Opinion
CASE NO. 2:12-cv-01154 WBS KJN
01-29-2013
MIKE KREIDLER, Insurance Commissioner for the State of Washington and as Receiver for Cascade National Insurance Company, in Liquidation, Plaintiff, v. MAINSTAY BUSINESS SOLUTIONS, a federally-authorized division of Blue Lake Rancheria Economic Development Corporation, Defendant.
BOUTIN JONES INC. Robert R. Rubin, SBN 117428 Michael E. Chase, SBN 214506 RAPPORT & MARSTON David J. Rapport, SBN 54384 Attorneys for defendant MAINSTAY BUSINESS SOLUTIONS Victoria Vreeland Attorneys for Mike Kreidler, Insurance Commissioner for the State of Washington as Receiver
BOUTIN JONES INC.
Robert R. Rubin, SBN 117428
Michael E. Chase, SBN 214506
RAPPORT & MARSTON
David J. Rapport, SBN 54384
Attorneys for defendant
MAINSTAY BUSINESS SOLUTIONS
STIPULATION AND [PROPOSED] ORDER EXTENDING TIME TO RESPOND TO COMPLAINT
Plaintiff Mike Kreidler, Insurance Commissioner for the State of Washington as Receiver 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"). In the Order, the Court directed that defendant Mainstay Business Solutions shall file its Answer or other response to the 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 matter.
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 parties previously stipulated, and the Court ordered, that the time for Mainstay Business Solutions to respond to the Complaint was extended to January 16, 2013. The Court subsequently extended the time, upon stipulation, to January 30, 2013.
4. The parties have nearly completed their negotiations, and anticipate filing a dismissal of this action as part of a settlement. They require additional time to finalize the settlement documents and stipulate that the time for Mainstay Business Solutions may and should be extended through and until February 15, 2013.
IT IS SO AGREED:
VREELAND LAW PLLC
By: _______________
Victoria Vreeland
Attorneys for Mike Kreidler, Insurance Commissioner
for the State of Washington as Receiver
BOUTIN JONES INC.
By: _______________
Robert R. Rubin
Michael E. Chase
Attorneys for Mainstay Business Solutions
ORDER
BASED ON THE FOREGOING STIPULATION, IT IS HEREBY ORDERED AS FOLLOWS:
Defendant Mainstay usiness Solutions shall file its Answer or other response to the Complaint by February 15, 2013.
_______________
WILLIAM B. SHUBB
UNITED STATES DISTRICT JUDGE