ELECTRONICALLY FIL > <p United States Attorney DOC Southern District of New York DATE FILED:____ 86 Chambers Street New York, New York 10007 June 26, 2023 MEMORANDUM □□□□□□ VIA ECF Hon. Gregory H. Woods United States District Judge United States District Court 40 Foley Square New York, New York 10007 Re: Holmes, et al. v. Mayorkas, et al., No. 23 Civ. 3847 (GHW) Dear Judge Woods: This Office represents defendants (the “government”) in the above-referenced action in which the plaintiffs seek an order compelling the United States Citizenship and Immigration Services (“USCIS”) to adjudicate the Petition for Alien Relative (Form I-130) filed on behalf of plaintiff Leroy Thaddeus Tavares and the Application to Register or Adjust Status (Form I-485) of Mr. Tavares. I write respectfully, and jointly with the plaintiffs, to request a 90-day stay of this matter, from June 26, 2023, to September 26, 2023. On June 22, 2023, USCIS issued the plaintiffs an interview notice relating to the □□□□□ application of Mr. Tavares, which set the interview for July 25, 2023. 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 August 25, 2023. I thank the Court for its consideration of this letter. Respectfully submitted, DAMIAN WILLIAMS United States Attorney By: — s/ Nancy Pham 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] cc: Counsel of record (via ECF) Attorney for Defendants granted. This case will be stayed through September 26, 2023. The initial pretrial conference currently scheduled for Augu: the joint letter and proposed case management plan due in advance of that conference, are adjourned sive die. The patties are to provide a joint status update or stipulation and proposed order of dismissal by August 25, 2023. of Court is directed to terminate the motion pending at Dkt. No. 14. iM ‘Ay , ff