STIPULATION TO EXTEND DEADLINE TO RESPOND TO 

MOTION TO COMPEL – CASE NO. C06-0846 JCC - 1 

 robertson ▪ CLARK LLP 

701 FIFTH AVENUE 

SUITE 4200 

SEATTLE, WASHINGTON 98104-

7051 

(206) 262-8144 

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 THE HONORABLE JOHN C. COUGHENOUR 

UNITED STATES DISTRICT COURT 

WESTERN DISTRICT OF WASHINGTON 

AT SEATTLE 

TANGLETOWN, LLC, 

 Plaintiff, 

 v. 

UNDERWRITERS AT LLOYD'S, LONDON, 

 Defendant. 

NO. C06-0846 JCC 

STIPULATED MOTION TO EXTEND 

DEFENDANT UNDERWRITERS AT 

LLOYD’S LONDON’S DEADLINE TO 

RESPOND TO PLAINTIFF 

TANGLETOWN LLC’S MOTION TO 

COMPEL

NOTE ON MOTION CALENDAR: 

February 12, 2007 

I. INTRODUCTION/RELIEF REQUESTED 

 COME NOW the parties and hereby stipulate to an Order extending the deadline for 

Defendant Underwriters at Lloyd’s, London (“Underwriters”), to respond to Plaintiff Tangletown, 

LLC’s (“Tangletown”) motion to compel for approximately three (3) days, specifically extending 

Underwriters’ deadline from February 12, 2007 to 5:00 PM on February 15, 2007. This extension is 

being requested because the parties have been involved in extensive settlement negotiations and are 

hopeful that a settlement will be executed so as to render Tangletown’s motion to compel moot. In 

Case 2:06-cv-00846-JCC Document 38 Filed 02/13/07 Page 1 of 3
STIPULATION TO EXTEND DEADLINE TO RESPOND TO 

MOTION TO COMPEL – CASE NO. C06-0846 JCC - 2 

 robertson ▪ CLARK LLP 

701 FIFTH AVENUE 

SUITE 4200 

SEATTLE, WASHINGTON 98104-

7051 

(206) 262-8144 

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order to minimize litigation expenses in light of the possible settlement agreement, the parties 

stipulate to extend the deadline for Underwriters to respond to Tangletown’s motion to compel to 

5:00 PM on February 15, 2007. 

II. STATEMENT OF FACTS AND ARGUMENT 

 On February 8, 2007, the parties attended mediation and, after concerted efforts by both 

sides, a preliminary settlement was reached but the specific terms of this settlement have not been 

finalized. The requested extension of time for Underwriters to respond to Tangletown’s motion to 

compel from February 12, 2007 to 5:00 PM on February 15, 2007 will serve the interests of justice 

as it allows the parties to avoid incurring additional litigation expenses which could be unnecessary 

and undermine the finalizing of the preliminary settlement. The parties are hopeful that the 

requested extension for Underwriters to respond to Tangletown’s motion to compel will provide 

sufficient time to allow the parties to reduce the preliminary settlement into a fully executed Mutual 

Release and Settlement Agreement, thus rendering the motion to compel moot and allowing for a 

complete dismissal of this action. Alternatively, should the parties be unsuccessful in executing a 

Mutual Release and Settlement Agreement, Underwriters’ opposition will be due by 5:00 PM on 

February 15, 2007. 

/ / / 

/ / / 

/ / / 

/ / / 

/ / / 

/ / / 

/ / / 

Case 2:06-cv-00846-JCC Document 38 Filed 02/13/07 Page 2 of 3
STIPULATION TO EXTEND DEADLINE TO RESPOND TO 

MOTION TO COMPEL – CASE NO. C06-0846 JCC - 3 

 robertson ▪ CLARK LLP 

701 FIFTH AVENUE 

SUITE 4200 

SEATTLE, WASHINGTON 98104-

7051 

(206) 262-8144 

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III. CONCLUSION 

 For the foregoing reasons, the parties respectfully request that the stipulated motion be 

granted and the time for Underwriters to respond to Tangletown’s motion to compel be extended to 

5:00 PM on February 15, 2007. All other case dates would remain the same. 

DATED this 12th day of February, 2007. 

STANISLAW ASHBAUGH, LLP EISENHOWER & CARLSON, PLLC 

By: /s/ Kathleen Harrison via e-mail authority By:/s/ Kathleen Harrison via e-mail auth

 Jesse Miller, WSBA#35837 Emily J. Schultz, WSBA#32053 

 Attorneys for Plaintiff Attorneys for Plaintiff 

ROBERTSON CLARK, LLP 

By /s/ Kathleen Harrison 

 Les Robertson, WSBA# 35438 

 Kathleen Harrison, WSBA # 36456 

 Attorneys for Defendant

ORDER

IT IS SO ORDERED. 

Dated this 13th day of February, 2007 A 

UNITED STATES DISTRICT JUDGE 

JOHN C. COUGHENOUR 

Case 2:06-cv-00846-JCC Document 38 Filed 02/13/07 Page 3 of 3