Patel v. United States Department of Homeland Security

District Judge Marsha J. Pechman Magistrate Judge Mary Alice Theiler

UNITED STATES DISTRICT COURT 7 WESTERN DISTRICT OF WASHINGTON AT SEATTLE TUSHAR BHARATBHAI PATEL, Case No. C19-2009 MJP-MAT 10 Petitioner, STIPULATED MOTION FOR ORDER OF DISMISSAL 11 v. Noted for consideration: U.S. DEPARTMENT OF HOMELAND January 7, 2020.

13 SECURITY, et al., 14 Respondents.

16 JOINT STIPULATION 17 The parties, through their undersigned counsel, hereby stipulate and agree that Petitioner was served with a Notice to Appear (“NTA”), placing him in removal proceedings on January 7, 2020, rendering his Thurassigiam-based habeas petition moot. Form I-862 NTA, attached hereto as Exhibit A; see also Thurassigiam v. U.S. Dept. of Homeland Sec., 917 F.3d 1097 (2019), cert. granted, -- S.Ct. --, 2019 WL 5281289 (Oct. 18, 2019). Accordingly, the parties hereby jointly move the Court for an order dismissing the Complaint without claim of either party for attorney’s fees or costs.

24 // // // // 1 Dated this 7th day of January, 2020.

BRIAN T. MORAN United States Attorney s/ Jennifer Lesmez s/ Priscilla T. Chan JENNIFER LESMEZ, WSBA No. 34547 PRISCILLA T. CHAN, WSBA No. 28533 Law Offices of Jennifer Lesmez Assistant United States Attorney P.O. Box 1797 United States Attorney’s Office Allyn, Washington 98524 700 Stewart Street, Suite 5220 Phone: 424-509-8697 Seattle, Washington 98101-1271 Fax: 253-295-4612 Phone: 206-553-7970 Email: [email protected] Fax: 206-553-4067 9 Email: [email protected] Attorney for Petitioner Attorney for Respondents 12 ORDER IT IS HEREBY ORDERED that this case is dismissed without an award of costs to either party.

Dated this 8th day of January, 2020.

A Marsha J. Pechman United States District Judge

Presented by: s/ Jennifer Lesmez JENNIFER LESMEZ, WSBA No. 34547 Law Offices of Jennifer Lesmez P.O. Box 1797 Allyn, Washington 98524 Phone: 424-509-8697 Fax: 253-295-4612 Email: [email protected] Attorney for Petitioner

10 BRIAN T. MORAN United States Attorney s/ Priscilla T. Chan PRISCILLA T. CHAN, WSBA No. 28533 Assistant United States Attorney Western District of Washington United States Attorney’s Office Stewart Street, Suite 5220 Seattle, Washington 98101-1271 Phone: 206-553-7970 Email: [email protected] Attorney for Respondents