Pinacho Ramirez v. Jaddou

District Judge Ricardo S. Martinez

7 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE GLORIA GUADALUPE PINACHO No. 2:23-cv-1351-RSM RAMIREZ, STIPULATED MOTION TO HOLD 11 Plaintiff, CASE IN ABEYANCE AND ORDER 12 v. Noted for Consideration on: September 28, 2023 UR MENDOZA JADDOU, et al., Defendants.

16 Plaintiff 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 stay these proceedings until December 6, 2023. Plaintiff brings this litigation pursuant to the Administrative Procedure Act and Mandamus Act seeking, inter alia, to compel the U.S. Citizenship and Immigration Services (“USCIS”) to compel action on her and her derivative spouse’s Form I-918s, Applications for U Nonimmigrant Status, and Form I-765s, Applications for Employment Authorization. For good cause, the parties request that the Court hold this case in abeyance until December 6, 2023.

24 Courts have “broad discretion” to stay proceedings. Clinton v. Jones, 520 U.S. 681, 706 (1997). “[T]he power to stay proceedings is incidental to the power inherent in every court to control the disposition of the causes on its docket with economy of time and effort for itself, for counsel, and for litigants.” Landis v. N. Am. Co., 299 U.S. 248, 254 (1936); see also Fed. R. Civ. 2 P. 1.

3 With additional time, this case may be resolved without the need of further judicial intervention. USCIS is processing Plaintiff’s applications. However, Plaintiff’s spouse must attend a biometrics appointment scheduled for October 10, 2023, so that USCIS can process his applications. Accordingly, the parties respectfully request that the instant action be stayed until December 6, 2023. The parties will submit a joint status report on or before December 6, 2023.

8 Dated: September 28, 2023 Respectfully submitted, TESSA M. GORMAN 10 Acting United States Attorney 11 s/Michelle R. Lambert MICHELLE R. LAMBERT, NYS #4666657 12 Assistant United States Attorney United States Attorney’s Office 1201 Pacific Avenue, Suite 700 14 Tacoma, Washington 98402 Phone: 253-428-3824 15 Email: [email protected] Attorneys for Defendants I certify that this memorandum contains words, in compliance with the Local 18 Civil Rules.

19 s/Katherine H. Rich KATHERINE H. RICH, WSBA#46881 20 Rich Immigration PC 1207 N. 200th Street, Suite 214b Shoreline, Washington 98133 22 Phone: 206-853-4073 Email: [email protected] 23 Attorney for Plaintiff

ORDER 2 The case is held in abeyance until December 6, 2023. The parties shall submit a joint status report on or before December 6, 2023. It is so ORDERED.

DATED this 29th day of September, 2023.

A RICARDO S. MARTINEZ UNITED STATES DISTRICT JUDGE