Deng v. United States Department of Homeland Security

District Judge Marsha J. Pechman

UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT SEATTLE FEIJIN DENG, KAAN GOKSAL, NAOYUKI Case No. 2:22-cv-00608-MJP KANDA, SEO YEONG KIM, SEUNG WOO SON, EROMOSELE UDUEBHO, MAI THANH STIPULATION FOR EXTENSION DUC LE, RAFAEL ANGELO AMADEI OF TIME REQUENA, Note on Motion Calendar: Plaintiffs, July 5, 2022 v. U.S. DEPARTMENT OF HOMELAND SECURITY, a federal agency, U.S. CITIZENSHIP AND IMMIGRATION SERVICES, a federal agency, UR MENDOZA JADDOU, Defendants.

20 Plaintiffs and Federal Defendants, by and through their counsel of record, pursuant to Federal Rule of Civil Procedure 6 and Local Rules 10(g) and 16, jointly stipulate and move for an extension of 30 days for Defendants to respond to the Complaint. Defendants answer or response to the complaint is currently set for July 8, 2022. The Court has also set initial scheduling dates and the parties recently notified the Court that they agreed this matter is exempt from the requirements of Federal Rule of Civil Procedure 26(a) and 26(f).

26 A court may modify a deadline for good cause. Fed. R. Civ. P. 6(b). 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 are currently attempting to resolve this matter and a significant number of issues are now moot. Therefore, the parties believe good cause exists for a brief stay to resolve this matter and to save the Court and the parties from spending unnecessary time and resources on it.

5 In light of the above, the parties jointly stipulate and request that the Court: 6 1. Extend Defendants’ time to respond to Plaintiffs’ Complaint to August 5, 2022.

7 2. Stay all other initial scheduling dates.

8 Stipulated to and presented this 5th day of July 2022.

9 FOX ROTHSCHILD, LLP NICHOLAS W. BROWN United States Attorney s/ Al Roundtree s/ Nickolas Bohl AL ROUNDTREE, WSBA #54851 NICKOLAS BOHL WSBA #48978 1001 Fourth Avenue, Suite 4400 Assistant United States Attorney Seattle, Washington 98154 United States Attorney’s Office Phone: 206-624-3600 700 Stewart Street, Suite 5220 Fax: 206-389-1708 Seattle, Washington 98101-1271 Email: [email protected] Phone: 206-553-7970 15 Fax: 206-553-4067 Counsel for Plaintiffs Email: [email protected] FRAGOMEN, DEL REY, BERNSEN & LOEWY, Counsel for Defendants LLP s/Carl W. Hampe CARL W. HAMPE, DC Bar #440475 Pro Hac Vice s/Daniel P. Pierce DANIEL P. PIERCE, DC Bar #988836 Pro Hac Vice 1101 15th Street NW, Suite 700 Washington, DC 20005 Phone: 202-223-5513 Fax: 202-371-2898 Email: [email protected] [email protected] Counsel for Plaintiffs 1 ORDER 2 The parties having stipulated and agreed, it is hereby so ORDERED.

4 DATED this 7th day of July, 2022.

A MARSHA J. PECHMAN 8 United States Senior District Judge