Dunstan et al v. comScore, Inc.

Filing 341

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 (Schapiro, Andrew)

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-05807
Hon. James F. Holderman
Magistrate Judge Young B. Kim

COMSCORE, INC., a Delaware corporation,
Defendant.

STIPULATED MOTION TO EXTEND SUMMARY JUDGMENT RESPONSE AND
REPLY DEADLINES
Plaintiffs 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 April
14, 2014 (Dkt. 340), so as to extend the date for Defendant’s response to Plaintiffs’ Motion for
Summary Judgment (Dkt. No. 321) twenty-eight days to June 3, 2014 and extend the date for
Plaintiffs’ corresponding reply to June 17, 2014. The extensions are necessary to allow the
parties to finalize a settlement agreement in the above-captioned matter. The Plaintiffs have
provided comScore a draft settlement agreement, to which comScore has proposed edits. The
parties have arrived at an agreement in principle, and will not request any further extensions on
the response and reply to Plaintiffs’ Motion for Summary Judgment (Dkt. No. 321).

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 June 3, 2014; and
2.

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

(Dkt. No. 321) shall be extended to June 17, 2014.

Respectfully submitted,
MIKE HARRIS and JEFF DUNSTAN,
individually and on behalf of a class of
similarly situated individuals,
Dated: May 5, 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: May 5, 2014

comScore, Inc.,
By: /s/ Andrew H. Schapiro
One of Defendant’s Attorneys

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Andrew H. Schapiro
Stephen Swedlow
Quinn Emanuel Urquhart & Sullivan, LLP
500 West Madison St., Suite 2450
Chicago, Illinois 60661
[e-mail]
[e-mail]
Counsel for Defendant comScore, Inc.

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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/ Andrew H. Schapiro

CERTIFICATE OF SERVICE
I, the undersigned, hereby certify that a true and correct copy of the foregoing has been
caused to be served on May 5, 2014 to all counsel of record via the Court’s ECF notification
system.
/s/ Andrew H. Schapiro

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