John P. Pratt Nicole Leibow 1 (admitted pro hac vice) Assistant United States Attorney 2 [email protected] United States Attorney’s Office Edward F. Ramos District of Nevada 3 [email protected] 501 Las Vegas Boulevard South, Suite 1100 (admitted pro hac vice) Las Vegas, NV 89101 4 Kurzban Kurzban Tetzeli & Pratt Office: (702) 388-6020 5 131 Madeira Avenue [email protected] Coral Gables, FL 33134 6 (305)444-0060 Attorney for Defendant 7 Anthony D. Guenther 8 [email protected] LAW OFFICES OF 9 ANTHONY D. GUENTHER, ESQ. Nevada Bar No. 5651 10 721 S. 6th Street 11 Las Vegas, NV 89101 (702)589-5170 12 Attorneys for Plaintiffs 13 14 UNITED STATES DISTRICT COURT 15 DISTRICT OF NEVADA 16 Yuliia Petlinska and Maksym Motolin, Case Number: 2:25-cv-00331-JCM-NJK 17 Plaintiffs, 18 JOINT STIPULATION v. 19 20 Kika Scott, Senior Official Performing the Duties of the Director, U.S. Citizenship and 21 Immigration Services, 22 Defendant. 23 24 This action was brought by Plaintiffs Yuliia Petlinska and Maksym Motolin seeking, 25 among other things, an order from this Court directing United States Citizenship and Immigration 26 Services (“USCIS”) to adjudicate their pending applications for Temporary Protected Status 27 28 1 1 (“TPS”) before April 28, 2025. On March 10, 2025, Plaintiffs filed a Motion for Preliminary 2 Injunction (see ECF Nos. 15 & 16), which is currently pending. 3 The parties have conferred and hereby jointly stipulate to the following resolution of this 4 action: 5 1. By April 26, 2025, USCIS will issue a final decision on the pending applications 6 for TPS filed by Plaintiffs Yuliia Petlinska and Maksym Motolin, subject to paragraph 3 infra. 7 2. If USCIS issues a Request for Evidence (“RFE”) on the pending TPS application(s), 8 such RFE(s) shall be issued on or before April 1, 2025. 9 3. In the event USCIS issues an RFE on one or both TPS applications, Plaintiffs must 10 submit a response by April 14, 2025 in order for USCIS to issue a final decision on the TPS 11 application(s) by April 26, 2025. 12 4. Plaintiff Yuliia Petlinska will file a Form I-526E Immigrant Petition by Regional 13 Center Investor no later than May 9, 2025. 14 5. Plaintiffs Yuliia Petlinska and Maksym Motolin request that the Court withdraw 15 their pending Motion for Preliminary Injunction (ECF Nos. 15 & 16). 16 6. Upon the final adjudication of Plaintiffs’ TPS applications, Plaintiffs will 17 voluntarily dismiss this action, under Federal Rule of Civil Procedure 41(a)(1)(A)(i), with the 18 parties bearing their own attorney’s fees and litigations costs. 19 7. This stipulation and any actions taken pursuant to it do not constitute any admission 20 by Defendants of negligence or wrongdoing by Defendants and shall not be construed as a 21 concession by Defendants as to any of Plaintiffs’ claims in this action. 22 8. The Parties agree that this Court shall retain jurisdiction to enforce the terms of this 23 stipulation. See Kokkonen v. Guardian Life Ins. Co. of America,

(1994). 24 WHEREFORE, the parties respectfully ask the Court to enter the attached Proposed Order 25 withdrawing Plaintiffs’ motion for preliminary injunction and staying this case pending the 26 Parties’ performance as provided above. 27 28 2 1 Dated: March 21, 2025 Respectfully submitted, 2 /s/ Edward F. Ramos /s/ Nicole Leibow 3 Edward F. Ramos Nicole Leibow 4 [email protected] Assistant United States Attorney Admitted pro hac vice United States Attorney’s Office 5 District of Nevada John P. Pratt 501 Las Vegas Boulevard South, Suite 1100 6 [email protected] Las Vegas, NV 89101 7 Admitted pro hac vice Office: (702) 388-6020 [email protected] 8 KURZBAN KURZBAN Attorney for Defendant TETZELI & PRATT, P.A. 9 131 Madeira Avenue 10 Coral Gables, Florida 33134 Tel. No. (305) 444-0060 11 Fax No. (305) 444-3503 12 Anthony D. Guenther 13 LAW OFFICES OF ANTHONY D. GUENTHER, ESQ. 14 Nevada Bar No. 5651 721 S. 6th Street 15 Las Vegas, NV 89101 16 Phone: (702) 589-5170 Fax: (702) 541-8866 17 Email: [email protected] 18 Attorneys for Plaintiffs 19 20 21 22 23 24 25 26 27 28 3 1 2 3 4 5 6 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 8 Yuliia Petlinska and Maksym Motolin, 9 Case Number: 2:25-cv-00331-JCM-NJK 1 Plaintiffs, 0 11 Vv. ORDER || Kika Scott, Senior Official Performing the B Duties of the Director, U.S. Citizenship and Immigration Services, 14 Defendant. 15 16 U7 This matter is before the Court on the parties’ Joint Stipulation, filed on March 21, 2025) 1g || Pursuant to the stipulation, it is hereby ORDERED that Plaintiffs’ motion for preliminar 19 injunction is withdrawn, this action is stayed, and the Parties are directed to perform consisten 59 || With their agreement. This Court retains jurisdiction to enforce the terms of the Parties’ stipulation. 5, || See Kokkonen v. Guardian Life Ins. Co. of America,

(1994). 22 IT IS SO ORDERED. 23 fp i , iy es *4 Dated: March 31, 2025. _, a Md Ss PAG Elon. Igmes C. Mahan UNITED STATES DISTRICT JUDGE 26 27 28