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 OAKLAND DIVISION 11 12 AKHILESH VANGALA, et al., ) No. 4:20-cv-8143-HSG ) 13 Plaintiffs, ) ) STIPULATION TO STAY PROCEEDINGS; 14 v. ) ORDER ) 15 UNITED STATES CITIZENSHIP AND ) IMMIGRATION SERVICES, et al., ) Hon. Haywood S. Gilliam, Jr. 16 ) Defendants. ) 17 ) 18 The parties, through their undersigned attorneys, hereby stipulate and respectfully request the 19 Court to stay proceedings in this case for a limited time, until February 15, 2021. The parties make this 20 joint request because they are engaged in settlement discussions and an administrative resolution that 21 may render further litigation of this case unnecessary. 22 Plaintiffs filed this action under the Administrative Procedure Act, challenging United States 23 Citizenship and Immigration Services’ (“USCIS”) implementation of a “blank space” rejection criteria 24 for certain immigration benefits forms. On December 3, 2020, the Court granted the parties’ stipulated 25 briefing schedule for Plaintiffs’ Motion for Class Certification. ECF No. 21. Shortly after this action was 26 filed, however, the parties entered into settlement discussions. In light of the parties’ pursuit of a 27 potential settlement in lieu of litigation, the parties conferred and agree that judicial economy would best 1 discretion” to stay proceedings. Clinton v. Jones,

(1997). “[T]he power to stay 2 proceedings is incidental to the power inherent in every court to control the disposition of the causes on 3 its docket with economy of time and effort for itself, for counsel, and for litigants.” Landis v. North Am. 4 Co.,

(1936); see also Fed. R. Civ. P. 1. 5 Accordingly, the parties stipulate and request that the proceedings in this case be stayed until 6 February15, 2021, at which time the parties will file a joint status report with the Court. At that time, 7 the parties may request a further continuance of the stay of proceedings, court approval of a proposed 8 settlement agreement and dismissal of the litigation if appropriate, or placement of the case back on the 9 Court’s active docket. A stay of proceedings in this case will benefit the parties and conserve the Court’s 10 resources while the parties pursue a potential settlement. 11 DATED: January 13, 2021 Respectfully submitted, 12 DAVID L. ANDERSON United States Attorney 13 s/ Elizabeth D. Kurlan 14 ELIZABETH D. KURLAN Assistant United States Attorney 15 Attorneys for Defendants 16 17 DATED: January 13, 2021 18 s/ Matt Adams MATT ADAMS 19 Attorney Northwest Immigrant Rights Project 20 Attorney for Plaintiffs 21 22 23 24 25 26 27 1 ORDER 2 Pursuant to the stipulation of the parties, and good cause having been shown, it is hereby ordered 3 || that the proceedings in this case is stayed until February 15, 2021. The parties shall provide a joint status 4 || report by February 15, 2021. 5 IT IS SO ORDERED. 6 DATED: 1/14/2021 g Aapurd §, Ml} HON. HAYWOOD S. GILLIAM, JR: 9 United States District Judge 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 STIPULATION TO STAY PROCEEDINGS AND ORDER