become involved in this matter?
13 A. Not that I know of.
14 Q. I was curious. He is not listed in the Experian
15 disclosure in this case as having been involved in this
16 matter. Do you know whether he has any knowledge of the
17 matters raised in this lawsuit?
18 A. He doesn't typically work with consumers, so I
19 would say not.
20 Q. Okay. Does he have a badge number within
21 Experian?
22 A. No.
**************
1
1 IN THE UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF TEXAS
2 SHERMAN DIVISION
3 JAMES E. JENSEN, *
*
4 Plaintiff, *
* CIVIL ACTION
5 VS. * NO. 00-CV-0040
*
6 EXPERIAN INFORMATION SOLUTIONS, INC.*
*
7 Defendant. *
8
9 *********************************************************
10 ORAL AND VIDEOTAPED DEPOSITION OF CAROLYN HELM
11 AUGUST 16, 2000
12 VOLUME 1
13 *********************************************************
14
15
16 ANSWERS AND DEPOSITION OF CAROLYN HELM, produced as a
17 witness duly sworn by me at the instance of the Plaintiff,
18 taken in the above-styled and -numbered cause on the 16th
19 day of August, 2000, A.D., beginning at 9:54 a.m. to 2:29
20 p.m., before LISA C. HUNDT, a Certified Shorthand Reporter
21 in and for the State of Texas, reported by machine
22 shorthand, in the offices of Jones, Day, Reavis & Pogue,
23 located at 2727 North Harwood, Dallas, Texas, in accordance
24 with the Federal Rules of Civil Procedure and the
25 agreements hereinafter set forth.
***********
1 BY MR. Szwak:
2 Q. Ms. Helm, briefly, we know each other from the
3 past. And the purpose of the deposition is to get some
4 information from you under oath as if you're in the
5 courtroom. If you answer my question, I assume that you
6 understood it. Is that fair enough?
7 A. Yes.
8 Q. Okay. Under the Eastern District Rules, the only
9 objections that can be made is attorney/client privilege.
10 And so, if at any point in time you need to stop and go
11 visit with your counsel, that's fine with me. Just tell us
12 and we'll take a break. Okay?
13 A. Okay.
14 Q. I'm not here to harass you in any way, and I'm
15 hope that I'm able to carefully word my questions so that
16 we understand each other. Let me start by just getting you
17 to tell us your name and your address.
18 A. My name is Carolyn Helm, and my address is 701
19 Experian Parkway. That's in Allen, Texas, and it's 75013
20 is the ZIP code.
21 Q. Tell me what your title is at Experian.
22 A. I'm now compliance manager.
23 Q. Compliance manager would be over the CASS
24 department?
25 A. It would be over the CASS department, yes.
8
1 Q. You have the appropriate authority to be here
2 today and testify on behalf of Experian?
3 A. Yes.
4 Q. And did you review the deposition notice in
5 connection with this case?
6 A. I have not reviewed the deposition notice.
7 Q. Let me provide it to you and ask you about which
8 areas you're able to testify. Here's a copy.
9 (Witness reviewed document.)
10 A. Okay. I believe I've been specifically brought in
11 to testify regarding our reinvestigation processes.
12 Q. Okay. Let me ask you: Are you familiar with some
13 of the other areas that are listed in that notice?
14 A. I am limitedly familiar with them. My expertise
15 is in reinvestigation because that's what we do.
16 Q. In terms of reinvestigation, would that include
17 fraud files?
18 A. Yes.
19 Q. Mixed files?
20 A. Yes.
21 Q. Basic accuracy issues?
22 A. Yes.
23 Q. Do you -- do you use the super CAP system in
24 connection with doing reinvestigations?
25 A. Yes.
9
1 Q. Are you familiar with the architecture of that
2 system?
3 A. No, I am not.
4 Q. But you do use that system in the course of
5 performing your functions?
6 A. Yes.
7 Q. You also are familiar with a manual record system
8 at Experian?
9 A. Manual record? I'm not familiar with it in those
10 terms.
11 Q. Consumer documentation as well as CDVs, ACDVs,
12 record retention?
13 A. Yes.
14 Q. Okay. If I could, please, get that from you.
15 (Witness handed document to Mr. Szwak.)
16 Q. Thanks.
17 Are you also familiar with CASS activities at the call
18 center?
19 A. Yes.
20 Q. Are you at all familiar with the use of a quota
21 system at the call center?
22 A. We do have a production system.
23 Q. Are you familiar with the employee incentive plan?
24 A. Yes.
25 Q. What about the -- the audit trail of the system
10
1 insofar as retaining copies of different documentation?
2 A. Yes.
3 Q. Okay. Are you somewhat familiar with the
4 relationship between the subscribers and Experian?
5 A. Well, that's not my area of expertise because
6 we're -- the center mostly deals with consumers. But I
7 have a -- a limited familiarity with it.
8 Q. Okay. Are you familiar with the different
9 suppression codes that are used at the call center?
10 A. I am familiar with them.
11 Q. Do you know the difference between a hard delete
12 and a soft delete and -- and other methods of removing data
13 from a person's file?
14 A. Yes.
***********
30
1 A. Yes, that's true.
2 Q. Okay. I want to move into another area now and
3 ask you: Carla Blair, is she still with Experian?
4 A. Yes.
5 Q. Is she still working in -- with the CASS system?
6 A. Yes.
7 Q. When I say the CASS system, the CASS department,
8 the special services department?
9 A. Yes.
10 Q. Special services is different from some of the
11 other departments. I understand that it's a legal liaison
12 department; is that correct?
13 A. You may call it like that. We do some legal work
14 in that department.
15 Q. You handle, perhaps, requests from outside counsel
16 to help with researching issues?
17 A. Yes.
18 Q. You handle governmental and incoming attorney
19 requests or letters?
20 A. Yes.
21 Q. What other activities are performed by the CASS
22 department?
23 A. We handle subpoenas that come in regarding credit
24 reporting. We also handle anything coming in from the
25 Federal Trade Commission.
31
1 Q. Are the members of the CASS department, the
2 employees who are regularly proffered as deponents in
3 lawsuits?
4 A. Some of the CASS members are.
5 Q. Do you know of any employees outside of the CASS
6 department that are ever proffered from the Allen center?
7 A. By "proffered," what do you mean that --
8 Q. Put forth as deponents or corporate
9 representatives for purposes of corporate depositions?
10 A. They're not designated as corporate reps, but
11 other agents have been deposed.
12 Q. When you say other agents of the special services
13 department?
14 A. And of the rest of the national consumer
15 assistance center.
16 Q. Do you know, from your review of the records, who
17 the actual Experian employees who handled Mr. Jensen's
18 disputes and complaints and requests for information from
19 Experian?
20 A. Not from the admin report.
21 Q. Let me see if I can help you with some of the --
22 the various names that have appeared in here and the codes.
23 One is the name of John Sprague. Do you know Mr. Sprague?
24 A. Yes.
25 Q. Who is he?
32
1 A. John Sprague is the vice president of the national
2 consumer assistance center.
3 Q. Does he normally handle consumer complaints?
4 A. No.
5 Q. He would be called in either in a special case or
6 when there's a problem?
7 A. No.
8 Q. Would there ever be a reason for him to become
9 involved in a con -- a particular consumer's dispute?
10 A. Only if requested by plaintiff's attorney.
11 Q. In this case, did the plaintiff's attorney request
12 Mr. Sprague to become involved in this matter?
13 A. Not that I know of.
14 Q. I was curious. He is not listed in the Experian
15 disclosure in this case as having been involved in this
16 matter. Do you know whether he has any knowledge of the
17 matters raised in this lawsuit?
18 A. He doesn't typically work with consumers, so I
19 would say not.
20 Q. Okay. Does he have a badge number within
21 Experian?
22 A. No.
**************