Dunstan et al v. comScore, Inc.

Filing 66

MOTION by Defendant comScore, Inc. for discovery bifurcation (Stack, Paul)

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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. COMSCORE, INC., a Delaware corporation, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) No. 11 C 5807 Judge Holderman Magistrate Judge Kim DEFENDANT’S MOTION TO BIFURCATE DISCOVERY Now comes COMSCORE, INC., Defendant herein, by its attorneys, and pursuant to Rules 1 and 26 of the Federal Rules of Civil Procedure, moves this Honorable Court to bifurcate discovery in the instant matter so as to permit discovery relating to issues of class certification to go forward while staying discovery on remaining issues until further order of Court. Defendant submits herewith a Memorandum of Law in support of this Motion. Respectfully submitted, Whitty Somvichian Michael G. Rhodes (admitted pro hac vice) Whitty Somvichian (admitted pro hac vice) Ray Sardo (admitted pro hac vice) COOLEY LLP 101 California Street, 5th Floor San Francisco, CA 94111 Telephone: (415) 693-2000 rhodesmg@cooley.com wsomvichian@cooley.com rsardo@cooley.com Paul F. Stack Paul F. Stack Mark W. Wallin STACK & O’CONNOR CHARTERED Suite 411 140 South Dearborn Street Chicago, Illinois 60603 Attorneys for Defendant comScore, Inc. 1250726/SF 2

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