Dunstan et al v. comScore, Inc.

Filing 239

comScore's Designation of Forensic Expert and Submission of Proposed Revisions to Plaintiffs' Proposed Protective Order Governing Production of Plaintiff Dunstan's Hard Drive by comScore, Inc. (Attachments: # 1 Exhibit A)(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 situated individuals

CASE NO. 1:11-cv-5807
Judge Holderman

Plaintiff,

Magistrate Judge Kim
v.
COMSCORE, INC., a Delaware corporation
Defendant.

COMSCORE’S DESIGNATION OF FORENSIC EXPERT AND SUBMISSION OF
PROPOSED REVISIONS TO PLAINTIFFS’ PROPOSED PROTECTIVE ORDER
GOVERNING PRODUCTION OF PLAINTIFF DUNSTAN’S HARD DRIVE
Pursuant to this Court’s October 16, 2013 Order (Dkt. No. 235), comScore hereby
designates Mike Perry of Elysium Digital LLC, 2 Oliver Street, 11th Floor, Boston, MA 02109
as its forensic expert. In addition, comScore’s proposed revisions to Plaintiffs’ Proposed
Protective Order (Dkt. No. 236-1) are attached hereto as Exhibit A. comScore submits these
proposed revisions more accurately reflect the Court’s October 16, 2013 Order and the parties’
discussions with the Court during the October 16, 2013 hearing.

DATED: October 22, 2013

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.

99999.77815/5554808.1

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CERTIFICATE OF SERVICE
I, the undersigned, hereby certify that a true and correct copy of COMSCORE’S
DESIGNATION OF FORENSIC EXPERT AND SUBMISSION OF PROPOSED REVISIONS
TO PLAINTIFFS’ PROPOSED PROTECTIVE ORDER GOVERNING PRODUCTION OF
PLAINTIFF DUNSTAN’S HARD DRIVE has been caused to be served on October 22, 2013 to
all counsel of record via email.
_/s/ Robyn Bowland
Robyn Bowland

99999.77815/5554808.1

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