Caution:  I used OCR software instead of transcribing.  Please e-mail if you find anything that doesn't make sense.

 IN THE JUSTICE COURT OF MOHAVE COUNTY
524 West Beale Street/ PO Box 29
Kingman, AZ 86402
Phone (928) 753-0710 Fax (928) 753-7840

Christine Baker
(address deleted)

        Plaintiff                                                     Case No. 801 2001 CV 1751 UN

V.

Trans Union LLC
Renaud Cook & Drury - Attorney
Two Renaissance Square
40 North Central Avenue # 1600
Phoenix, AZ 85004
        Defendant

DEFENDANT TRANS UNION LLC'S
RULE 26.1 INITIAL DISCLOSURE

Trans Union LLC ("Trans Union") hereby makes its Initial Disclosures pursuant to 16 A.R.S. Rules of Civil Procedure, Rule 26.1.

(A)     The factual basis of the claim or defense.

Trans Union responded to Christine Baker's ("Plaintiff") dispute letter of August 2001 by requesting a copy of her driver's license and social security card because an additional file was coming up when hername and address were entered to access her credit file. Plaintiff never responded to this request.

(B)     The legal theory upon which each claim or defense is based.

Trans Union acted in compliance with the Fair Credit Reporting Act in its handling of Plaintiffs contacts with Trans Union and her credit file.

(C)     The names, address, and telephone numbers of any witnesses expected tobe called at trial with a fair description of the substance of each witness' expected testimony.

Trans Union has not identified its witnesses who may be called at trial.

(D)     The names and addresses of all persons who may have knowledge or information relevant to the events, transactions, or occurrences that gave rise to the action, and the nature of the knowledge or information each such individual is believed to possess.

1. Christine Baker
   (address/phone deleted)

Christine Baker is the Plaintiff in this matter and is believed to have knowledge
of the facts relating to the allegations made in this case, her dealings with creditors, her dealings with Trans Union, and her alleged damages.

2. Diane A. Terry
   Consumer Relations Center
   Trans Union LLC
   1561 E. Orangethorpe Avenue
   Fullerton, CA 92831
   (714) 738-3800

Consumer relations center director has knowledge of contacts between Plaintiff
and Trans Union and consumer relations procedures utilized involving Plaintiff.

3. Emily Gutierrez
   Consumer Relations Center
   Trans Union LLC
   1561 E. Orangethorpe Avenue
   Fullerton, CA 92831
   (714) 738-3800

Consumer relations priority processing investigator has knowledge of contacts between Plaintiff and Trans Union and consumer relations procedures utilized involving Plaintiff.

4. Juzper Pascual
   Consumer Relations Center
   Trans Union LLC
   1561 E. Orangethorpe Avenue
   Fullerton, CA 92831
   (714) 738-3800

Consumer relations consumer contact representative has knowledge of contact between Plaintiff and Trans Union and consumer relations procedures utilized involving Plaintiff.

5. Annette Perez
   Consumer Relations Center
   Trans Union LLC
   1561 E. Orangethorpe Avenue
   Fullerton, CA 92831
   (714) 738-3800

Consumer relations associate contact representative has knowledge of contact between Plaintiff and Trans Union and consumer relations procedures utilized involving Plaintiff.

6. Fabi Clelland
   Consumer Relations Center
   Trans Union LLC
   1561 E. Orangethorpe Avenue
   Fullerton, CA 92831
   (714) 738-3800

Consumer relations consumer contact representative has knowledge of contact between Plaintiff and Trans Union and consumer relations procedures utilized involving Plaintiff.

7. Sheila Hicks
   Address and phone number unknown

Former consumer relations terminal operator has knowledge of contact between Plaintiff and Trans Union and consumer relations procedures utilized involving Plaintiff. Ms. Hicks is no longer employed with Trans Union.

8. Plaintiff's present and former creditors are believed to have knowledge regarding Plaintiffs accounts, Plaintiffs payment history and any communications or correspondence between Plaintiff and her creditors. The names, addresses and telephone numbers, if known, of Plaintiffs creditors are contained in the document being produced by Trans Union labeled TU00001 - TU00005.

9. The persons and entities with whom Plaintiff has applied for credit are believed to have knowledge regarding Plaintiffs applications, Plaintiffs credit history, the reasons Plaintiff was granted or denied credit, and any communications or correspondence between them and Plaintiff. The names, addresses and telephone numbers, if known, of the persons and entities with whom Plaintiff has applied for credit are contained in the document being produced by Trans Union labeled TU00001 TU00005.

10. The persons and entities who have reviewed Plaintiffs credit reports are believed to have knowledge regarding their communications and correspondence with Plaintiff, the reasons that they reviewed Plaintiffs credit reports and the contents of Plaintiffs credit reports. The names, addresses and telephone numbers, if known, of the persons and entities who have reviewed Plaintiffs credit reports are contained in the document being produced by Trans Union labeled TU00001 - TU00005.

(E)     The names and addresses of all persons who have given statements, whether written or recorded, signed or unsigned, and the custodian of the copies of those statements.

        Trans Union has not obtained any written or recorded statements at this time.

(F)     The name and address of each person whom the disclosing party expects to call as an expert witness at trial, the subject matter on which the expert is expected to testify, the substance of the facts and opinions to which the expert is expected to testify, a summary of the grounds for each opinion, the qualifications of the witness and the name and address of the custodian of copies of any reports prepared by the expert.

        Trans Union has not identified who its expert witnesses will be, if any, at trial.

(G)     A computation and the measure of damage alleged and the documents or testimony on which such computation and measure are based and the names, addresses, and telephone numbers of all damage witnesses.

Trans Union is not claiming any damages against Plaintiff at this time.

(H)     The existence, location, custodian, and general description of any tangible evidence or relevant documents that the disclosing party plans to use at trial and relevant insurance agreements.

        Trans Union is providing a copy of its Consumer Relations file for Christine Baker labeled TU00006 - TU00116. Some or all of these documents may be used at trial.

(I)     A list of the documents or, in the case of voluminous documentary information, a list of the categories of documents, known by a party to exist whether or not in the party's possession, custody or control and which that party believes may be relevant to the subject matter of the action and those which appear reasonably calculated to lead to the discovery of admissible evidence, and the date(s) upon which those documents will be made, or have been made, available for inspection and copying.

        Trans Union objects to producing any documents which are protected by the attorney-client, work product, and investigative privileges. All documents protected by these privileges have been withheld from production. Specifically, Trans Union has withheld from production correspondence between Trans Union employees and its counsel, a summary of the case prepared by a Trans Union employee for Trans Union's counsel after the anticipation of litigation, and communications between Trans Union employees regarding the subject matter of this suit. Trans Union further objects to producing documents which contain information that is confidential and proprietary to Trans Union and/or contain Trans Union's trade secrets. Specifically, Trans Union has withheld from production certain policy and procedure documents which contain confidential and proprietary information relating to Trans Union and its trade secrets. Trans Union further objects to producing documents which contain information that is confidential and proprietary to third parties or consumers.

Subject to and without waiving the foregoing objections, Trans Union is providing a copy of its Consumer Relations file for Christine Baker labeled TUO0006 - TUO01 16. The only other documents that may be relevant to the subject matter of the action are Christine Baker's records and the records of the creditor(s) who allegedly denied her credit.

Dated this 31 st day of January, 2002.

Respectfully submitted,

(signed "Amanda Stamps Lewis")

LESLI ANNE HAACKE
Arizona State Bar No. 012734
RENAUD COOK & DRURY, P.A.
Two Renaissance Square
40 North Central, Suite 1600
Phoenix, AZ 85004

PAULL.MYERS
Texas State Bar No. 14765100
AMANDA LEWIS
Texas State Bar No. 24013553
STRASBURGER & PRICE, L.L.P.
901 Main Street, Suite 4300
Dallas, Texas 75202-3794
(214) 651-4300
(214) 651-4300 (fax)

ATTORNEYS FOR DEFENDANT
TRANS UNION LLC

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct of the foregoing has been sent to the following via certified mail, return receipt requested, this 31 st day of January, 2002.  (Not an OCR error, this is how it was sent.)

Christine Baker
(address deleted)
Pro Se Plaintiff

AMANDA LEWIS