Opinion
2:22-cv-00923-MMD-BNW
04-12-2023
EMPIRE TECHNOLOGICAL GROUP LIMITED, Plaintiff, v. LIGHT & WONDER, INC., and SG GAMING, INC., Defendants. LIGHT & WONDER, INC., and SG GAMING, INC., Counter-Claimants, v. EMPIRE TECHNOLOGICAL GROUP, LIMITED, Counter-Defendant.
DICKINSON WRIGHT PLLC, MICHAEL N. FEDER (Nevada Bar #7332), JOHN L. KRIEGER (Nevada Bar #6023), JOHN S. ARTZ (AdmittedPro hac vice), YAFEEZ S. FATABHOY (Admitted Pro hac vice), Attorneys for Defendants/Counter-Claimants Light & Wonder, Inc. and SG Gaming, Inc. LEWIS ROCA ROTHGERBER CHRISTIE LLP, G. WARREN BLEEKER (Admitted Pro Hac Vice), MICHAEL J. MCCUE MENG ZHONG, Attorneys for Plaintiff/Counter-Defendant Empire Technological Group Limited.
DICKINSON WRIGHT PLLC, MICHAEL N. FEDER (Nevada Bar #7332), JOHN L. KRIEGER (Nevada Bar #6023), JOHN S. ARTZ (AdmittedPro hac vice), YAFEEZ S. FATABHOY (Admitted Pro hac vice), Attorneys for Defendants/Counter-Claimants Light & Wonder, Inc. and SG Gaming, Inc.
LEWIS ROCA ROTHGERBER CHRISTIE LLP, G. WARREN BLEEKER (Admitted Pro Hac Vice), MICHAEL J. MCCUE MENG ZHONG, Attorneys for Plaintiff/Counter-Defendant Empire Technological Group Limited.
STIPULATION AND PROPOSED ORDER TO EXTEND THE DEADLINE GOVERNING THE LAST DAY TO FILE SUMMARY JUDGMENT MOTION REGARDING INITIAL PHASE OF DISCOVERY
BRENDA WEKSLER, UNITED STATES MAGISTRATE JUDGE.
Plaintiff/Counter-Defendant Empire Technological Group Limited (“Plaintiff/Counter-Defendant”) and Defendants/Counter-Claimants Light & Wonder, Inc. and LNW Gaming, Inc., formerly known as SG Gaming, Inc. (“Defendants/Counter-Claimants”) (together, the “Parties”), by and through their respective counsel of record, hereby respectfully submit this Stipulation and Proposed Order to extend the deadline governing the deadline to file Summary Judgment relating to the Initial Phase of Discovery in this case (“Summary Judgment Deadline”). Previously, the Court entered an Order extending all discovery deadlines in this matter thirty (30) days, including the Summary Judgment Deadline. This Stipulation will not affect any deadlines other than the Summary Judgment Deadline. This is now the second request to extend the Summary Judgment Deadline and the Parties seek a seven (7) day extension. The Parties have agreed to such extension for the reasons set out below.
COMPLETED DISCOVERY
In the Discovery Plan and Scheduling Order (Dkt No. 23), the Parties bifurcated discovery into two phases. During the Initial Phase of Discovery, which was limited to Light & Wonder's I-Score Plus defense, the Parties completed six (6) depositions, sent multiple sets of discovery, and produced thousands of pages of documents. The Parties completed discovery on March 29, 2023. The existing Summary Judgment Deadline is April 12, 2023.
GOOD CAUSE TO EXTEND DEADLINE
The Parties were diligent in conducting the Initial Phase of Discovery in this matter and, as set forth above, vigorously sought and obtained discovery relating to the I-Score Plus defense. Good cause for the extension is based on the need for additional time to thoroughly assess the discovery conducted and prepare a motion for summary judgment in light of the complexity of the issues involved. Moreover, the Parties are requesting the extension due to the upcoming holidays and counsels' traveling schedules. The Parties thus make the present request to extend the Summary Judgment Deadline in view of the issues identified above.
The Parties have stipulated and agreed to extend the Summary Judgment Deadline by an additional seven (7) days as set forth below. This extension will ensure that the relevant information and issues are reviewed and properly briefed for the Court to rule on any summary judgment motions. For these reasons, this Stipulation is made for good cause and not for purposes of delay.
The Parties hereby stipulate and agree to only extend the existing Summary Judgment Deadline of April 12, 2023, seven (7) days to April 19, 2023. All other deadlines remain the same.
IT IS SO AGREED AND STIPULATED:
IT IS SO ORDERED: