Opinion
2:22-cv-00923-MMD-BNW
04-19-2023
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.
MICHAEL N. FEDER JOHN L. KRIEGER Howard Hughes Parkway, JOHN S. ARTZ (AdmittedPro hac vice) YAFEEZ S. FATABHOY (Admitted Pro hac vice) Ann Arbor, Attorneys for Defendants/Counter-Claimants Light & Wonder, Inc. and SG Gaming, Inc. G. WARREN BLEEKER (Admitted Pro Hac Vice) MICHAEL J. MCCUE MENG ZHONG Attorneys for Plaintiff/Counter-Defendant Empire Technological Group Limited
MICHAEL N. FEDER JOHN L. KRIEGER Howard Hughes Parkway, JOHN S. ARTZ (AdmittedPro hac vice) YAFEEZ S. FATABHOY (Admitted Pro hac vice) Ann Arbor, Attorneys for Defendants/Counter-Claimants Light & Wonder, Inc. and SG Gaming, Inc.
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 (THIRD REQUEST)
BRENDA WEKSLER UNITED STATES MAGISTRATE JUDGE
DICKINSON WRIGHT PLLC
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. The Court also entered an Order extending the deadline to file Summary Judgment seven (7) days. This is now the third request to extend the Summary Judgment Deadline and the Parties seek an additional 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 (ECF 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 19, 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 primarily based on the fact that due to unforeseen circumstances, Mr. Yafeez Fatabhoy, one of Defendant's primary attorneys, had his newborn son admitted into the hospital this past week. Mr. Fatabhoy participated in and guided much of Defendants' discovery, and is an integral part of the Defendants' legal team. The Parties have thus agreed to a seven (7) day extension to the Summary Judgment Deadline to accommodate these unforeseen circumstances.
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 19, 2023, seven (7) days to April 26, 2023. All other deadlines remain the same.
IT IS SO AGREED AND STIPULATED:
IT IS SO ORDERED: