Dunstan et al v. comScore, Inc.

Filing 312

DECLARATION of Rafey S. Balabanian regarding response in opposition to motion, 311 (Attachments: # 1 Exhibit A)(Thomassen, Benjamin)

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,

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Plaintiffs,
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v.
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COMSCORE, INC., a Delaware corporation,
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Defendant.
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__________________________________________)

Case No. 1:11–cv–05807
Hon. James F. Holderman
Magistrate Judge Kim

DECLARATION OF RAFEY S. BALABANIAN IN
SUPPORT OF PLAINTIFFS’ RESPONSE IN OPPOSITION TO
DEFENDANT’S MOTION TO TRANSFER UNDER 28 U.S.C. § 1404(a)
I, Rafey S. Balabanian, pursuant to 28 U.S.C. § 1746, hereby declare and state as follows:
1.

I am an adult over the age of 18, and I am fully competent to make this

Declaration. I have personal knowledge of all matters set forth herein. If called upon to testify as
to the matters stated herein, I could and would competently do so. I make this Declaration in
support of Plaintiffs’ Response in Opposition to Defendant’s Motion to Transfer Under 28 U.S.C.
§ 1404(a).
2.

I am a Partner at the law firm of Edelson PC, which has been retained to represent

Plaintiffs Mike Harris and Jeff Dunstan (collectively, “Plaintiffs”) in this matter.
3.

Attached to this Declaration as Exhibit A is a true and accurate copy of excerpts

from the transcript of the Rule 30(b)(6) deposition of comScore, Inc., through its designee
Michael Brown.

1

I declare under penalty of perjury that the foregoing is true and correct.
Executed on this 28th day of January, 2014 in Chicago, Illinois.
s/ Rafey S. Balabanian

2

CERTIFICATE OF SERVICE
I, Benjamin S. Thomassen, an attorney, certify that on January 28, 2014, I served the
above and foregoing Declaration of Rafey S. Balabanian in Support of Plaintiffs’ Response in
Opposition to Defendant’s Motion to Transfer Under 28 U.S.C. § 1404(a), 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.

s/ Benjamin S. Thomassen

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