reg United States Attorney Southern District of New York 86 Chambers Street New York, New York 10007 July 5, 2023 VIA ECF Hon. Ronnie Abrams United States District Judge United States District Court 40 Foley Square New York, New York 10007 Re: Ulyanova, et al. v. Garland, et al., No. 23 Civ. 4089 (RA) Dear Judge Abrams: 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 plaintiff's Petition for Alien Relative (Form I-130) and the Application to Register or Adjust Status (Form I-485). I write respectfully, and jointly with the plaintiffs, to request a 90-day stay of this matter, from July 24, 2023, to October 24, 2023. I also respectfully request that the initial pretrial conference currently scheduled for July 12, 2023, Dkt. No. 23, and the joint letter and proposed case management plan due in advance of that conference, be adjourned sine die. On June 15, 2023, USCIS approved plaintiffs I-130 petition, and USCIS is prepared to begin adjudicating the I-485 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.,

, 254- 55 (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 October 24, 2023. I thank the Court for its consideration of this letter. Respectfully submitted, Application granted. DAMIAN WILLIAMS SO ORDERED. United States Attorney By: _s/ Nancy Pham lf / NANCY D. PHAM (Co Special Assistant United States Attorney Hon. Ronnie Abrams 86 Chambers Street, 3rd Floor 7 6003 Tams New York, New York 10007 Telephone: (202) 305-8062 E-mail: [email protected] Attorney for Defendants cc: Counsel of record (via ECF)