Dunstan et al v. comScore, Inc.

Filing 214

SUPPLEMENT to status report 212 (Balabanian, Rafey)

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,
Plaintiffs,
v.

Case No. 1:11-cv-05807
Hon. James F. Holderman
Magistrate Judge Young B. Kim

COMSCORE, INC., a Delaware corporation,
Defendant.
PLAINTIFFS’ SUPPLEMENTAL STATUS REPORT
Plaintiffs Mike Harris and Jeff Dunstan (collectively, “Plaintiffs”) hereby submit this
Supplemental Status Report following up the Parties’ September 16, 2013 Joint Status Report.
I.

PLAINTIFFS’ POSITION
On September 16, 2013, the Parties filed their Joint Status Report pursuant to the Court’s

July 26th Minute Order, apprising the Court of any written discovery issues. Under the section
titled “Plaintiffs’ Position,” Plaintiffs indicated that they sent a meet and confer letter to
Defendant comScore, Inc. on September 16, 2013 outlining the deficiencies in its responses to
their written discovery requests. However, while Plaintiffs intended to send that meet and confer
letter on September 16th, based on comScore’s document production, certain additional edits
were made to the letter, which delayed service of the letter until September 18th. Thus,
“Plaintiffs’ Position” statement in the Joint Status Report contained an error inasmuch as the
meet and confer letter was sent on September 18th—not September 16th.

Respectfully submitted,
MIKE HARRIS and JEFF DUNSTAN,
individually and on behalf of a class of similarly
situated individuals,
Dated: September 20, 2013

By: /s/ Rafey S. Balabanian
One of Plaintiffs’ Attorneys
Jay Edelson
Rafey S. Balabanian
Ari J. Scharg
Benjamin S. Thomassen
Chandler R. Givens
EDELSON LLC
350 North LaSalle, Suite 1300
Chicago, Illinois 60654
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Counsel for Plaintiffs and the Class and Subclass

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CERTIFICATE OF SERVICE
I, Rafey S. Balabanian, an attorney, hereby certify that on September 20, 2013, I served
the above and foregoing Plaintiffs’ Supplemental Status Report, by causing true and accurate
copies of such paper to be filed and transmitted to all counsel of record via the Court’s CM/ECF
electronic filing system on this 20th day of September 2013.
/s/ Rafey S. Balabanian

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