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DEFENDANT TRANS UNION LLC'S
FIRST
REQUEST FOR ADMISSION TO PLAINTIFF
To: Plaintiff Pro Se, Christine Baker,
(address deleted)
In accordance with Rule 36 of the Arizona
Rules of Civil Procedure, Defendant Trans Union LLC
("Trans Union") hereby serves upon Plaintiff
the following Requests for Admission. You are required
to serve responses to the following Requests for Admission
within (40) days of the date these Requests are received
by Plaintiff to Trans Union's counsel, Amanda Stamps
Lewis, Strasburger & Price, L.L.P., 901 Main Street,
Suite 4300, Dallas, Texas, 75202-3794
DEFINITIONS
For purposes of these Request for Production,
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.
REQUESTS FOR ADMISSION
REQUEST FOR ADMISSION NO. 1:
Admit that you sent one letter to Trans Union which
disputed various items on your Trans Union credit file.
RESPONSE:
REQUEST FOR ADMISSION NO. 2:
Admit that you sent the letter referenced in Request
for Admission No. 1 to Trans Union on August 10, 2001.
RESPONSE:
REQUEST FOR ADMISSION NO. 3:
Admit that in your letter, you did not provide your
social security number, nor was it provided on any enclosures.
RESPONSE:
REQUEST FOR ADMISSION NO. 4:
Admit that pursuant to the Fair Credit Reporting Act,
Trans Union has thirty (30) days to complete an investigation
into disputed items.
RESPONSE:
REQUEST FOR ADMISSION NO. 5:
Admit that you applied for credit cards with Capital
One Bank and Generations Bank prior to September 6,
2001.
RESPONSE:
REQUEST FOR ADMISSION NO. 6:
Admit that your Trans Union credit report reflects inquiries
by Capital One Bank and Generations Bank both on September
6, 2001
RESPONSE:
REQUEST FOR ADMISSION NO. 7:
Admit that you received a letter from Trans Union, dated
August 21, 2001, requesting a copy of your social security
card and driver's license.
RESPONSE:
REQUEST FOR ADMISSION NO. 8:
Admit that you never provided a copy of your social
security card or driver's license as requested by Trans
Union in its letter to you provided August 21, 2001.
RESPONSE:
REQUEST FOR ADMISSION NO. 9:
Admit that you filed for Chapter 7 bankrupcty
in May 1996 and were discharged in November 1996
RESPONSE:
REQUEST FOR ADMISSION NO. 10:
Admit that the following accounts were included in your
Chapter 7 bankruptcy: AFSCI #20448370261128, AFSCI #20452950260645,
ANBCC #4621200050384343, ANBCC #5436660021615277, Capital
One Bank #5291071313973289, First USA Bank/First Card
#4678093959475, First USA Bank/First Card #4678095615240,
Fleet#4071296782002893, Providian #4428000416001630,
Wells Fargo #5490960003901916
RESPONSE:
'REQUEST FOR ADMISSION NO. 11:
Admit that the above named companies did not collect
the full amount of money you owed them because you filed
and were discharged from Chapter 7 bankruptcy.
RESPONSE:
REQUEST FOR ADMISSION NO. 12:
Admit that some or all of the above named companies
were previously or are currently reported on your Trans
Union credit file.
RESPONSE:
REQUEST FOR ADMISSION NO. 13:
Admit that these accounts are accurately reflected on
your Trans Union credit file as included in bankruptcy.
RESPONSE:
REQUEST FOR ADMISSION NO. 14:
Admit that Generations Bank denied you credit due to
"delinquent past or present credit obligations."
RESPONSE:
Respectfully submitted,
Leslieann Haacke
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