Olmos Gomez v. Cuccinelli

Hon. Marsha J. Pechman

7 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE JOSE LUIS OLMOS GOMEZ, Case No. 2:20cv1304-MJP Plaintiff, Stipulated Motion to Extend Deadlines 11 v. Note on Motion Calendar: 12 October 22, 2020.

KENNETH T. CUCCINELLI, et al.

Defendants.

16 The parties, pursuant to Local Rules 10(g) and 16, hereby jointly stipulate and move for a 60-day extension of Defendants’ deadline to file an Answer to the Complaint. The Answer is currently due November 9, 2020; the new deadline would be January 8, 2021.

19 A court may modify a schedule for good cause. Fed. R. Civ. P. 16(b)(4). 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 this deadline. Defendants have scheduled Plaintiff’s I-485 interview and intend to adjudicate the I-485 Application for lawful permanent resident status promptly thereafter. Adjudication of Plaintiff’s I-485 Application would fully resolve this mandamus action without the time and expense of further litigation.

1 Accordingly, the parties seek a 60-day extension of the deadline for Defendants to file the Answer.

3 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

4 DATED: October 22, 2020 s/ Alexandra Lozano ALEXANDRA LOZANO, WSBA #40478 Alexandra Lozano Immigration Law 6 16400 Southcenter Pkwy., Suite 410 Tukwila, WA 98188 7 Phone: 206-406-3068 Fax: 206-494-7775 Email: [email protected] Attorney for Plaintiff DATED: October 22, 2020 s/ Matt Waldrop MATT WALDROP, Georgia Bar #349571 13 Assistant United States Attorney United States Attorney’s Office 14 700 Stewart Street, Suite 5220 Seattle, Washington 98101-1271 15 Phone: 206-553-7970 Fax: 206-553-4067 Email: [email protected] Attorney for Defendants

1 ORDER 2 The Court GRANTS the stipulated motion. Defendants’ response is now due by January 8, 2021.

4 IT IS SO ORDERED.

5 Dated this 26th day of October, 2020.

A The Honorable Marsha J. Pechman 10 United States District Judge

STIPULATED MOTION TO EXTEND DEADLINES