Quite frankly, I don't understand this response at all.
They're not disputing any of my claims, most of the Response is the same as their Motion, what am I missing?
I'm thrilled to see that apparently the 1/5/01 Carla Blair deposition, (my Exhibit O) IS legit, since they didn't dispute the authenticity. It's always a little strange to get those documents from anonymous sources.
And it is almost funny that I faxed my request for termination of access of ConsumerInfo.com (my Exhibit P) to the Experian database to NCO Legal instead of Experian's attorneys. Of course I didn't find out about it because NCO Legal doesn't respond to any faxes, whether for them or someone else, just LIKE Experian!
And fortunately, it is immaterial. I felt really weird about sending that fax to Experian - obviously they already KNEW about the non compliance of the ConsumerInfo.com tri-merged reports from my previous filings and my credit reports attached as exhibits to those filings.
I am just amazed that they can't come with ANY defense other than technicalities such as that I filed my response late.
Anybody with just *some* legal skills ought to be able to put Craig Smith in PRISON - they have done NOTHING to make the reports FCRA compliant and still sell the snake oil scores!
