Dunstan et al v. comScore, Inc.

Filing 66

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

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.

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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: [phone]
[e-mail]
[e-mail]
[e-mail]

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

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