Dunstan et al v. comScore, Inc.

Filing 176

DECLARATION of Robyn Bowland regarding memorandum in opposition to motion 175 (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Errata J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16 Exhibit P, # 17 Exhibit Q, # 18 Exhibit R, # 19 Exhibit S, # 20 Exhibit T, # 21 Exhibit U, # 22 Exhibit V, # 23 Exhibit W)(Bowland, Robyn)

Download PDF
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-cv-5807 Plaintiff, Chief Judge Holderman v. Magistrate Judge Kim COMSCORE, INC., a Delaware corporation Defendant. DECLARATION OF ROBYN BOWLAND I, Robyn Bowland, hereby declare and state based upon my personal knowledge as follows: 1. I am an attorney at the law firm of Quinn Emanuel Urquhart & Sullivan LLP. I am admitted to practice law in the state of Illinois and represent comScore, Inc. (“comScore”) in the above-titled action. This declaration is based on my personal knowledge, except where expressly noted otherwise. 2. A true and correct copy of a website entitled “comScore Fact Sheet – comScore, Inc.” available at http:www.comscore.com/About_comScore/comScore_Fact_Sheet, accessed on February 25, 2013, is attached as Exhibit A to this Declaration. 3. A true and correct copy of the Expert Witness Report of Colin O’Malley, dated November 30, 2012, is attached as Exhibit B to this Declaration. 4. A true and correct copy of excepts of the deposition transcript of Michael Brown, dated August 15, 2012, is attached as Exhibit C to this Declaration. 99999.77815/5189084.1 5. A true and correct copy of the Expert Witness Report of Roberto Tamassia, dated November 30, 2012, is attached as Exhibit D to this Declaration. 6. A true and correct copy of CS0016873, an Excel spreadsheet produced by comScore in this case, is attached as Exhibit E to this Declaration. 7. A true and correct copy of excerpts of the deposition transcript of Colin O’Malley, dated December 13, 2012, is attached as Exhibit F to this Declaration. 8. A true and correct copy of excepts of the deposition transcript of Roberto Tamassia, dated December 14, 2012, is attached as Exhibit G to this Declaration. 9. A true and correct copy of comScore’s Second Supplemental Responses to Plaintiff Harris’s First Set of Interrogatories, dated May 24, 2012, is attached as Exhibit H to this Declaration. 10. A true and correct copy of excerpts of comScore’s Responses to Plaintiff Harris’s First Set of Interrogatories, dated March 23, 2012, is attached as Exhibit I to this Declaration. 11. A true and correct copy of comScore’s Fourth Supplemental Responses to Plaintiff Harris’s First Set of Interrogatories, dated September 14, 2012, is attached as Exhibit J to this Declaration. 12. A true and correct copy of excerpts of the deposition transcript of Don Waldhalm, dated October 25, 2012, is attached as Exhibit K to this Declaration. 13. A true and correct copy of excerpts of the deposition transcript of Yvonne Bigbee, dated September 12, 2012, is attached as Exhibit L to this Declaration. 14. A true and correct copy of excerpts of the deposition transcript of Randall L. McCaskill, dated September 14, 2012, is attached as Exhibit M to this Declaration. 2 15. A true and correct copy of excerpts of the deposition transcript of Michiko A. Chand, dated September 13, 2012, is attached as Exhibit N to this Declaration. 16. A true and correct copy of excerpts of Plaintiff Mike Harris’s Responses to Defendant comScore’s First Set of Interrogatories, dated April 9, 2012, is attached as Exhibit O to this Declaration. 17. A true and correct copy of excerpts of the deposition transcript of Michael J. Harris, dated July 13, 2012, is attached as Exhibit P to this Declaration. 18. A true and correct copy of Exhibit 6 used during the deposition of Michael J. Harris on July 13, 2012, is attached as Exhibit Q to this Declaration. 19. A true and correct copy of the Declaration of Michael Brown, dated February 26, 2013, is attached as Exhibit R to this Declaration. 20. A true and correct copy of excerpts of Plaintiff Jeff Dunstan’s Responses to Defendant comScore’s First Set of Interrogatories, dated April 9, 2012, is attached as Exhibit S to this Declaration. 21. A true and correct copy of excerpts of Plaintiff Jeff Dunstan’s First Supplemental Responses to Defendant comScore’s First Set of Interrogatories is attached as Exhibit T to this Declaration. 22. A true and correct copy of Harris-Dunstan 0632-0655, an anti-virus log produced by Plaintiff Jeff Dunstan in this case, is attached as Exhibit U to this Declaration. 23. A true and correct copy of excerpts of the deposition transcript of Jeffrey Dunstan, deposed August 8, 2012, is attached as Exhibit V to this Declaration. 3

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?