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 24
Solutions, by and through their undersigned counsel, hereby agree as follows: 25 1. On November 19, 2012, the Court entered an Order Setting Aside Entry of Default,
Default Judgment and Amended Default Judgment ("the Order"). In the Order, the Court directed 27 that defendant Mainstay Business Solutions shall file its Answer or other response to the 28 Complaint within thirty (30) days of the entry of the Order.
2. Following entry of the Order, the parties have been negotiating a resolution of this
3. Due to the parties' ongoing negotiations and because counsel for Mainstay
Business Solutions would be out of town for a pre-planned family vacation for two weeks, the 5 parties previously stipulated, and the Court ordered, that the time for Mainstay Business Solutions 6 to respond to the Complaint was extended to January 16, 2013. The Court subsequently extended 7 the time, upon stipulation, to January 30, 2013. 8
4. The parties have nearly completed their negotiations, and anticipate filing a 9 dismissal of this action as part of a settlement. They require additional time to finalize the 10 settlement documents and stipulate that the time for Mainstay Business Solutions may and should 11 be extended through and until February 15, 2013. 12
DATED: January 29, 2013. 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: January 29, 2013. 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 FOLLOWS: 4
Defendant Mainstay Business Solutions shall file its Answer or other response to the ...