Dunstan et al v. comScore, Inc.

Filing 294

DECLARATION of Rafey S. Balabanian regarding motion to compel 293 (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 Exhibit J, # 11 Exhibit K, # 12 Exhibit L)(Thomassen, Benjamin)

EXHIBIT G

12/20/13

Edelson LLC Mail - Dunstan v. comScore

Ben Thomassen <[e-mail]>

Dunstan v. comScore
Robyn Bowland <[e-mail]>
Fri, Dec 6, 2013 at 4:56 PM
To: Ben Thomassen <[e-mail]>
Cc: Andy Schapiro <[e-mail]>, Stephen Swedlow
<[e-mail]>, Paul Stack <[e-mail]>, Jay Edelson
<[e-mail]>, Rafey Balabanian <[e-mail]>, Chandler Givens
<[e-mail]>, Nick Larry <[e-mail]>

Ben,

As mentioned on the call, we will need some time to ensure we can find a court reporter for the evening
of December 17, 2013. We will get back to you on the start time for Mr. Harris’ deposition.

We are still working on deposition scheduling for the 30(b)(6) deposition, but will hopefully be able to
get back to you soon. Because Plaintiffs’ 30(b)(6) notice is so wide-ranging, a series of short depositions
will be required. It would therefore be much more efficient from a logistical and scheduling standpoint
to take these depositions in Reston, Virginia. Please confirm that Plaintiffs will take these depositions in
Reston.

Although it is comScore’s continued position that the “decision-making” topics are irrelevant, in an effort
to resolve the dispute between the parties comScore will revise its 30(b)(6) deposition topics to include
the “decision-making” topics. comScore maintains its objection to the Abraham deposition.

comScore will make Mr. O’Toole available for a second deposition if Plaintiffs travel to Reston for the
30(b)(6) depositions.

We are still investigating whether a confidentiality agreement exists between comScore and Mr. Fox. In
any event, comScore would like to attend and is available on Dec. 19th .

Regards,

Robyn Bowland
Associate,
Q uinn Em anue l Urquhart & Sullivan, LLP
500 W e st Madison Stre e t, Suite 2450
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12/20/13

Edelson LLC Mail - Dunstan v. comScore

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From: Ben Thomassen [mailto:[e-mail]]
Sent: Thursday, December 05, 2013 8:08 PM
To: Robyn Bowland
Cc: Andy Schapiro; Stephen Swedlow; Paul Stack; Jay Edelson; Rafey Balabanian; Chandler Givens; Nick Larry
Subject: Dunstan v. comScore
[Quoted text hidden]

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