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 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 September 18, 2022, and stayed initial scheduling dates. The parties anticipate this being the last stipulation.

23 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.

5 The beneficiary at issue was interviewed on June 8, 2022, and subsequently completed the required security and medical check processes. All that remains is for the International Office of Migration to make travel arrangements and then the government will issue the necessary travel documents to the beneficiary. At that point, the case will be moot, and the parties will file the appropriate papers to dismiss the matter.

10 In light of the above, the parties jointly stipulate and request that the Court: 11 1. Extend Defendants’ time to respond to Plaintiffs’ Complaint to October 19, 2022.

12 Stipulated to and presented this 19th day of September, 2022.

13 MENTER IMMIGRATION LAW PLLC NICHOLAS W. BROWN 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 18 Fax: 206-553-4067 Counsel for Plaintiffs Email: [email protected] Counsel for Defendants 1 ORDER 2 The parties having stipulated and agreed, it is hereby so ORDERED.

3 DATED this 28th day of September, 2022.

A B arbara Jacobs Rothstein U.S. District Court Judge