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Brief of respondent Sergio L Ramirez in - Proof of Service

Document TransUnion LLC, Petitioner v. Sergio L. Ramirez, 20-297, Brief of respondent Sergio L Ramirez in, Proof of Service (U.S. Nov. 6, 2020)
1, Andrew Cockle, of lawful age, being duly sworn, upon my oath state that I did, on the 6th day of November, 2020, send out from Omaha, NE 2 package(s) containing 3 copies of the RESPONDENT’S BRIEF IN OPPOSITION in the above entitled case.
All parties required to be served have been served by third-party commercial carrier for delivery within 3 calendar days.
Packages were plainly addressed to the following:
2510 Philadelphia, PA 19103 215—735-8600 jfrancis@consumerlawfirm.corn Counsel for Respondent Subscribed and sworn to before me this 6th day of November, 2020.
I am duly authorized under the laws of the State ofNebraska to administer oaths.
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Brief of respondent Sergio L Ramirez in

Document TransUnion LLC, Petitioner v. Sergio L. Ramirez, 20-297, Brief of respondent Sergio L Ramirez in (U.S. Nov. 6, 2020)
Although Petitioner strains to conjure up a cir- cuit conflict, there is none.
... alerts labeled consumers as SDNs with whom companies are prohibited by federal law from engaging in any business—and thus com- municate a much more consequential piece of infor- mation than a credit history—TransUnion took none ...
None of Petitioner’s six pre-trial motions in limine sought to preclude Ramirez from offering testimony about the consequences TransUnion’s inaccurate report had on his life, nor did Petitioner object to this testimony at trial.
Despite the “reprehensibility of TransUnion’s con- duct,” it nonetheless “conclude[d] that a ratio of 4 to 1 between the statutory and punitive damages is the most the Constitution permits on this record.” Id. Judge McKeown concurred in ...
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Brief amicus curiae of Consumer Data

Document TransUnion LLC, Petitioner v. Sergio L. Ramirez, 20-297, Brief amicus curiae of Consumer Data (U.S. Oct. 8, 2020)
To understand that Congress in § 1681e(b) did not seek to address the (nonexistent) harms that flow from a line of information merely sitting within a consumer’s credit file, recognizing the difference 10 between consumer “file” and ...
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Brief amicus curiae of The Chamber of - Main Document

Document TransUnion LLC, Petitioner v. Sergio L. Ramirez, 20-297, Brief amicus curiae of The Chamber of, Main Document (U.S. Oct. 8, 2020)
It nonetheless brushed aside these differences as irrelevant to typicality, saying all that mattered was “the class-wide theory of liability” and dismissing Ramirez’s unique injuries as at most “slightly more severe than some class members’ ...
7 Thus, in Doe, the Fourth Circuit held that the plaintiffs’ decision “to pursue only the $1,000 mini- mum statutory damages” did not eliminate their “grave typicality problems” because none of the named plaintiffs could show actual ...
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Brief amicus curiae of The Chamber of - Proof of Service

Document TransUnion LLC, Petitioner v. Sergio L. Ramirez, 20-297, Brief amicus curiae of The Chamber of, Proof of Service (U.S. Oct. 8, 2020)
No. 20-297 In the Supreme Court of the United States
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Brief amicus curiae of The Chamber of

Document TransUnion LLC, Petitioner v. Sergio L. Ramirez, 20-297, Brief amicus curiae of The Chamber of (U.S. Oct. 8, 2020)
It nonetheless brushed aside these differences as irrelevant to typicality, saying all that mattered was “the class-wide theory of liability” and dismissing Ramirez’s unique injuries as at most “slightly more severe than some class members’ ...
7 Thus, in Doe, the Fourth Circuit held that the plaintiffs’ decision “to pursue only the $1,000 mini- mum statutory damages” did not eliminate their “grave typicality problems” because none of the named plaintiffs could show actual ...
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Brief amicus curiae of Consumer Data - Proof of Service

Document TransUnion LLC, Petitioner v. Sergio L. Ramirez, 20-297, Brief amicus curiae of Consumer Data, Proof of Service (U.S. Oct. 8, 2020)
I, Marianna Iannotta, being duly sworn according to law and being over the age of 18, upon my oath depose and say that: I am retained by Counsel of Record for Amicus Curiae Consumer Data Industry Association.
by depositing three copies of same, addressed to each individual respectively, and enclosed in a post-paid, properly addressed wrapper, in an official depository maintained by the United States Postal Service, via Express Mail.
That on the same date as above, I sent to this Court forty bound copies and one unbound copy of the within Brief of Consumer Data Industry Association as Amicus Curiae Supporting Petitioner through the United States Postal Service by Express Mail, postage prepaid.
I declare under penalty of perjury that the foregoing is true and correct.
Notary Public State of New York No. 01MA6204360 Qualified in Queens County
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Brief amicus curiae of Consumer Data - Main Document

Document TransUnion LLC, Petitioner v. Sergio L. Ramirez, 20-297, Brief amicus curiae of Consumer Data, Main Document (U.S. Oct. 8, 2020)
To understand that Congress in § 1681e(b) did not seek to address the (nonexistent) harms that flow from a line of information merely sitting within a consumer’s credit file, recognizing the difference 10 between consumer “file” and ...
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Brief amicus curiae of Consumer Data - Certificate of Word Count

Document TransUnion LLC, Petitioner v. Sergio L. Ramirez, 20-297, Brief amicus curiae of Consumer Data, Certificate of Word Count (U.S. Oct. 8, 2020)
required by Supreme Court Rule 33.1(h), As I certify that the document contains 4,480 words, excluding the parts of the document that are exempted by Supreme Court Rule 33.1(d).
I declare under penalty of perjury that the foregoing is true and correct.
Executed on October 8, 2020
Sworn to and subscribed before me this 8th day of October, 2020.
Notary Public State of New York No. 01MA6204360 Qualified in Queens County Commission Expires Apr. 20, 2021
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Brief amicus curiae of The Chamber of - Certificate of Word Count

Document TransUnion LLC, Petitioner v. Sergio L. Ramirez, 20-297, Brief amicus curiae of The Chamber of, Certificate of Word Count (U.S. Oct. 8, 2020)
No. 20-297 In the Supreme Court of the United States
I, Andrew J. Pincus, counsel for Amicus Curiae and a member of the Bar of this Court, hereby certify that, according to the word-count tool in Microsoft Word, the Brief of the Chamber of Commerce of the United States of America as Amicus Curiae in Support of Petitioner consists of 4,139 words, including footnotes and excluding the sections enumerated by Rule 33.1(d).
The Brief therefore complies with Rule 33.1(g).
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Motion to extend the time to file a

Document TransUnion LLC, Petitioner v. Sergio L. Ramirez, 20-297, Motion to extend the time to file a (U.S. Sep. 30, 2020)
Re: TransUnion, LLC v. Ramirez, No. 20-297 Via Overnight Delivery Danny Bickell Deputy Clerk Supreme Court of the United States One First Street NE Washington, DC 20543
Dear Mr. Bickell: I am counsel for respondent in the above-referenced case.
On September 8, 2020, a certiorari petition was docketed in this case, and unless extended by the Court, the response would be due on October 8, 2020.
Pursuant to Rule 30.4 of the Rules of this Court, I respectfully request an extension of 29 days, to and including November 6, 2020.
Andrew J. Ogilvie Counsel for Respondent 3450 Sacramento St., #413 San Francisco, CA 94118 Tel.
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Motion to extend the time to file a - Main Document

Document TransUnion LLC, Petitioner v. Sergio L. Ramirez, 20-297, Motion to extend the time to file a, Main Document (U.S. Sep. 30, 2020)

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Petition for a writ of certiorari filed

Document TransUnion LLC, Petitioner v. Sergio L. Ramirez, 20-297, Petition for a writ of certiorari filed (U.S. Sep. 2, 2020)

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Petition for a writ of certiorari filed - Certificate of Word Count

Document TransUnion LLC, Petitioner v. Sergio L. Ramirez, 20-297, Petition for a writ of certiorari filed, Certificate of Word Count (U.S. Sep. 2, 2020)

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Petition for a writ of certiorari filed - Appendix

Document TransUnion LLC, Petitioner v. Sergio L. Ramirez, 20-297, Petition for a writ of certiorari filed, Appendix (U.S. Sep. 2, 2020)

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