International Game Technology et al v. Illinois National Insurance Co.

Filing 48

ORDER granting 46 Stipulation; Discovery due by 4/13/2018. Motions due by 5/11/2018. Proposed Joint Pretrial Order due by 6/8/2018. Signed by Magistrate Judge Nancy J. Koppe on 11/16/2017. (Copies have been distributed pursuant to the NEF - JM)

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7455 Arroyo Crossing, Suite 22 0
Las Vegas, Nev ada 89113

FORAN GLENNON PALANDECH PONZI & RUDLOFF PC

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Amy M. Samberg
Nevada Bar No. 10212
FORAN GLENNON PALANDECH
PONZI & RUDLOFF PC
1 East Washington Street, Suite 500
Phoenix, AZ 85004
Telephone: [phone]
Facsimile: 312-863-5099
Email: [e-mail]
Justin S. Hepworth
Nevada Bar No. 10080
Casey G. Perkins
Nevada Bar No. 12063
FORAN GLENNON PALANDECH PONZI & RUDLOFF PC
2200 Paseo Verde Parkway, Suite 280
Henderson, NV 89052
Telephone: [phone]
Facsimile: 312-863-5099
E-Mail: [e-mail]

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Attorneys for Defendant Illinois National Insurance Co.

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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INTERNATIONAL GAME TECHNOLOGY and
IGT-UK GROUP LIMITED,

Case No. 2:16-cv-02792-APG-NJK

Plaintiff,
v.
ILLINOIS NATIONAL INSURANCE CO.,

STIPULATION AND ORDER TO
EXTEND DISCOVERY
DEADLINES

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Defendant.

(Third Request)

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Plaintiffs International Game Technology and IGT-UK Group Limited (collectively “IGT”)

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and Defendant Illinois National Insurance Co. (“INIC”), by and through their respective counsel of

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record, hereby stipulate and request that the Court extend certain discovery deadlines by

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approximately sixty (60) days. This is the third request by any party to extend any discovery

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deadlines in this matter.

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Pursuant to Local Rule 26-4, the parties state as follows:

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I.

DISCOVERY COMPLETED TO DATE

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•

The parties conducted the Fed. R. Civ. P. 26(f) conference.

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•

The parties have exchanged initial and supplementary disclosures of documents and

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lists of witnesses, including the exchange of tens of thousands of pages of

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documents.
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responded.
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IGT propounded interrogatories and requests for admissions on INIC, to which INIC
has responded.

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7455 Arroyo Crossing, Suite 22 0
Las Vegas, Nev ada 89113

INIC propounded requests for production of documents and interrogatories on IGT,
to which IGT has responded.

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FORAN GLENNON PALANDECH PONZI & RUDLOFF PC

IGT propounded requests for production of documents, to which INIC has

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IGT has noticed the depositions of INIC’s 30(b)(6) designee and multiple current
and former INIC employees.

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IGT issued subpoenas to multiple third-parties requesting production of documents.

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IGT issued subpoenas for deposition to three former employees of INIC.

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INIC propounded requests for admission and an additional set of requests for

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production of documents on IGT, to which IGT has responded.
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The parties have engaged in multiple meet and confer teleconferences regarding the
above discovery.

II.

DISCOVERY TO BE COMPLETED

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Deposition(s) of Rule 30(b)(6) designee(s) of INIC.

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Deposition(s) of current and former employees and/or representatives of INIC.

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Deposition(s) of Rule 30(b)(6) designee(s) of IGT.

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Deposition(s) of current and former employees and/or representatives of IGT.

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Deposition of the Rule 30(b)(6) designee(s) and/or officers/employees of Marsh &

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McLennan Companies, Inc.

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Deposition of additional non-party fact witnesses.

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Disclosure of expert witnesses and rebuttal.

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Depositions of expert witnesses.

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The above list is made without prejudice to the Parties’ ability to conduct additional
discovery or to object to such discovery consistent with the Federal Rules of Civil Procedure.

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III.

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REASONS WHY DISCOVERY CANNOT BE COMPLETED WITHIN THE
CURRENT SCHEDULE

parties in this case have engaged in written discovery and have attempted to resolve several

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discovery issues that have arisen between them. Despite those efforts, the parties have reached an

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impasse on several issues relating to the scope of discovery pending resolution of two motions that

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are now before the Court: a motion by IGT to amend its complaint to assert causes of action for

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breach of the implied covenant of good faith and fair dealing and violations of Nevada’s Unfair

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7455 Arroyo Crossing, Suite 22 0
Las Vegas, Nev ada 89113

As the Court is aware from the parties’ previous submissions and as outlined above, the

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FORAN GLENNON PALANDECH PONZI & RUDLOFF PC

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Claims Settlement Practices Act and a motion by IGT to compel discovery of documents and

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deposition testimony from INIC. Absent a ruling from the Court on these pending motions, which

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may impact the scope and extent of permissible discovery in this action, the parties are not able to

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complete discovery and disclosure of expert opinions in this case under the current schedule.

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Consequently, the parties request that the Court extend the remaining discovery deadlines,

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beginning with the deadline for disclosure of expert witnesses, by approximately sixty (60) days,

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as outlined below.

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The parties agree that this extension is not made for the purposes of delay, but to allow

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additional time for the court to decide the Motion for Leave and for the parties to complete fact

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discovery, as necessary, before disclosing experts to ensure a just adjudication of the case on the

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merits, and that none of them will be prejudiced by an extension.

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IV.

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WHEREFORE, the parties respectfully request that this Court extend discovery deadlines

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7455 Arroyo Crossing, Suite 22 0
Las Vegas, Nev ada 89113

FORAN GLENNON PALANDECH PONZI & RUDLOFF PC

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PROPOSED SCHEDULE

as follows:
EVENT
Add Parties/Amend
Pleadings
Designate Expert
Witness(es)
File Interim Status Report
Designate Rebuttal
Witness(es)
Close of Discovery
File Dispositive Motions
Joint Pretrial Order

CURRENT DEADLINE
July 13, 2017

PROPOSED DEADLINE
No Extension Requested

December 11, 2017

February 9, 2018

December 11, 2017
January 8, 2018

February 9, 2018
March 16, 2018

February 9, 2018
March 12, 2018
April 9, 2018

April 13, 2018
May 11, 2018
June 8, 2018
*In the event dispositive motions
are filed, the date for filing the
Joint Pretrial Order shall be
suspended until 30 days after the
decision of the dispositive
motions or further order of Court.

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Dated: November 15th, 2017

Dated November 15th, 2017

BOWLER DIXON & TWITCHELL LLP

FORAN GLENNON PALANDECH
PONZI & RUDLOFF PC

__/s/_Kevin B. Dreher________________
Andrew F. Dixon, Esq.
Nevada Bar No. 8422
3137 East Warm Springs Road, Ste. 100
Las Vegas, Nevada 89120

__/s/ Casey G. Perkins__________
Amy M. Samberg, Esq.
Nevada Bar No. 10212
1 East Washington Street, Suite 500
Phoenix, AZ 85004

REED SMITH LLP
John D. Shugrue, Esq.
Kevin B. Dreher, Esq.
Pro Hac Vice
10 South Wacker Drive, Suite 4000
Chicago, IL 60606-7507

Casey G. Perkins, Esq.
Nevada Bar No. 12063
7455 Arroyo Crossing, Suite 220
Las Vegas, Nevada 89113

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Counsel for Defendant Illinois
National Insurance Co.

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Counsel for Plaintiffs International Game
Technology and IGT-UK Group Limited

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ORDER
IT IS SO ORDERED.

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DATED this _____ day of November, 2017.

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_______________________________________
UNITED STATES MAGISTRATE JUDGE

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