Rodriguez v. Cuccinelli

Hon. Judge Marsha J. Pechman

8 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON 9 AT SEATTLE

11 DANIEL LOZANO RODRIGUEZ, NO. 2:20-cv-00569-MJP 12 Plaintiff, Stipulated Motion to Extend v. Deadlines

14 KENNETH T. CUCCINELLI, et al. Note on Motion Calendar: July 16, 2020 Defendants.

17 The parties, pursuant to Local Rules 10(g) and 16, hereby jointly stipulate and move for a 60-day extension of their deadline to file a Joint Status Report and Discovery Plan, and of Defendants’ deadline to Answer the Complaint. The Joint Status Report and Answer are currently due July 27 and August 4, 2020, respectively; the new deadlines would be September 25 and October 5, 2020.

23 A court may modify a schedule for good cause. Fed. R. Civ. P. 16(b)(4).

24 Continuing pretrial and trial dates is within the discretion of the trial judge. See King v. State of California, 784 F.2d 910, 912 (9th Cir. 1986). The parties submit there is good cause for an extension of these deadlines. Defendants are working to schedule Plaintiff’s I-485 interview and intend to adjudicate the I-485 Application for lawful permanent resident status promptly thereafter.

3 Adjudication of Plaintiff’s I-485 Application would fully resolve this mandamus action without the time and expense of further litigation.

Accordingly, the parties seek a 60-day extension of their deadline to file a Joint Status Report and Defendants’ deadline to file the Answer.

IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

9 DATED: July 16, 2020 s/ Alexandra Lozano ALEXANDRA LOZANO, WSBA 10 #40478 Alexandra Lozano Immigration Law 11 16400 Southcenter Pkwy., Suite 410 Tukwila, WA 98188 Phone: 206-406-3068 13 Fax: 206-494-7775 Email: 14 [email protected] Attorney for Plaintiff DATED: July 16, 2020 s/ Kyle A. Forsyth 18 KYLE A. FORSYTH, WSBA #34609 Assistant United States Attorney 19 United States Attorney’s Office Stewart Street, Suite 5220 20 Seattle, WA 98101-1271 Phone: (206) 553-7970 21 Email: [email protected] 22 Attorney for Defendants 1 ORDER

2 IT IS SO ORDERED.

Dated this 16th day of July, 2020.

A Marsha J. Pechman United States Senior District Judge STIPULATED MOTION TO EXTEND DEADLINES UNITED STATES ATTORNEY STEWART STREET, SUITE 5220