Dunstan et al v. comScore, Inc.

Filing 338

MOTION by Defendant comScore, Inc. for extension of time to file response/reply as to motion for partial summary judgment 321 as Agreed and Stipulated by the Parties (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,
Plaintiffs,

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

v.
COMSCORE, INC., a Delaware corporation,
Defendant.

STIPULATED MOTION TO EXTEND SUMMARY JUDGMENT RESPONSE AND
REPLY DEADLINES
Plaintiff Mike Harris and Jeff Dunstan (“Plaintiffs”) and Defendant comScore, Inc.
(“comScore”) (collectively, the “Parties”), by and through their undersigned counsel, hereby
stipulate and, by agreement, respectfully move the Court to amend its Minute Entry dated March
11, 2014 (Dkt. 337), so as to extend the date for Defendant’s response to Plaintiffs’ Motion for
Summary Judgment (Dkt. No. 321) twenty-eight days to May 6, 2014 and extend the date for
Plaintiffs’ corresponding reply to May 20, 2014. The extensions are necessary to allow the
parties to continue working toward settlement of the above-captioned matter.

NOW THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and between the
Parties, and subject to the approval of the Court, as follows:
1.

The deadline for Defendant’s Response to Plaintiffs’ Motion for Summary

Judgment (Dkt. No. 321) shall be extended to May 6, 2014; and
2.

The deadline for Plaintiffs’ Reply to Plaintiffs’ Motion for Summary Judgment

(Dkt. No. 321) shall be extended to May 20, 2014.

04692.62386/5860912.1

Respectfully submitted,
MIKE HARRIS and JEFF DUNSTAN,
individually and on behalf of a class of
similarly situated individuals,
Dated: April 7, 2014

By: /s/Rafey S. Balabanian
One of Plaintiffs’ Attorneys
Jay Edelson
Rafey S. Balabanian
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]
Counsel for Plaintiffs and the Class and Subclass

Dated: April 7, 2014

comScore, Inc.,
By: /s/ Andrew H. Schapiro
One of Defendant’s Attorneys
Andrew H. Schapiro
Stephen Swedlow
Robyn Bowland
Quinn Emanuel Urquhart & Sullivan, LLP
500 West Madison St., Suite 2450
Chicago, Illinois 60661
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Counsel for Defendant comScore, Inc.

04692.62386/5860912.1

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SIGNATURE ATTESTATION
Pursuant to Section IX(C)(2) of the General Order on Electronic Case Filing, I hereby
attest that the content of this document is acceptable to all persons whose signatures are indicated
by a conformed signature (/s/) within this e-filed document.
/s/ Robyn M. Bowland

CERTIFICATE OF SERVICE
I, the undersigned, hereby certify that a true and correct copy of the foregoing has been
caused to be served on April 7, 2014 to all counsel of record via the Court’s ECF notification
system.
/s/ Robyn M. Bowland

04692.62386/5860912.1

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