Dunstan et al v. comScore, Inc.

Filing 102

MOTION by Defendant comScore, Inc. to compel Plaintiffs to Produce Documents and Things (Bowland, Robyn)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
MIKE HARRIS and JEFF DUNSTAN,
individually and on behalf of a class of similarly
CASE NO. 1:11-cv-5807
situated individuals
Judge Holderman
Plaintiff,
Magistrate Judge Kim
v.
COMSCORE, INC., a Delaware corporation
Defendant.

COMSCORE'S MOTION TO COMPEL PLAINTIFFS TO PRODUCE
DOCUMENTS AND THINGS
Pursuant to Rule 37(a) of the Federal Rules of Civil Procedure, comScore, Inc.
("comScore") respectfully moves this Court to compel Plaintiffs Mike Harris and Jeff Dunstan
("Plaintiffs") to produce documents and things in response to comScore's First Set of Requests
for Production of Documents. comScore seeks an order compelling Plaintiffs to produce for
inspection the computer or computers that Plaintiffs contend were affected by comScore
software. In support thereof, comScore submits the accompanying Memorandum and exhibits
thereto. This motion is made after counsel for comScore and Plaintiffs' counsel engaged in a
meet and confer teleconference on April 25, 2012 at 2:00 P.M. and after the parties exchanged
correspondence. Despite comScore's good faith attempt to obtain Plaintiffs' outstanding
production without recourse to this Court, it has been unable to do so.

4734825_1.DOC

DATED: May 4, 2012

QUINN EMANUEL URQUHART &
SULLIVAN, LLP

_/s/ Andrew H. Schapiro____
Andrew H. Schapiro
[e-mail]
Stephen Swedlow
[e-mail]
Robyn Bowland
[e-mail]
QUINN EMANUEL URQUHART &
SULLIVAN, LLP
500 West Madison Street, Suite 2450
Chicago, Illinois 60661
Telephone: [phone]
Facsimile: [phone]
Paul F. Stack
[e-mail]
Mark William Wallin
[e-mail]
Stack & O'Connor Chartered
140 South Dearborn Street
Suite 411
Chicago, IL 60603
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant comScore, Inc.

4734825_1.DOC