Dunstan et al v. comScore, Inc.

Filing 359

MOTION by Plaintiffs Jeff Dunstan, Mike Harris for leave to file excess pages PLAINTIFFS' 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 Memorandum of Law in Support of
Motion for Approval of Attorneys’ Fees, Expenses, and Incentive Award. In support of this
motion, Plaintiffs state as follows:
1.

Plaintiffs have filed a Memorandum of Law in Support of Motion for Approval of

Attorneys’ Fees, Expenses, and Incentive Award (Dkt. 358) (the “Memorandum”), requesting
that the Court (i) approve the attorneys’ fees and expenses as set forth in the Memorandum, and
(ii) award the agreed-upon incentive awards to Plaintiffs Mike Harris and Jeff Dunstan.
2.

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

due to the many elements addressed in the Memorandum—including a history of the litigation, a
summary of the work performed on behalf of the Class, and an explanation of the reasons why
this Court should approve the requested fees and incentive awards—Plaintiffs require an
additional five (5) pages for their Memorandum.

3.

Plaintiffs’ proposed 20-page Memorandum is filed at Dkt. 358. In accordance

with Local Rule 7.1, a Table of Contents and Table of Authorities are included with the
Memorandum. Should the Court deny this motion, Plaintiffs will withdraw their Memorandum
from the docket and seek leave to file an abbreviated version of the brief.
WHEREFORE, Plaintiffs respectfully request that this Court enter an Order granting
this motion and permitting the filing of their 20-page Memorandum of Law in Support of Motion
for Approval of Attorneys’ Fees, Expenses, and Incentive Award, currently filed at Dkt. 358, and
such other relief as the Court deems equitable and just.

Dated: August 20, 2014

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 August 20, 2014, 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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