Maalin v. Mayorkas

1 District Judge Tana Lin

7 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE FARTUN A. MAALIN et al., No. 2:21-cv-1700-TL 10 Plaintiffs, STIPULATED MOTION TO HOLD CASE IN ABEYANCE AND 11 v. [PROPOSED] ORDER ALEJANDRO MAYORKAS, et al., Noted for Consideration on: July 22, 2022 13 Defendants.

Plaintiffs and Defendants, by and through their counsel of record, pursuant to Federal Rule of Civil Procedure 6 and Local Rules 7(d)(1), 10(g) and 16, hereby jointly stipulate and move to continue to stay these proceedings for thirty days. The case is currently stayed. Dkt. No. 20. The parties are currently working diligently towards a resolution to this litigation.

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 State Department received Plaintiffs’ marriage certificate on July 20, 2022 and intends to expedite the remaining processing. However, additional time is necessary. Therefore, the parties believe good cause exists for a brief stay in these proceedings to save the parties from spending unnecessary time and judicial resources on this matter.

1 Accordingly, the parties jointly stipulate and request that the Court stay these proceedings for thirty days. The parties will submit a joint status report on or before September 2, 2022.

3 Dated: July 22, 2022 Respectfully submitted, 4 NICHOLAS W. BROWN United States Attorney s/Michelle R. Lambert 6 MICHELLE R. LAMBERT, NYS #4666657 Assistant United States Attorney 7 United States Attorney’s Office 1201 Pacific Avenue, Suite 700 8 Tacoma, Washington 98402 Phone: 206-428-3824 9 Email: [email protected] Attorneys for Defendants 11 s/Jane Marie O’Sullivan JANE MARIE O’SULLIVAN 12 WSBA#34486 O’Sullivan Law Office 13 2417 Pacific Avenue SE, 2nd Floor Olympia, Washington 98501 14 Phone: 206-340-9980 Email: [email protected] 15 Attorney for Plaintiffs

1 [PROPOSED] ORDER 2 The parties having stipulated and agreed, it is hereby SO ORDERED. The parties shall file a joint status report on or before September 2, 2022.

5 DATED this 25th day of July 2022.

A Tana Lin United States District Judge