ey United States Attorney Southern District of New York 86 Chambers Street New York, New York 10007 March 24, 2023 VIA ECF USDC SDNY Hon. Jennifer H. Rearden DOCUMENT United States District Judge ELECTRONICALLY FILED United States District Court DO #: 40 Foley Square DATE FILED:_ 3/28/2023 New York, New York 10007 Re: Page, et al. v. Jaddou, et al., No. 23 Civ. 00254 (JHR) Dear Judge Rearden: This Office represents defendants (the “government”) in the above-referenced action in which the plaintiffs seek an order compelling U.S. Citizenship and Immigration Services (“USCIS”) to adjudicate an Application to Adjust Status (Form I-485). I write respectfully, and jointly with the plaintiffs, to request a 120-day stay of this matter, from March 31, 2023, to July 31, 2023. On March 16, 2023, USCIS issued the plaintiffs a Request for Evidence, seeking missing evidence required to process the Form I-485. The plaintiffs have until June 12, 2023 to submit a response, and once received, USCIS requires time to review the plaintiffs’ response and adjudicate the application. The parties may be able to resolve this matter without further intervention of the Court. Accordingly, the requested stay is in the interests of efficiency and conservation of judicial and party resources. See Landis v. North Am. Co.,

(1936) (a district court has the “inherent power” to stay a pending action in the interest of judicial economy). This is the parties’ first request for a stay. The parties further propose providing a joint status update or stipulation and proposed order of dismissal by July 31, 2023. I thank the Court for its consideration of this letter. Respectfully submitted, SO ORDERED. DAMIAN WILLIAMS United States Attorney Jennifer H. Rearden, U.S.D.J. By: _s/ Nancy Pham Date: March 28, 2023 NANCY D. PHAM . Special Assistant United States Attorney 86 Chambers Street, 3rd Floor New York, New York 10007 Telephone: (202) 305-8062 E-mail: [email protected] Attorney for Defendants cc: Counsel of record (via ECF)