Free Stipulation - District Court of Delaware - Delaware

Case 1:04-cv—OO138-JJF Document 79 Filed 06/O1/2005 Paget Of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
GTECH CORPORATION,
Plaintiff
v. C.A. No. O4-138-JIF
SCIENTIFIC GAMES INTERNATIONAL,
INC.; SCIENTIFIC GAMES HOLDINGS
CORPORATION; SCIENTIFIC GAMES {
FINANCE CORPORATION; and
SCIENTIFIC GAMES CORPORATION,
Defendants.
:
STIPULATION
IT IS HEREBY STIPULATED AND AGREED, that:
I. The parties will not offer or seek to offer opinions, conclusions or
testimony from patent law experts in this action.
2. Draft expert reports generated in connection with this action need not be
retained. All draft expert reports will be immune from discovery and inadmissible at trial.
3. The parties will not seek discovery of any notes prepared by experts in
connection with preparation of expert reports or declarations submitted in this action, or of any
communications between counsel and experts concerning this action.
4. Nothing in paragraphs 2-3 above shall preclude, or is intended to preclude,
a party from seeking, and receiving, discovery of any information relied upon by an expert in
rendering any opinions or conclusions in this action or relied upon in connection with an expert
report or declaration submitted by that expert in this action. The parties expressly agree that
discovery shall be permitted concerning anything an expert relied upon in connection with an

Case 1:04-cv-00138-JJF Document 79 Filed 06/O1/2005 Page 2 of 2
expert report, declaration, opinion or conclusion submitted or offered in this action, which could
potentially include communications with counsel, notes made by counsel or the expert, or other ‘
materials which would otherwise be exempt from discovery under paragraphs 2-3 of this
Stipulation.
YOUNG, CONAWAY, STARGATT & TAYLOR MORRIS, NICHOLS, ARSHT & TUNNELL
( I I ' V7/` ____/s/ Rodger D. Smith II
osy . Ingersoll ( ' 088) Jack B. Blumenfeld (#1014)
John W. Shaw (#3362) Rodger D. Smith II (#3778)
Karen E. Keller (#4489) 1201 N. Market Street
1000 West Street, 17th Floor P.O. Box 1347
P.O. Box 391 Wilmington, DE 19899
Wilmington, DE 19899 (302) 658-9200
(302) 571-6600 Attorneys for Defendants
Of counsel:
Thomas I. Meloro
Larissa A. Soccoli
Andrew L. Reibman
KENYON & KENYON
One Broadway
New York, New York 10004
Telephone: (212) 425-7200
Facsimile: (212) 425-5288
Attorneys for Plaintiff
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Case 1:04-cv-00138-JJF

Document 79

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Case 1:04-cv-00138-JJF

Document 79

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