THOMAS v. EQUIFAX INFORMATION SERVICES LLC

CourtDistrict Court, D. New Jersey
DecidedMarch 19, 2025
Docket2:23-cv-15724
StatusUnknown

This text of THOMAS v. EQUIFAX INFORMATION SERVICES LLC (THOMAS v. EQUIFAX INFORMATION SERVICES LLC) is published on Counsel Stack Legal Research, covering District Court, D. New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
THOMAS v. EQUIFAX INFORMATION SERVICES LLC, (D.N.J. 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

: BABACAR THOMAS, :

: Civil Action No. 23-15724 (JXN) Plaintiff, :

: v. : OPINION & ORDER EQUIFAX INFORMATION SERVICES : LLC, et al., : : Defendants.

CLARK, Magistrate Judge

THIS MATTER comes before the Court on a motion by Defendants Trans Union LLC (“Trans Union”) and Experian Information Solutions, Inc. (“Experian”) (collectively, “Defendants”) seeking an award of Rule 37 sanctions and attorneys’ fees against pro se Plaintiff Babacar Thomas (“Plaintiff”). See Dkt. Nos. 62, 64.1 Plaintiff filed two responses in opposition [Dkt. Nos. 65, 67], and a supplemental brief in opposition [Dkt. No. 71]. Trans Union replied [Dkt. No. 70]. For the reasons set forth below, Defendants’ motion for Rule 37 sanctions [Dkt. No. 62] is GRANTED in part and DENIED in part. I. BACKGROUND Plaintiff filed a Complaint in this action on September 1, 2023. Dkt. No. 1. Generally, Plaintiff alleges that Defendants Equifax Information Services LLC (“Equifax”), Experian Information Solutions, Inc. (“Experian”), and Transunion LLC (“Trans Union”) (collectively, “Defendants”) published false and damaging information to his credit report following his Chapter 7 bankruptcy declaration in December of 2022. Accordingly, Plaintiff seeks related relief under

1 Experian joins in Trans Union’s motion. See Dkt. No. 64. the Fair Credit Reporting Act (“FCRA”), 15 U.S.C. § 1681 et seq. See id. ¶¶ 20-27. Several months after filing for bankruptcy, Plaintiff obtained copies of his consumer credit report from Defendants. Id. ¶ 22. After receiving and reviewing those reports, Plaintiff concluded that Defendants “inaccurately” reported his bankruptcy declaration and credit accounts because they allegedly “failed to report that [Plaintiff’s] bankruptcy discharge relieved [him] of personal

liability on his discharged debts.” Id. ¶ 24. In other words, Plaintiff alleges that, rather than noting his credit accounts as discharged in bankruptcy, Defendants reported certain credit accounts as “charged off” and thereby negatively impacted Plaintiff’s creditworthiness. Id. ¶ 26. Plaintiff claims that, on or about May 23, 2023, he filed disputes with Defendants concerning the “inaccurate information” on his credit report. Id. ¶ 27. After receiving “unsatisfactory investigation results,” Plaintiff sent a second set of dispute letters to Defendants on or around June 13, 2023. Id. ¶ 32. On July 5, 2023, Plaintiff sent a third dispute letter to Trans Union and threatened legal action. Id. ¶ 35. On August 17, 2023, Plaintiff sent “final” dispute letters to Defendants for their alleged failure to remove Plaintiff’s “unverified accounts” from his

credit report. Thereafter, Plaintiff filed this action. Id. ¶ 38. Equifax was voluntarily dismissed from the case on October 5, 2023. Dkt. No. 9. Experian and Trans Union each filed an Answer to Plaintiff’s Complaint on November 13, 2023, largely denying the allegations and raising a number of affirmative defenses. See Dkt. Nos. 15, 16. Specifically, Defendants contend that Plaintiff’s claims are “meritless” and “false[].” Dkt. No. 37 at p. 3. “In fact,” Trans Union contends, “Trans Union reported Plaintiff’s bankruptcy as discharged and paid as of November 1, 2022 and all of Plaintiff’s charged off accounts were updated to ‘included in bankruptcy’ as of that date.” Id. Fact discovery was originally set to conclude on August 30, 2024. Dkt. No. 29 at ¶ 2. On April 1, 2024, Plaintiff filed his first motion to compel, seeking Trans Union’s responses to his initial written discovery requests. Dkt. No. 30 at 3-4. Plaintiff argued that Trans Union’s responses to his interrogatories “consist[ed] of boilerplate objections” and lacked “substantive information and documents” and were made in an attempt to “obstruct” his case. Id. Trans Union responded and asserted (and still does nearly one year later) that the documents produced by it establish that

Plaintiff’s credit information was not improperly reported and that, in any event, Plaintiff’s motion to compel was made in contravention of the Local Civil Rules. See Dkt. No. 31 at p. 1. On May 13, 2024, Trans Union filed a letter with the Court outlining its various discovery disputes with Plaintiff. See Dkt. No. 33. In its letter, Trans Union noted Plaintiff’s “refusal to respond to Trans Union’s written discovery requests . . . which were due on April 1, 2024.” Id. at p. 1. Moreover, Plaintiff apparently “w[ould] not appear for his deposition properly noticed for June 4, 2024 and [] refused to provide another date to be deposed.” Id. The next day, the Court conducted a telephone status conference with the parties. During the May 14, 2024 conference, the Court administratively terminated Plaintiff’s motion to compel

for his failure to raise his discovery disputes with the Court in the first instance. Dkt. No. 34; see also Dkt. No. 29 ¶ 7 (“No motion to compel discovery . . . shall be entertained unless a letter outlining the dispute is submitted[.]”). The Court directed the parties to meet and confer regarding their discovery disputes and mandated responses to any outstanding discovery requests by May 28, 2024. Dkt. No. 34. However, if issues remained, the parties were to submit a joint discovery disputes letter to the Court by June 6, 2024. Id. Three days later, Plaintiff filed a letter accusing Trans Union of “improper[ly] and unethical[ly]” communicating with the Court and admonishing it for “disregard[ing]” Plaintiff’s “pending” motion to compel, which had been terminated by the Court during the May 14, 2024 telephone conference. See Dkt. No. 36. Trans Union’s conduct, Plaintiff argued, demonstrates its “neglect[] [of] its discovery duties” and “hinder[ance]” of this case. Id. at 2. On June 6, 2024, Trans Union filed a letter informing the Court that “Plaintiff has refused to conduct a meet and confer by telephone” regarding the parties’ discovery disputes. Dkt. No. 37 at 1; see also Dkt. No. 39 at 15 (Plaintiff “carefully considered [Trans Union’s] proposal for a

phone call to discuss . . . outstanding discovery obligations,” but declined, believing it in the “best interests of all parties to keep [] communications in writing.”). Plaintiff also failed to serve his responses to Trans Union’s discovery requests by May 28, 2024. Dkt. No. 37; see Dkt. No. 34. In turn, Trans Union sought an order compelling Plaintiff to appear for his deposition. Id. Notably, Plaintiff had already expressed a refusal to attend his properly noticed deposition scheduled on June 4, 2024. Id. Trans Union rescheduled Plaintiff’s deposition for June 25, 2024, but Plaintiff again “refused” to appear and stated that “[he] will not be able to appear for a deposition until Trans Union has provided the outstanding discovery [he] [] requested.” Id. On June 11, 2024, Plaintiff failed to appear for a scheduled telephone conference. Dkt. No.

38. The same day, Plaintiff filed a letter claiming that he had served responses to Defendants’ written discovery requests on June 1, 2024. Dkt. No. 39. But Plaintiff had, several days after the deadline for written discovery responses, mailed his responses to counsel for Trans Union’s incorrect address (to counsel for Trans Union’s Texas, rather than Indianapolis, office). Id. at 1. Plaintiff further asserted that “the main problem remains the [D]efendants’ own failure to provide the discovery I have legitimately requested.” Id. at 2.

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THOMAS v. EQUIFAX INFORMATION SERVICES LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/thomas-v-equifax-information-services-llc-njd-2025.