Free Motion for Leave to File - District Court of Connecticut - Connecticut

Case 3:03-cv-00253-JBA

Document 64

Filed 01/15/2004

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UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT WILLIAM SPECTOR v. EQUIFAX INFORMATION SERVICES, LLC CASE NO. 3:03CV 253 (JBA) January 15, 2004

PLAINTIFF'S MOTION FOR LEAVE TO FILE SUPPLEMENTAL OBJECTION TO MAGISTRATE JUDGE'S ORDERS Plaintiff respectfully moves to supplement his objections (Doc. Nos. 42-43) to the Magistrate Judge'Protective Order and Ruling on Papers Filed Under Seal. Equifax has s now disclaimed the documents entitled " Report," New Litigation," Closed VIP " " Litigation," New Demands," " " and Closed Demands." attached letter. Although See Equifax has repeatedly stated that it has policies and procedures in place for the offline procedures at issue herein, the named documents are not they. Accordingly, Equifax has retreated from its basis for confidentiality and a protective order as to those documents, and plaintiff should be allowed to use them normally, including as full, open exhibits herein.

THE PLAINTIFF

BY____/s/ Joanne S. Faulkner JOANNE S. FAULKNER ct04137 123 Avon Street New Haven, CT 06511-2422 (203) 772-0395 [email protected]

Case 3:03-cv-00253-JBA

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Suite 2800 1100 Peachtree St. Atlanta GA 30309-4530 t 404 815 6500 f 404 815 6555 www.KilpatrickStockton.com

January 9, 2003 VIA REGULAR MAIL AND E-MAIL

direct dial 404 815 6224 [email protected]

Joanne S. Faulkner, Esq. 123 Avon Street New Haven, Connecticut 06511
Re: Dear Joanne: As you know, among the hundreds of pages of documents produced by Equifax in this litigation were five pages entitled " Report"" VIP , New Litigation"" , Closed Litigation"" , New Demands" and " Closed Demands."After further investigation and discussion with Equifax, we have learned that those documents themselves are not a part of Equifax'manuals, do not contain current procedures or policies, s and never have. Instead, they were based on handwritten notes made by one of Equifax'employees, s Lanette Fullwood, many years ago. They were never intended to be a complete and accurate description of Equifax'policies and procedures with respect to litigation and have never been distributed to employees or s used as such in training employees. To the extent that Equifax has stated anything to the contrary in this case, we regret the error, and such statements are withdrawn. Further, since these are not a part of Equifax'manuals, we request that you return them to us s immediately. Very truly yours, William Spector v. Equifax Information Services, LLC, et al.

J. Anthony Love JAL:

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Case 3:03-cv-00253-JBA

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This is to certify that the foregoing was mailed on January 14, 2004, postage prepaid, to:

J. Anthony Love Kilpatrick Stockton 1100 Peachtree St #2800 Atlanta GA 30309-4530 ___/s/ Joanne S. Faulkner Joanne S. Faulkner

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