Case 2:21-cv-01953-APG-EJY Document 161 Filed 03/19/25 Page 1 of 4
`
`MICHAEL C. VAN, ESQ.
`Nevada Bar No. 3876
`GARRETT R. CHASE, ESQ.
`Nevada Bar No. 14498
`JOSHUA J. FLOTH, ESQ.
`Nevada Bar No. 16860
`VC2 LAW
`8985 South Eastern Avenue, Suite 100
`Las Vegas, Nevada 89123
`Telephone: (702) 478-7770
`Facsimile: (702) 478-7779
`Email: michael@vc2law.com
`garrett@vc2law.com
`josh@vc2law.com
`Attorneys for Counterdefendant Jeri Wiedemer
`
`UNITED STATES DISTRICT COURT
`DISTRICT OF NEVADA
`
`RES EXHIBIT SERVICES, LLC, a New
`York limited liability company;
`
` Case No.: 2:21-cv-01953-APG-EJY
`
`STIPULATION AND [PROPOSED]
`ORDER TO EXTEND DISCOVERY
`DEADLINES
`
`(Fourth Request)
`
`vs.
`
`Plaintiff,
`
`LNW GAMING, INC. f/k/a SG GAMING,
`INC. f/k/a BALLY GAMING, INC., a
`Nevada corporation,
`
` Defendant.
`
`LNW GAMING, INC. f/k/a SG GAMING,
`INC. f/k/a BALLY GAMING, INC., a
`Nevada corporation,
`
`Counterclaimant,
`
`vs.
`
`RES EXHIBIT SERVICES, LLC, a New
`York limited liability company; JAMES
`LEONARDO, an individual; JERI
`WIEDEMER, an individual; and ROBERT
`REYES, an individual,
`
`Counterdefendants.
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`26
`
`27
`
`28
`
`Page 1 of 5
`
`
`
`Case 2:21-cv-01953-APG-EJY Document 161 Filed 03/19/25 Page 2 of 4
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`STIPULATION AND [PROPOSED] ORDER TO EXTEND DISCOVERY DEADLINES
`
`(Fourth Request)
`
`Pursuant to Local Rule (“LR”) IA 6-1, Plaintiff/Counterdefendant RES Exhibit Services,
`
`LLC (“RES”), Defendant/Counterclaimant LNW Gaming, Inc. f/k/a SG Gaming, Inc. f/k/a Bally
`
`Gaming, Inc. (“LNW”), Defendant James Leonardo (“Leonardo”), Defendant Jeri Wiedemer
`
`(“Wiedemer”) and Defendant Robert Reyes (“Reyes”) (collectively, the “Parties”), by and through
`
`their undersigned counsel of record, hereby request and stipulate to a 60-day extension of all
`
`discovery deadlines in light of the broad scope of discovery in this case, the recent appearance of
`
`counsel, the discovery remaining to be done, scheduling conflicts of the parties and witnesses, and
`
`10
`
`the length of time it has taken to review and produce voluminous amount of documents and
`
`11
`
`electronically stored information (“ESI”) which may be relevant to issues in this matter.
`
`12
`
`This is the Parties’ fourth request for an extension of time, and the first request to extend
`
`13
`
`the deadlines entered in the Court’s recent Scheduling Order [ECF No. 156]. This request is not
`
`14
`
`intended for delay and is made in good faith.
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`26
`
`27
`
`I.
`
`DISCOVERY COMPLETED
`
`1. RES has served its initial disclosures and one (1) supplement thereto;
`
`2. LNW has served its initial disclosures and eight (8) supplements thereto;
`
`3. Wiedemer, Leonardo and Reyes have served their initial disclosures;
`
`4. The Parties have each propounded and responded to written discovery requests and
`
`produced the vast majority of responsive documents and ESI in this action.
`
`II.
`
`DISCOVERY TO BE COMPLETED
`
`1. The Parties intend to notice and/or issue subpoenas for several party and non-party
`
`depositions of witnesses located throughout the United States;
`
`2. The Parties may propound additional written discovery requests;
`
`3. The Parties may disclose expert witnesses and reports pursuant to Fed. R. Civ. P.
`
`26(a)(2); and
`
`4. The Parties may notice the depositions of expert witnesses.
`
`28
`
`/ / /
`
`Page 2 of 5
`
`
`
`Case 2:21-cv-01953-APG-EJY Document 161 Filed 03/19/25 Page 3 of 4
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`III.
`
`PROPOSED UPDATED DISCOVERY PLAN AND SCHEDULING ORDER
`
`The Court adopted a Discovery Plan and Scheduling Order on January 30, 2025 [ECF
`
`No. 156]. For the reasons discussed herein and as suggested by the Court in its March 9, 2025
`
`Minute Order [ECF No. 159], the Parties now propose that the Court adopt the following deadlines:
`
`A. Discovery Cut-Off
`
`The current discovery cut-off date is Tuesday, July 29, 2025. The Parties propose to
`
`extend that deadline by 60 days to Monday, September 29, 2025.
`
`B. Deadline to Amend Pleadings/Add Parties.
`
`The deadline to amend pleadings/add parties is Wednesday, April 30, 2025. The Parties
`
`10
`
`propose to extend that deadline by 60 days to Monday, June 30, 2025.
`
`11
`
`12
`
`C. Deadline to Disclose Experts
`
`The current deadline to disclose expert witnesses is Friday, May 30, 2025, and the
`
`13
`
`deadline to disclose rebuttal experts is Sunday, June 29, 2025. The Parties propose to extend the
`
`14
`
`deadline for filing expert disclosures by 60 days to Tuesday, July 29, 2025. Rebuttal disclosures
`
`15
`
`shall be made thirty (30) days later on Thursday, August 28, 2025.
`
`16
`
`17
`
`D. Deadline to File Dispositive Motions
`
`The current dispositive motion deadline is Friday, August 29, 2025. The Parties
`
`18
`
`propose to extend that deadline by 60 days to Tuesday, October 28, 2025.
`
`19
`
`20
`
`E. Deadline for Joint Pre-Trial Order
`
`Pursuant to LR 26-1(b)(5), the parties shall have until 30 days after the deadline for
`
`21
`
`filing dispositive motion to file the joint pretrial order. Alternatively, if dispositive motions are
`
`22
`
`filed, the Parties will have 30 days after the date that the Court decides any dispositive motions
`
`23
`
`within which to file the joint pretrial order. The deadline to file the joint pretrial order is currently
`
`24
`
`Monday, September 29, 2025. The Parties propose to extend that deadline by 60 days to Friday,
`
`25
`
`November 28, 2025. This deadline is suspended if the dispositive motions are timely filed and the
`
`26
`
`joint pretrial order will be due 30 days following disposition of any dispositive motion.
`
`27
`
`…
`
`28
`
`…
`
`Page 3 of 5
`
`
`
`Case 2:21-cv-01953-APG-EJY Document 161 Filed 03/19/25 Page 4 of 4
`
`F. FRCP 26(a)(3) Disclosures
`
`The Parties agree to include their disclosures required by FRCP 26(a)(3) and any
`
`objections thereto in the joint pretrial order.
`
`IT IS SO STIPULATED.
`
`DATED this 19th day of March 2025.
`
`VC2 LAW
`
`RICE REUTHER SULLIVAN & CARROLL,
`LLP
`
`/s/ Garrett R. Chase________
`MICHAEL C. VAN, ESQ.
`Nevada Bar No. 3876
`GARRETT R. CHASE, ESQ.
`Nevada Bar No. 14498
`JOSHUA J. FLOTH, ESQ.
`Nevada Bar No. 16860
`8985 S. Eastern Ave., Suite 100
`Las Vegas, NV 89123
`Attorneys for Counterdefendant
`Jeri Wiedemer
`
`/s/ Chad W. Flansburg
`DAVID A. CARROLL, ESQ. (7643)
`ANTHONY J. DIRAIMONDO, ESQ. (10875)
`ROBERT E. OPDYKE, ESQ. (12841)
`3800 Howard Hughes Pkwy., Suite 1200
`Las Vegas, Nevada 89169
`-and-
`CHAD W. FLANSBURG, ESQ.
`(Pro Hac Vice)
`28 East Main Street, Suite 1400
`Rochester, New York 14614-1935
`Attorneys for RES Exhibit Services, LLC, James
`Leonardo, and Robert Reyes
`
`CAMPBELL & WILLIAMS
`
`/s/ Philip R. Erwin____________________
`PHILIP R. ERWIN, ESQ. (11563)
`SAMUEL R. MIRKOVICH (11662)
`ARIANA N. REED (15310)
`710 South Seventh Street, Suite A
`Las Vegas, Nevada 89101
`Attorneys for LNW Gaming Inc. f/k/a
`SG Gaming Inc. f/k/a Bally Gaming Inc.
`
`IT IS SO ORDERED.
`
`____________________________________
`U.S. MAGISTRATE JUDGE
`
`Date: March 19, 2025
`
`1
`
`2
`
`3
`
`4
`
`5
`
`6
`
`7
`
`8
`
`9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`26
`
`27
`
`28
`
`Page 4 of 5
`
`
