Dunstan et al v. comScore, Inc.

Filing 107

STIPULATION to Allow Defendant Comscore, Inc. to Withdraw comScore's Motion to Compel Without Prejudice (Scharg, Ari) (Docket Text modified by Clerks' Office.)

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 situated individuals,

Case No. 1:11-5807

Plaintiffs,

Mag. Young B. Kim

v.
COMSCORE, INC., a Delaware corporation,
Defendant.
STIPULATION TO ALLOW DEFENDANT COMSCORE, INC.
TO WITHDRAW ITS MOTION TO COMPEL WITHOUT PREJUDICE
Plaintiff Mike Harris and Jeff Dunstan (“Plaintiffs”) and Defendant comScore, Inc.
(“comScore”) (collectively, the “Parties”), by and through their undersigned counsel, hereby
stipulate and agree to allow Defendant to withdraw its pending Motion to Compel (Dkt. No. 103)
without prejudice. In support of the instant stipulation, the Parties state as follows:
WHEREAS, on May 4, 2012, Defendant filed a Motion to Compel, which sought the
production of Plaintiffs’ computers. (Dkt. No. 103);
WHEREAS, since the filing of that motion, the Parties have reached an agreement on
certain issues raised by the Motion to Compel and are endeavoring to come to agreement on the
remaining issues;
WHEREAS, in order to conserve the resources of the Parties and the Court, Plaintiffs
have agreed to allow comScore to withdraw its pending Motion to Compel without prejudice and
further agree that, if comScore ultimately decides to re-file its Motion to Compel the production
of Plaintiffs’ computers, Plaintiffs will not raise an objection based upon timeliness.
NOW THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and between

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the Parties as follows:
1.

Defendant comScore, Inc.’s pending Motion to Compel is withdrawn without

prejudice.
2.

In the event comScore re-files its Motion to Compel the production of Plaintiffs'

computers, Plaintiffs agree to not raise an objection based on timeliness.
Respectfully submitted,
Dated: May 18, 2012

MIKE HARRIS AND JEFF DUNSTAN,
By: /s/ Ari J. Scharg
One of Plaintiffs’ Attorneys
Jay Edelson
Rafey S. Balabanian
Ari J. Scharg
Chandler R. Givens
EDELSON MCGUIRE LLC
350 North LaSalle, Suite 1300
Chicago, Illinois 60654
Tel: [phone]
[e-mail]
[e-mail]
[e-mail]
[e-mail]

Dated: May 18, 2012

COMSCORE, INC.
By: /s/ Stephen Swedlow
One of Defendant’s Attorneys
Stephen Swedlow
Andrew H. Schapiro
Amanda Williamson
Robyn Bowland
Quinn Emanuel Urquhart & Sullivan, LLP
500 West Madison St., Suite 2450
Chicago, Illinois 60661
[e-mail]
[e-mail]
[e-mail]
[e-mail]
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Paul F. Stack
Mark William Wallin
Stack & O'Connor Chartered
140 South Dearborn Street
Suite 411
Chicago, IL 60603
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

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