United States District Court, D. Nevada
INTERNATIONAL GAME TECHNOLOGY and IGT-UK GROUP LIMITED Plaintiffs,
ILLINOIS NATIONAL INSURANCE CO. Defendant.
D. Shugrue, Esq. (admitted pro hac vice) Kevin B. Dreher,
Esq. (admitted pro hac vice) REED SMITH LLP and Andrew F.
Dixon, Esq. Nevada State Bar No. 8422 BOWLER DIXON &
TWITCHELL LLP Attorneys for Plaintiffs, INTERNATIONAL GAME
TECHNOLOGY and IGT-UK GROUP LIMITED
Samberg Nevada Bar No. 10212 FORAN GLENNON PALANDECH PONZI
& RUDLOFF PC Justin S. Hepworth Nevada Bar No. 10080
Casey G. Perkins Nevada Bar No. 12063 FORAN GLENNON PALANDECH
PONZI & RUDLOFF PC Attorneys for Defendant ILLINOIS
NATIONAL INSURANCE CO.
STIPULATION AND ORDER TO EXTEND DEADLINE TO FILE
International Game Technology and IGT-UK Group Limited
(collectively “Plaintiffs”) and Defendant
Illinois National Insurance Co. (“INIC”), by and
through their respective counsel of record, hereby stipulate
and request for good cause showing that the Court extend the
deadline for the parties to file dispositive motions in this
action by approximately sixty (60) days from Tuesday, July
10, 2018 to Monday, September 10, 2018. The parties also
jointly request that the Court defer ruling on
Plaintiffs' June 12, 2018 Motion to Compel Defendant to
Produce Documents (Dkt. 79) pending the parties'
settlement negotiations. If the parties are unable to reach a
settlement, they will jointly advise the Court so that the
motion may then be considered and ruled upon.
the first request by any party since the close of discovery
to specifically extend the deadline to file dispositive
motions and the sixth overall request by any party to amend
any case management deadlines in this matter.
required by Local Rule 26-4, the parties state as follows:
DISCOVERY COMPLETED TO DATE
• The parties conducted the Fed.R.Civ.P. 26(f)
• 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. .
Plaintiffs propounded multiple requests for production of
documents, to which INIC responded.
• INIC propounded requests for production of documents
and interrogatories on Plaintiffs, to which Plaintiffs have
• Plaintiffs propounded multiple sets of interrogatories
and requests for admission on INIC to which INIC has
• INIC propounded requests for admission and additional
requests for production of documents to which Plaintiffs
• Plaintiffs have taken the depositions of INIC pursuant
to Rule 30(b)(6) as well as four current and former claim
handlers, a claim supervisor, a former underwriter, and the
Global Head of Financial Lines - Specialty Claims.
• INIC has taken the deposition of Plaintiffs pursuant
to Rule 30(b)(6) as well as two of Plaintiffs' employees,
Senior Legal Counsel for IGT-UK and ...