STIPULATION AND [PROPOSED] ORDER EXTENDING TIME TO RESPOND TO COMPLAINT
Plaintiff Mike Kreidler, Insurance Commissioner for the State of Washington as Receiver 23 for Cascade National Insurance Company, in Liquidation, and defendant Mainstay Business Solutions, by and through their undersigned counsel, hereby agree as follows:
1. On November 19, 2012, the Court entered an Order Setting Aside Entry of Default, Default Judgment and Amended Default Judgment ("the Order").
2. In the Order, the Court directed that defendant Mainstay Business
file its Answer or other response to the Complaint within thirty
(30) days of the entry of the Order.
3. Since entry of the Order, the parties have been negotiating a resolution of this matter and believe they are close to an agreement which will result in the dismissal of this action, 3 or entry of a stipulated judgment.
4. Further, counsel for Mainstay Business Solutions will be out of town for a pre-planned family vacation on and between December 24, 2012 and January 4, 2013. 6
5. The parties agree that the time by which Mainstay Business Solutions shall answer or otherwise respond to the Complaint should be extended by thirty (30) days, to and including 8 January 16, 2013. 9
6. Mainstay Business Solutions has not requested any prior extensions of time to 10 answer or otherwise respond to the Complaint. 11 12
DATED: December 3, 2012. VREELAND LAW PLLC 14 By: Victoria Vreeland /s/ 15 Victoria Vreeland Attorneys for Mike Kreidler, Insurance Commissioner 16 for the State of Washington as Receiver 17 DATED: December 3, 2012. BOUTIN JONES INC. 18 19 By: Michael E. Chase /s/ Robert R. Rubin Michael E. Chase Attorneys for Mainstay Business Solutions
BASED ON THE FOREGOING STIPULATION, IT IS HEREBY ORDERED AS
Defendant Mainstay Business Solutions shall file its Answer or other response to the ...