1 CRAIG H. MISSAKIAN (CABN 125202) United States Attorney 2 KENNETH W. BRAKEBILL (CABN 196696) Acting Chief, Civil Division 3 ELIZABETH D. 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 Facsimile: (415) 436-6748 [email protected] 7 Attorneys for Defendants 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 OAKLAND DIVISION 11 ZANIAR GHAZIZADEH, 12 Case No. 4:25-cv-04515 JST Plaintiff, 13 v. STIPULATION REMANDING CASE TO 14 UNITED STATES CITIZENSHIP AND UNITED STATES CITIZENSHIP AND IMMIGRATION SERVICES, PURSUANT TO 15 IMMIGRATION SERVICES, et al.,

(b) and [PROPOSED] ORDER

16 Defendants.

17

18 Plaintiff commenced an action pursuant to

(b), requesting this Court to 19 adjudicate his application for naturalization that was pending before the United States Citizenship and 20 Immigration Services (“USCIS” or “the agency”) for more than 120 days after Plaintiff had been 21 interviewed. USCIS is prepared to resolve this matter by adjudicating Plaintiff’s application for 22 naturalization. However, USCIS cannot adjudicate the application until the Court remands the matter to 23 the agency. See

(b) (explaining that the district court “may remand [a Section 1447(b) 24 case], with appropriate instructions, to the [USCIS]”); United States v. Hovsepian,

, 1160 25 (9th Cir. 2004) (accord). 26 /// 27 1 Accordingly, subject to the Court’s approval, IT IS HEREBY STIPULATED that: 2 1. The Court shall remand this case to USCIS, 630 Sansome Street, San Francisco, CA 3 94111, directing the agency to take all necessary actions and issue a decision on Plaintiff’s application 4 for naturalization within twenty-one-days of the remand, absent unforeseen circumstances. 5 2. If USCIS does not issue a decision on Plaintiff’s application for naturalization within the 6 time frames set forth above, Defendants agree not to oppose any motion by Plaintiff requesting that the 7 Court vacate the remand order and reassert jurisdiction over Plaintiff’s action pursuant to

1447(b). 9 3. Each of the parties shall bear their own costs and fees. 10 Dated: September 29, 2025 Respectfully submitted,1 11 CRAIG H. MISSAKIAN United States Attorney 12 13 /s/ Elizabeth D. Kurlan ELIZABETH D. KURLAN 14 Assistant United States Attorney Attorneys for Defendants 15 16 Dated: September 29, 2025 /s/ John F. Flanagan 17 JOHN F. FLANAGAN Attorney for Plaintiff 18 19 20 [PROPOSED] ORDER 21 Pursuant to stipulation, IT IS SO ORDERED. 22 23 Date: October 1, 2025 ______________________ ____ 24 JON S. TIGAR United States District Judge 25 26 1 In accordance with Civil Local Rule 5-1(i)(3), the filer of this document attests that all 27 signatories listed herein concur in the filing of this document.