MEMORANDUM OPINION
SUE L. ROBINSON, District Judge.
I. INTRODUCTION
On November 24, 2009, ING Bank ("ING") filed suit against Dana Palmer/Team One Appraisals ("Palmer") and American Reporting Company ("ARC") (collectively "defendants"). (D.I. 1) Dana Palmer is the president of Team One Appraisals, a Washington-based real estate appraisal business. (Id. at ¶¶ 4-5) ARC is also a Washington-based real estate appraisal company. (
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