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 AND ORDER FOR Plaintiffs, EXTENSION OF 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 October 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 Department of State anticipates receiving relocation assurances from the appropriate Refugee Service Center within two weeks, then the International Office of Migration will expedite making travel arrangements, and Department of State 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 November 17, 2022.

12 Stipulated to and presented this 21st day of October, 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. This being the seventh extension of time granted in this case, however, the parties are advised that absent extraordinary circumstances, no further extensions of time for Defendants to respond to the Complaint will be granted.

6 DATED this 27th day of October, 2022.

A 9 Barbara Jacobs Rothstein U.S. District Court Judge