DEFENDANTS’ NOTICE OF RELATED PROCEEDING AND JOINT MOTION REQUESTING

STATUS CONFERENCE PAGE 1 

IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF TEXAS 

SHERMAN DIVISION 

SEAN OWENS, § 

 § 

 Plaintiff, § 

 § 

v. § 

 § 

EXPERIAN INFORMATION § 

SOLUTIONS, INC., § 

 § Case No. 4:23-cv-00079-SDJ-KPJ 

EQUIFAX INFORMATION § 

SERVICES, LLC, § 

 § 

EDUCATIONAL CREDIT § 

MANAGEMENT CORPORATION § 

(agent of ECMC Group) § 

Defendants. 

§ 

§ 

DEFENDANTS’ NOTICE OF RELATED PROCEEDING AND JOINT MOTION 

REQUESTING STATUS CONFERENCE 

Defendants Experian Information Solutions, Inc., Equifax Information Services, LLC, and 

Educational Credit Management Corporation (collectively, the “Defendants”) hereby file this 

Notice of Related Proceeding and Joint Motion Requesting Status Conference. In support of this 

Motion, Defendants state that they seek to address the recent transfer of this action from the United 

States District Court for the Central District of California, and to discuss the impact Case No. 4:20-

cv-00665-SDJ-KPJ, a duplicative action previously filed by Plaintiff Sean Owens (“Plaintiff”) and 

pending before this Court, has on the disposition of the instant proceeding. 

Plaintiff initiated this action against Defendants in the Central District of California on 

August 29, 2022, in a case styled Sean Owens v. Experian Information Solutions, Inc. et al., Civil 

Action No. 8:22-cv-01601-FWS-JDW (the “California action”). Defendants filed a Joint Motion 

Case 4:23-cv-00079-SDJ-KPJ Document 41 Filed 02/23/23 Page 1 of 4 PageID #: 186
DEFENDANTS’ NOTICE OF RELATED PROCEEDING AND JOINT MOTION REQUESTING

STATUS CONFERENCE PAGE 2 

to Dismiss or, in the Alternative, Motion to Stay (“Joint Motion to Dismiss or Stay”) on the 

grounds that the California action was duplicative to an action previously filed by Plaintiff and 

pending in the Eastern District of Texas in a case styled Owens v. Trans Union, LLC, et al., Civil 

Action No. 4:20-cv-665-SDJ-KPJ (the “Texas Action”). See ECF No. 19. The Central District 

Court granted Defendants’ Motion to Dismiss or Stay on January 27, 2023, and Ordered that the 

duplicative California action be transferred to the United States District Court for the Eastern 

District of Texas. See ECF No. 32. The California action was, in fact, transferred and is now 

pending before this Court. See ECF No. 33.1 

Defendants believe that a status conference would most efficiently and effectively address 

the transfer and impact of Case No. 4:20-cv-665-SDJ-KPJ on the instant proceeding. For the 

reasons stated herein, the Parties respectfully request that the Court grant this Joint Motion 

Requesting Status Conference and in doing so, set a status conference at the Court’s earliest 

convenience. 

Respectfully submitted, 

/s/ Mark A. Platt 

MARK A. PLATT 

State Bar No. 00791453 

mplatt@fbtlaw.com 

SARAH M. SMITH 

Texas Bar No. 24115049 

E-mail: smsmith@fbtlaw.com 

 

1

 To avoid litigating two nearly identical actions in the same forum, Defendants filed a Joint Motion to Stay Action 

Pending Final Judgment in the Prior Related Action on February 10, 2023. See ECF No. 37. That Motion is 

pending before the Court. 

Case 4:23-cv-00079-SDJ-KPJ Document 41 Filed 02/23/23 Page 2 of 4 PageID #: 187
DEFENDANTS’ NOTICE OF RELATED PROCEEDING AND JOINT MOTION REQUESTING

STATUS CONFERENCE PAGE 3 

FROST BROWN TODD LLP 

Rosewood Court 

2101 Cedar Springs Road, Suite 900 

Dallas, Texas 75201 

(214) 580-5852 Telephone 

(214) 545-3473 Facsimile 

Attorneys For Defendant 

Educational Credit Management Corporation 

/s/ Forrest M. “Teo” Seger, III (with permission)

FORREST M. “TEO” SEGER, III 

Texas Bar No. 24070587 

teo.seger@clarkhillstrasburger.com

CLARK HILL STRASBURGER 

2301 Broadway 

San Antonio, TX 78215 

(210) 250-6162 

(210) 250-6100 Fax 

Counsel for Equifax Information Services LLC 

/s/ Julia N. Camp (with permission) 

JULIA N. CAMP 

Texas Bar No. 24123598 

juliacamp@jonesday.com 

JONES DAY 

717 Texas, Suite 3300 

Houston, TX 77002 

(832) 239-3939 

(832) 239-3600 Fax 

Counsel for Experian Information Solutions, Inc. 

Case 4:23-cv-00079-SDJ-KPJ Document 41 Filed 02/23/23 Page 3 of 4 PageID #: 188
DEFENDANTS’ NOTICE OF RELATED PROCEEDING AND JOINT MOTION REQUESTING

STATUS CONFERENCE PAGE 4 

CERTIFICATE OF CONFERENCE 

I hereby certify that on or about February 1, 2023, and on February 22, 2023, counsel for 

Defendants made efforts to confer with Plaintiff Sean Owens regarding the relief requested in this 

Motion, as demonstrated in the attached Exhibit A. Defendants did not receive a response from 

Mr. Owens regarding the relief requested. 

/s/ Mark A. Platt 

Mark A. Platt 

CERTIFICATE OF SERVICE 

This is to certify that a true and correct copy of the foregoing pleading has been furnished 

to Plaintiff and all parties of record via the CM/ECF system, and by first-class mail to the pro se

plaintiff on February 23, 2023, as follows: 

Sean Owens 

6009 W. Parker Rd., No. 299 

Plano, TX 75093 

(469) 522-3371 

Pro se Plaintiff 

Sean Owens 

1055 West 7th Street, 33rd Floor 

Los Angeles, California 90017 

(323) 412-8516 

Pro se Plaintiff 

/s/ Mark A. Platt 

Mark A. Platt 

0008587.0738502 4886-1815-9184v1 

Case 4:23-cv-00079-SDJ-KPJ Document 41 Filed 02/23/23 Page 4 of 4 PageID #: 189