Dunstan et al v. comScore, Inc.

Filing 350

MOTION by Plaintiffs Jeff Dunstan, Mike Harris for leave to file excess pages MOTION FOR LEAVE TO FILE AN ENLARGED BRIEF INSTANTER (Balabanian, Rafey)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS, EASTERN DIVISION
JEFF DUNSTAN and MIKE HARRIS,
individually and on behalf of a class of
similarly situated individuals,
Plaintiffs,
v.

Case No. 1:11-cv-5807
Hon. James F. Holderman
Magistrate Judge Young B. Kim

COMSCORE, INC., a Delaware corporation,
Defendant.

PLAINTIFFS’ MOTION FOR LEAVE
TO FILE AN ENLARGED BRIEF INSTANTER
Plaintiffs Jeff Dunstan and Mike Harris, individually and on behalf of all others similarly
situated (collectively “Plaintiffs”), respectfully move the Court pursuant to Local Rule 7.1 for an
Order allowing them leave to file instanter an enlarged Motion for Preliminary Approval of
Class Action Settlement. In support of this Motion, Plaintiffs state as follows:
1.

Plaintiffs have filed a Motion for Preliminary Approval of Class Action

Settlement (Dkts. 345 (public) and 346 (provisionally sealed)), seeking (i) modification of the
Class definition as set forth in the Settlement Agreement, (ii) preliminary approval of the
Settlement Agreement, and (iii) approval of the accompanying form and methods of notice.
2.

While Plaintiffs have endeavored to keep their briefing as succinct as possible,

due to the many elements inherent to their Motion for Preliminary Approval—including fully
setting forth this case’s extensive litigation history, a summary of the Settlement Agreement, and
all the reasons why this Court should preliminarily approve the Settlement Agreement—
Plaintiffs require an additional 7 pages for their Motion for Preliminary Approval of Class
Action Settlement.

3.

Plaintiffs’ proposed 22-page Motion for Preliminary Approval is filed at (Dkts.

345 (public) and 346 (provisionally sealed)). In accordance with Local Rule 7.1, a Table of
Contents and Table of Authorities are included in the Motion. Should the Court deny this
Motion, Plaintiffs will withdraw their Motion for Preliminary Approval from the docket.
WHEREFORE, Plaintiffs respectfully request that this Court enter an Order granting
this motion and permitting the filing of their 22-page Motion for Preliminary Approval of Class
Action Settlement, currently filed at (Dkt. 345 (public) and 346 (provisionally sealed)), and such
other relief as the Court deems equitable and just.

Dated: May 30, 14

Respectfully submitted,
MIKE HARRIS and JEFF DUNSTAN,
individually and on behalf of all others similarly
situated,
By: s/ Rafey S. Balabanian
One of Plaintiffs’ Attorneys
Jay Edelson
[e-mail]
Rafey S. Balabanian
[e-mail]
Chandler R. Givens
[e-mail]
Benjamin S. Thomassen
[e-mail]
EDELSON PC
350 North LaSalle Street, Suite 1300
Chicago, Illinois 60654
Tel: [phone]
Fax: [phone]
Attorneys for Plaintiffs and the Class

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CERTIFICATE OF SERVICE
I, Rafey S. Balabanian, an attorney, hereby certify that on May 30, 14, I served the above
and foregoing Plaintiffs’ Motion for Leave to File an Enlarged Brief Instanter by causing true
and accurate copies of such paper to be transmitted to all counsel of record via the Court’s
CM/ECF electronic filing system.
s/ Rafey S. Balabanian

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