Abdule v. Jaddou

District Judge Barbara J. Rothstein

7 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE DEKA AHMED ABDULE and BASHIR Case No. 2:21-cv-01558-BJR MOHAMED HASHI, 10 STIPULATION FOR EXTENSION OF Plaintiffs, TIME AND ORDER v. UR MENDOZA JADDOU, Director of the United States Citizenship and Immigration Services; THOMAS SMITHAM, Charges d’Affairs of the United States Embassy in Rome, Italy; ANTONY J.

BLINKEN, United States Secretary of State, United States Department of State; ALEJANDRO MAYORKAS, Secretary of Department of Homeland Security; 17 Defendants.

18 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, hereby jointly stipulate and move for an extension of 30 days for Defendants to respond to the Complaint. The Court had previously extended the response date until July 15, 2022, and stayed initial scheduling dates.

22 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 underlying facts continue to evolve and there is a significant likelihood that the matter could either become moot or the parties are able to resolve it without the need for litigation. Therefore, the parties believe good cause exists for a brief stay to save the Court and the parties from spending unnecessary time and resources on it.

4 The beneficiary at issue was interviewed on June 8, 2022, USCIS and DOS are reviewing the results of the updated security checks, which are necessary before the adjudication of a Form I-730 petition may be completed. USCIS and DOS are continuing to assess the recently received security check results, and all other information relevant to the adjudication of the Form I-730 petition. Depending on the results of this assessment, the government anticipates being able to inform the court within 30 days on the status of its processing of the Form I-730 petition for the beneficiary. If the beneficiary continues to be eligible to travel and the security check related information is resolved, the beneficiary will be scheduled for a medical exam.

12 In light of the above, the parties jointly stipulate and request that the Court: 13 1. Extend Defendants’ time to respond to Plaintiffs’ Complaint to August 19, 2022.

Stipulated to and presented this 14th day of July, 2022.

MENTER IMMIGRATION LAW PLLC NICHOLAS W. BROWN 16 United States Attorney s/ Meena Pallipamu Menter s/ Nickolas Bohl MEENA PALLIPAMU MENTER, WSBA #31870 NICKOLAS BOHL WSBA #48978 4444 Woodland Park Ave. N., Suite 203 Assistant United States Attorney Seattle, Washington 98103 United States Attorney’s Office Phone: 206-419-7332 700 Stewart Street, Suite 5220 Fax: 206-407-2594 Seattle, Washington 98101-1271 Email: [email protected] Phone: 206-553-7970 Fax: 206-553-4067 Counsel for Plaintiffs Email: [email protected] 22 Counsel for Defendants 1 ORDER 2 The parties having stipulated and agreed, it is hereby so ORDERED.

4 DATED this 18th day of July, 2022.

Aiboe arbain, BARBARA J. ROTHSTEIN 7 United States District Judge STIPULATION FOR EXTENSION OF TIME AND ORDER UNITED STATES ATTORNEY 1-cev-01558-BIR 700 STEWART STREET. SUITE 5220