IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF PENNSYLVANIA 

 

NADIA A. DEDICOVA-KENT ) 

 ) 

 Plaintiff, ) 

 vs. ) 

 ) Civil Action No. 04-1482 

EQUIFAX INFORMATION SERVICES, LLC ) 

 and ) 

EXPERIAN INFORMATION ) 

SOLUTIONS, INC. ) 

 and ) 

TRANS UNION, LLC ) 

 and ) 

MBNA AMERICA BANK, NA ) 

 ) 

 Defendants. ) 

 ) 

O R D E R

AND NOW, this day of , 2005, upon consideration of Plaintiff’s 

Motion to Compel the Deposition of a Corporate Representative of Defendant Trans Union, 

LLC, it is hereby ORDERED that the motion is GRANTED and that Defendant Trans Union, 

LLC shall produce a Corporate Representative to be deposed by Plaintiff within twenty (20) days 

of the date of this Order or risk further sanctions upon application to the Court. 

BY THE COURT: 

 

 Surrick, J. 

Case 2:04-cv-01482-RBS Document 33 Filed 06/15/05 Page 1 of 6
IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF PENNSYLVANIA 

 

NADIA A. DEDICOVA-KENT ) 

 ) 

 Plaintiff, ) 

 vs. ) 

 ) Civil Action No. 04-1482 

EQUIFAX INFORMATION SERVICES, LLC ) 

 and ) 

EXPERIAN INFORMATION ) 

SOLUTIONS, INC. ) 

 and ) 

TRANS UNION, LLC ) 

 and ) 

MBNA AMERICA BANK, NA ) 

 ) 

 Defendants. ) 

 ) 

PLAINTIFF NADIA A. DEDICOVA-KENT’S MOTION 

TO COMPEL THE DEPOSITION OF A CORPORATE 

REPRESENTATIVE OF DEFENDANT TRANS UNION, LLC

Plaintiff Nadia A. Dedicova-Kent, through her undersigned attorneys, hereby moves this 

Court to enter the accompanying order compelling Defendant Trans Union, LLC (“Trans 

Union”) to produce a corporate representative for deposition, and, in support thereof avers as 

follows: 

 1. This is an action for damages brought by an individual consumer against the 

Defendants for violations of the Fair Credit Reporting Act (hereafter the “FCRA”), 15 U.S.C. §§ 

1681 et seq., as amended, and various other laws of the Commonwealth of Pennsylvania, which 

was commenced by the filing of a Complaint on or about April 2, 2004, in the United States 

District Court For the Eastern District of Pennsylvania. 

Case 2:04-cv-01482-RBS Document 33 Filed 06/15/05 Page 2 of 6
 2. On or about March 11, 2005, Plaintiff sent a Notice of Deposition to defense 

counsel for Defendant Trans Union to produce a corporate representative for deposition. (A true 

and accurate copy of Plaintiff’s Notice of Deposition is attached hereto as Exhibit A). 

3. Plaintiff has requested that defense counsel produce a corporate representative for 

deposition on several occasions, both over the telephone and in writing. (See a true and accurate 

June 9, 2005 print out of an e-mail string between Plaintiff’s counsel and defense counsel 

attached hereto as Exhibit B). 

4. Defendant Trans Union has failed to produce a corporate representative prior to 

the close of discovery, despite its promises to do so. 

 5. Discovery is set to close today, June 15, 2005. Plaintiff will suffer hardship and 

prejudice as a result of Defendant Trans Union’s failure to produce a corporate representative for 

deposition. 

 6. Plaintiff has attempted in good faith to resolve this discovery dispute. Plaintiff’s 

Local Rule 26.1(f) Certification of Counsel is attached. 

 

Case 2:04-cv-01482-RBS Document 33 Filed 06/15/05 Page 3 of 6
WHEREFORE, based upon the foregoing, Plaintiff Nadia A. Dedicova-Kent respectfully 

requests that this Court enter the accompanying Order compelling the Defendant Trans Union to 

produce a corporate representative for deposition within twenty (20) days of the date of this 

Order or risk further sanctions upon application to the Court. 

RESPECTFULLY SUBMITTED,

FRANCIS & MAILMAN, P.C. 

 BY: _____________________________ 

 JAMES A. FRANCIS, ESQUIRE 

 MARK D. MAILMAN, ESQUIRE 

 JOHN SOUMILAS, ESQUIRE 

Attorney for Plaintiff 

 Land Title Building, 19th Floor 

 100 South Broad Street 

 Philadelphia, PA 19110 

 (215) 735-8600 

Dated: June 15, 2005 

Case 2:04-cv-01482-RBS Document 33 Filed 06/15/05 Page 4 of 6
IN THE UNITED STATES DISTRICT COURT 

 FOR THE EASTERN DISTRICT OF PENNSYLVANIA 

 

NADIA A. DEDICOVA-KENT ) 

 ) 

 Plaintiff, ) 

 vs. ) 

 ) Civil Action No. 04-1482 

EQUIFAX INFORMATION SERVICES, LLC ) 

 and ) 

EXPERIAN INFORMATION ) 

SOLUTIONS, INC. ) 

 and ) 

TRANS UNION, LLC ) 

 and ) 

MBNA AMERICA BANK, NA ) 

 ) 

 Defendants. ) 

 ) 

LOCAL RULE 26.1(f) CERTIFICATION OF COUNSEL

 The undersigned counsel of Plaintiff Nadia A. Dedicova-Kent hereby certify, pursuant to 

Local Rule 26.1(f), that they have attempted in good faith to resolve this discovery dispute, but 

have been unable to do so without court intervention. 

 

RESPECTFULLY SUBMITTED, 

 FRANCIS & MAILMAN, P.C. 

 BY:______________________________ 

 JAMES A. FRANCIS, ESQUIRE 

 MARK D. MAILMAN, ESQUIRE 

 JOHN SOUMILAS, ESQUIRE 

 Attorneys for Plaintiff 

 Land Title Building, 19th Floor 

 100 South Broad Street 

 Philadelphia, PA 19110 

 (215) 735-8600 

Dated: June 15, 2005 

Case 2:04-cv-01482-RBS Document 33 Filed 06/15/05 Page 5 of 6
CERTIFICATE OF SERVICE

I, John Soumilas, hereby certify that, on this date, I caused a true and correct copy of the 

foregoing Plaintiff’s Motion to Compel to be served by way of U.S. mail, first-class and postage 

pre-paid, upon the following: 

Bruce S. Luckman, Esquire 

Kogan, Trichon & Wertheimer, P.C. 

1818 Market Street, 30th Floor 

Philadelphia, PA 19103 

 Mark C. Cawley, Esquire 

Saul Ewing LLP 

1500 Market Street, 

Centre West Square, 38th Floor 

Philadelphia PA 19102 

 FRANCIS & MAILMAN, P.C.

 ____________________________ 

 JAMES A. FRANCIS, ESQUIRE 

MARK D. MAILMAN, ESQUIRE 

JOHN SOUMILAS, ESQUIRE 

 Attorneys for Plaintiff 

 Land Title Building, 19th Floor 

100 South Broad Street 

Philadelphia, PA 19110 

 (215) 735-8600 

DATE: June 15, 2005 

 

Case 2:04-cv-01482-RBS Document 33 Filed 06/15/05 Page 6 of 6