Specifically, it states that "an objective standard is used to assess whether a credit reporting agency has in place and followed reasonable procedures to assure that its credit reports achieve maximum possible accuracy." Id. at 24 (quoting Villaflor v. Equifax Info., No. C-09-00329 MMC, 2010 WL 2891627, at *1 (N.D. Cal. July 22, 2010) (internal quotation marks omitted). Accordingly, the reasonableness of the procedures used by CoreLogic must be assessed by reference to the procedures themselves, which are what define the relevant inquiry, and not any internal commentary on those procedures.
Courts in this district have followed the demanding three-factor test laid out in Shelton, but most of those courts have encountered the issue when a party seeks to depose opposing counsel about the pending case, and thus did not have to consider a scenario like the one presented in Pamida. See, e.g., Chao, 2012 WL 5988617 at *1 (defendant sought to depose plaintiff's counsel); Villaflor v. Equifax Info., No. C-09-00329 MMC, 2010 WL 2891627, at *1 (N.D. Cal. July 22, 2010) (same); M.A. Mobile Ltd. v. Indian Inst. of Tech. Kharagpur, No. C-08-02658-RMW, 2014 WL 819161, at *1 (N.D. Cal. Feb. 28, 2014) (plaintiffs' sought to depose defendants' counsel); AWGI, LLC v. Duncan & Elbaz, Inc., No. C10-01529 HRL, 2010 WL 4595158, at *1 (N.D. Cal. Nov. 3, 2010) (same). In its own research, the court could locate only one case within this district considering the issue of a deposition of counsel who represented the opposing party in the present case and had also represented that party in a different, concluded matter.