Agalar Aliev v. Trans Union, LLC

Summary

The United States District Court for the Eastern District of Virginia resolves the remaining privilege-designation issue in Plaintiff Agalar Aliev’s motion to compel discovery from Trans Union, LLC in a Fair Credit Reporting Act action. The court holds that most of Trans Union’s redactions, including those covering a credit-file summary, reason codes, and remaining documents, are not protected work product, while sustaining limited designations for potentially attorney-client communications. Trans Union is ordered to produce unredacted versions of specified pages by January 30, 2026.

Holdings

1. Trans Union's redactions to the summary report were not protected opinion work product because they did not reveal counsel's selection of particular documents from a larger universe; instead, the report showed that counsel requested production of the plaintiff's entire credit file.
2. The court sustained the privilege designations for specified redactions on pages TU 00003 and TU 00005 because the materials may relate to attorney-client communications, but overruled the designation for page TU 00004 because Trans Union provided no rationale for redacting the summary report or audit trail.
3. Reason codes explaining why Trans Union printed documents from Aliev's credit file were not protected work product.
4. Trans Union failed to establish privilege or work-product protection for the remaining documents and was required to produce unredacted versions.

Questions Presented

1. Whether Trans Union's redactions to the summary report constituted protected opinion work product because they identified documents counsel directed personnel to collect or print.
2. Whether the redacted comments were protected by the attorney-client privilege or work-product doctrine.
3. Whether reason codes explaining why documents were printed constituted protected work product.
4. Whether Trans Union established privilege or work-product protection for the remaining entirely redacted documents.

Disposition

other