|
DEFENDANT TRANS UNION LLC'S
FIRST
SET OF INTERROGATORIES TO PLAINTIFF
To: Plaintiff Pro Se, Christine Baker,
(address deleted)
Defendant, TRANS UNION LLC (hereinafter
referred to as "Trans Union"), by its attorneys,
hereby serves upon Plaintiff the following Interrogatories
pursuant to Rule 33 of the Arizona Rules of Civil Procedure.
You are required to serve verified responses to the
following Interrogatories within (40) days of the date
of service.
The following are deemed to be continuing
Interrogatories. At such time as you receive information
which renders the answers thereto incomplete, inaccurate
or in any way misleading, you are required to supplement
the answers accordingly.
DEFINITIONS
For purposes of these Interrogatories,
the following definitions shall apply.
- "You," "Your" or "Plaintiff"
means plaintiff CHRISTINE BAKER and any of her
authorized agents or representatives or any
person who took any action pursuant to her authorization.
- "Trans Union" means Defendant
Trans Union LLC.
- "Person" means any individual,
partnership, corporation, trust, estate, cooperative
association, group, proprietorship, government,
governmental subdivision or agency, or other
entity.
- For any information withheld on the basis
of a claim fo privilege, identiy the privileged,
the persons who possess or who have shared the
information and such other facts, including
but not limited to the nature of the information,
that support your claim of privilege.
- "Medical Facility" means any hospital,
clinic, or other facility in which medical care
is provided.
- "Mental health professional" means
a psychiatrist, psychologist, sociologist, licensed
professional counselor, or any other individual
or entity which provides psychiatric, mental
health or counseling services of any kind.
INTERROGATORIES
INTERROGATORY NO. 1: State
your full name (and other names you have used), and
every address Plaintiff had used for the ten years prior
to filing this lawsuit, including your present address,
and the dates Plaintiff used each address.
Response:
INTERROGATORY NO. 2: State
the name, address and telephone number of each and every
person or entity having knowledge of relevant facts
in this case. This request in not limited to, but necessarily
includes, each and every person you may call as a witness
at trial.
Response:
INTERROGATORY NO. 3: Describe
your work history for the last (10) years, including
your present occupation and each past position or occupation,
and the name and address of each employer.
Response:
INTERROGATORY NO. 4: Does
the Plaintiff contend that Trans Union reported inaccurate
or obsolete information regarding Plaintiff to any person(s)
or entity(ies) other than plaintiff? If the answer is
yes, please identify the person(s) or entity(ies) to whom Trans Union reported such information,
the dates on which such information was reported, what
was inaccurate, and identify all documents which evidence,
refer or relate to these contentions.
Response:
INTERROGATORY NO. 5: State
the name, address, and telephone number of every person
or entity with which you have applied for credit, from
which you have received credit or which has otherwise
reviewed your credit report since January 1, 1999, and
for each person or entity identified state the type
of credit transaction involved, the terms of the credit,
the amount you sought to finance, and the disposition
or outcome of the credit transaction.
Response:
INTERROGATORY NO. 6: With
respect to each application or extension of credit identified
in response to the previous interrogatory, please state
whether you allege that any action and/or inaction of
Trans Union affected such application for or extension
of credit in any way. If so, please specify what
effect, if any, such action and/or inaction allegedly
had, including but not limited to, the denial
of credit, and increase or variance in the applicable
interest rate (and the amount of such increase, if any),
and any variance in any of the terms of the transaction.
Response:
INTERROGATORY NO. 7: Identify
and describe in detail each and every inaccuracy you
contend exists or ever existed in any consumer report
prepared by Trans Union relating to you. With regard
to each such alleged inaccuracy, state the date upon
which you first became aware of the alleged inaccuracy;
and how you became aware of it.
Response:
INTERROGATORY NO. 8: Identify
and describe all communications between you (or anyone
acting on your behalf) and Trans Union, including the
date of such communication, the method of each communication,
the names of all individuals participating in or
present during such communication, and a general statement
of the substance of the communication, and identify
all documents relating to each communication.
Response:
INTERROGATORY NO. 9: For
each item of monetary damages you claim to have suffered
because of some action or inaction on the part of Trans
Union, describe in detail the nature and amount of the
damages, when the damages were suffered, how the damages
were calculated, the facts supporting your claim that
the damages resulted from some action or inaction on
the part of Trans Union, and identify all documents
relating to any portion of your damage claims.
Response:
INTERROGATORY NO. 10: For
each legal proceeding to which you have been a party,
whether civil, criminal, bankruptcy or other proceedings,
state the style and case number of the proceeding, the
court in which the proceeding was or is pending, and
describe the nature of the proceeding and the outcome
of the proceeding.
Response:
INTERROGATORY NO. 11: Identify
any witness you may call at the time of trial to offer
expert testimony by stating the person's identity and
qualifications, the subject matter on which the person
is expected to testify, the mental impressions and opinions
held by the person, the grounds and basis for each impression
or opinion, and the facts and evidence in support of
or upon which the person relies and which form the basis
of the mental impressions and opinions held by the person.
Response:
INTERROGATORY NO. 12: State
the name, address and telephone number of each and every
medical or mental health practitioner, therapist, or
professional you have seen in the last ten years.
Response:
(Attached is the "verification"
for notarization)
|
