Galvez v. Jaddou

UNITED STATES DISTRICT COURT FOR THE 7 WESTERN DISTRICT OF WASHINGTON AT SEATTLE LEOBARDO MORENO GALVEZ, CASE NO. 2:19-cv-00321-RSL et al., STIPULATED MOTION AND ORDER FOR 10 Plaintiffs, EXTENSION OF DEADLINE v. UR JADDOU, et al., Defendants.

COME NOW, Plaintiffs and Defendants, by and through their counsel of record, pursuant to Federal Rule of Civil Procedure 6 and Local Rules 10(g) and 16, and hereby jointly stipulate and move for an extension of 14 days until July 28, 2023 for the parties to submit a joint status report.

A court may modify a deadline for good cause. Fed. R. Civ. P. 6(b). Continuing 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 previously attempted to achieve a negotiated settlement of Plaintiffs’ claims. Dkt. 85. That attempt was unsuccessful, and the Court directed the parties to submit a joint status report on or before July 14, 2023. Id. The Court ordered the parties to propose amendments to the current permanent injunction that “are consistent with the Ninth Circuit’s instructions and analysis.” Id. The Defendants are consulting on a proposal and need additional time to complete that work.

3 Therefore, the parties believe good cause exists for a brief stay to allow the parties to prepare the joint status report. In light of the above, the parties jointly stipulate and request that the Court: 1. Extend until July 28, 2023 the deadline for the parties to submit a joint status report.

7 DATED this 29th day of June, 2023.

8 TESSA M. GORMAN Acting United States Attorney s/ Matt Waldrop s/ Matt Adams MATT WALDROP, GA. BAR # 349571 MATT ADAMS, WSBA # 28287 Assistant United States Attorney Northwest Immigrant Rights Project United States Attorney’s Office 615 Second Avenue, Suite 400 Stewart Street, Suite 5220 Seattle, WA 98104 Seattle, Washington 98101-1271 Phone: (206) 957-8611 Phone: 206-553-7970 Email: [email protected] Email: [email protected] Attorney for Plaintiffs Attorneys for Defendants I certify that this memorandum contains 216 words, in compliance with the Local Rules.

1 ORDER 2 The parties having stipulated and agreed, it is hereby so ORDERED.

4 DATED this 30th day of June, 2023.

7 ROBERT S. LASNIK UNITED STATES DISTRICT JUDGE