Dunstan et al v. comScore, Inc.

Filing 236

Plaintiffs' Submission of Proposed Order Governing Production of Plaintiff Dunstan's Hard Drive by Jeff Dunstan, Mike Harris (Attachments: # 1 Exhibit A)(Thomassen, Benjamin)

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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-5807 Hon. James F. Holderman Magistrate Judge Young B. Kim COMSCORE, INC., a Delaware corporation, Defendant. PLAINTIFFS’ SUBMISSION OF PROPOSED PROTECTIVE ORDER GOVERNING PRODUCTION OF PLAINTIFF DUNSTAN’S HARD DRIVE Pursuant to this Court’s October 16, 2013 Order, (Dkt. 235), Plaintiffs here submit a Proposed Protective Order Governing Production of Plaintiff Jeff Dunstan’s Hard Drive (the “Proposed Order”), a copy of which is attached hereto as Exhibit A. Respectfully submitted, MIKE HARRIS and JEFF DUNSTAN, individually and on behalf of a class of similarly situated individuals, Dated: October 18, 2013 By: s/ Benjamin S. Thomassen One of Plaintiffs’ Attorneys Jay Edelson Rafey S. Balabanian Ari J. Scharg Chandler R. Givens Benjamin S. Thomassen EDELSON LLC 350 North LaSalle, Suite 1300 Chicago, Illinois 60654 Telephone: (312) 589-6370 Facsimile: (312) 589-6378 jedelson@edelson.com rbalabanian@edelson.com ascharg@edelson.com cgivens@edelson.com bthomassen@edelson.com 2 CERTIFICATE OF SERVICE I, Benjamin S. Thomassen, an attorney, hereby certify that on October 18, 2013, I served the above and foregoing Plaintiffs’ Submission of Proposed Protective Order Governing Production of Plaintiff Dunstan’s Hard Drive, 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 18th day of October 2013. s/ Benjamin S. Thomassen 3

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