Mansur v. United States Department of Homeland Security

1 The Honorable Barbara J. Rothstein

7 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE RASHMI MANSUR, SWETHA KRISHNAN, Case No. 2:22-cv-01675-BJR RUCHIR KHANDELWAL, AND ANUPAM AWAL, JOINT STIPULATION AND Plaintiffs, ORDER TO EXTEND DEADLINE v. U.S. DEPARTMENT OF HOMELAND SECURITY, a federal agency, U.S. CITIZENSHIP AND IMMIGRATION SERVICES, a federal agency, and UR MENDOZA JADDOU, Defendants.

17 The parties, pursuant to Federal Rule of Civil Procedure 6 and Local Rules 10(g) and 16, hereby jointly stipulate and move to extend Defendants’ time to respond to the Complaint until April 21, 2023. Plaintiffs are foreign nationals who bring this litigation pursuant to the Administrative Procedure Act and the Mandamus Act seeking, inter alia, to compel U.S. Citizenship and Immigration Services to adjudicate their visa applications. See Dkt. 1; Dkt. 14.

22 Defendants have yet to answer the Amended Complaint.

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 parties are currently working in good faith to determine whether this case may be resolved without further litigation. Since the last extension, Plaintiff Awal’s application has been approved. To give the parties time to discuss potential resolution of this case, as well as allow the government additional time for further expedited administrative processing of Plaintiff Krishnan’s case, the parties stipulate and jointly request that the Court extend Defendants’ time to respond to the Complaint until April 21, 2023.

7 SO STIPULATED.

8 Dated this 7th day of April, 2023.

9 FOX ROTHSCHILD LLP NICHOLAS W. BROWN United States Attorney s/Al Roundtree s/ Katie D. Fairchild AL ROUNDTREE, WSBA #54851 KATIE D. FAIRCHILD, WSBA #47712 1001 Fourth Ave, Suite 440 Assistant United States Attorney Seattle, WA 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 14 Fax: 206-553-4067 Email: [email protected] FRAGOMEN, DEL REY, BERNSEN & LOEWY, LLP Attorney for Defendants I certify that this memorandum contains s/ Carl Hampe 201 words, in compliance with the Local Carl W. Hampe (Pro Hac Vice) Civil Rules.

18 Daniel P. Pierce (Pro Hac Vice) 1101 15th Street NW, Suite 700 Washington, DC 20005 Phone: 202-223-5515 Email: [email protected] Email: [email protected] Attorneys for Plaintiffs 1 ORDER 2 The parties having stipulated and agreed, it is hereby so ORDERED.

3 DATED this 10th day of April, 2023.

5 & Aare L otditein, BARBARA J. ROTHSTEIN 6 United States District Judge 1] JOINT STIPULATION AND UNITED STATES ATTORNEY [PROPOSED] ORDER TO EXTEND DEADLINE 700 STEWART STREET, SUITE 5220