1 DAVID L. ANDERSON (CABN 149604) United States Attorney 2 SARA WINSLOW (DCBN 457643) Chief, Civil Division 3 ELIZABETH KURLAN (CABN 255869) Assistant United States Attorney 4

450 Golden Gate Avenue, Box 36055 5 San Francisco, California 94102-3495 Telephone: 415-436-7298 6 [email protected]

7 Attorneys for Defendants

8

UNITED STATES DISTRICT COURT 9

NORTHERN DISTRICT OF CALIFORNIA 10

SAN FRANCISCO DIVISION 11

12

GABOR SZECSI, et al., ) No. 3:20-cv-2621-VC 13 ) 14 Plaintiffs, ) ) STIPULATION TO STAY PROCEEDINGS; 15 v. ) [PROPOSED] ORDER )

16 CHAD WOLF, Acting Secretary, U.S. ) ) Honorable Vince Chhabria Department of Homeland Security, et al., ) 17 ) 18 Defendants. ) )

19 20 The parties, through their undersigned attorneys, hereby stipulate and respectfully request the 21 Court to stay proceedings in this case for a limited time, until August 21, 2020. The parties make this 22 joint request because they are pursuing an administrative resolution that may render further litigation of 23 this case unnecessary and moot. 24 Plaintiffs filed this mandamus action on April 15, 2020, requesting United States Citizenship and 25 Immigration Services (“USCIS”) to take action on their petitions for U nonimmigrant status (“U visa 26 27 petitions”) and related applications for Employment Authorization Documents (“EAD”). ECF 1. 1 The parties have been engaged in cooperative and productive communications regarding 2 USCIS’s agreement to expedite adjudication of Plaintiffs’ U visa petitions for potential placement on the 3 U visa waitlist, and Plaintiffs’ EAD applications as well. In light of USCIS’s plan to expedite 4 adjudication of Plaintiffs’ U visa petitions and EAD applications, the parties conferred and agree that 5 judicial economy would best be served by staying the litigation deadlines in this case for a limited time. 6 Courts have “broad discretion” to stay proceedings. Clinton v. Jones,

(1997). “[T]he 7 8 power to stay proceedings is incidental to the power inherent in every court to control the disposition of 9 the causes on its docket with economy of time and effort for itself, for counsel, and for litigants.” Landis 10 v. North Am. Co.,

(1936); see also Fed. R. Civ. P. 1. 11 Accordingly, the parties stipulate and request that the proceedings in this case be stayed until 12 August 21, 2020, at which time the parties will file a joint status report with the Court. At that time, the 13 parties may request a further continuance of the stay of proceedings, dismissal of the litigation if 14 appropriate, or placement of the case back on the Court’s active docket. A stay of proceedings in this 15 16 case will benefit the parties and conserve the Court’s resources while the parties pursue a potential 17 administrative resolution. 18 In accordance with Civil Local Rule 5(i)(3), the filer of this document attests that all signatories 19 listed below concur in the filing of this document. 20 DATED: July 2, 2020 Respectfully submitted, 21 DAVID L. ANDERSON 22 United States Attorney 23 s/ Elizabeth D. Kurlan ELIZABETH D. KURLAN 24 Assistant United States Attorney

25 Attorneys for Defendants

26

27 DATED: July 2, 2020 1 S/ Marc Van Der Hout MARC VAN DER HOUT 2 JOHNNY SINODIS 3 Attorneys for Plaintiffs 4 5 [PROPOSED] ORDER

6 Pursuant to the stipulation of the parties, and good cause having been shown, it is hereby ordered

7 || that the proceedings in this case is stayed until August 21, 2020. The parties shall provide a joint status 8 || report by August 21, 2020. 9 IT IS SO ORDERED. 10 || TED: 7/18/2020

D THEHON. VINCE CHHABRIA United States District Judge 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 STIPULATION TO STAY PROCEEDINGS AND [PROPCOSEB] ORDER