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International Game Technology v. Illinois National Insurance Co.

United States District Court, D. Nevada

November 16, 2017

INTERNATIONAL GAME TECHNOLOGY and IGT-UK GROUP LIMITED, Plaintiff,
v.
ILLINOIS NATIONAL INSURANCE CO., Defendant. EVENT CURRENT DEADLINE PROPOSED DEADLINE

          BOWLER DIXON & TWITCHELL LLP Andrew F. Dixon, Esq. Nevada Bar No. 8422 REED SMITH LLP John D. Shugrue, Esq. Kevin B. Dreher, Esq. Counsel for Plaintiffs International Game Technology and IGT-UK Group Limited

          FORAN GLENNON PALANDECH PONZI & RUDLOFF PC Amy M. Samberg, Esq. Nevada Bar No. 10212 Casey G. Perkins, Esq. Nevada Bar No. 12063 Counsel for Defendant Illinois National Insurance Co.

          STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES

         Plaintiffs International Game Technology and IGT-UK Group Limited (collectively “IGT”) and Defendant Illinois National Insurance Co. (“INIC”), by and through their respective counsel of record, hereby stipulate and request that the Court extend certain discovery deadlines by approximately sixty (60) days. This is the third request by any party to extend any discovery deadlines in this matter.

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

I. DISCOVERY COMPLETED TO DATE
• The parties conducted the Fed. R.Civ. P. 26(f) conference.

         • The parties have exchanged initial and supplementary disclosures of documents and lists of witnesses, including the exchange of tens of thousands of pages of documents.

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

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

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

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

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

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

• INIC propounded requests for admission and an additional set of requests for production of documents on IGT, to which IGT has responded.

         • The parties have engaged in multiple meet and confer teleconferences regarding the above discovery.

II. DISCOVERY TO BE COMPLETED
• Deposition(s) of Rule 30(b)(6) designee(s) of INIC.
• Deposition(s) of current and former employees and/or representatives of INIC.
• Deposition(s) of Rule 30(b)(6) designee(s) of IGT.
• Deposition(s) of current and former employees and/or representatives of IGT.
• Deposition of the Rule 30(b)(6) designee(s) and/or officers/employees of Marsh & McLennan Companies, Inc.
• Deposition of additional non-party fact ...

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