Vasquez Garcia v. Jaddou

District Judge Robert S. Lasnik 7 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE DINORA ELIZABETH VASQUEZ No. 2:23-cv-1345-RSL GARCIA, STIPULATED MOTION TO HOLD 11 Plaintiff, CASE IN ABEYANCE AND ORDER 12 v. 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 for 90 days. 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 January 29, 2024.

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. P.1.

3 With additional time, this case may be resolved without the need of further judicial intervention. On October 23, 2023, USCIS issued a Request for Evidence (“RFE”) to Plaintiff.

5 She has until January 18, 2024 to respond to the RFE. Once USCIS receives this response, the agency can continue processing the applications. Accordingly, the parties respectfully request that the instant action be stayed until January 29, 2024. The parties will submit a joint status report on or before January 29, 2024. The parties further request that this Court vacate its Order Regarding Initial Disclosures, Joint Status Report, and Early Settlement. Dkt. No. 6.

10 Dated: October 25, 2023 Respectfully submitted, TESSA M. GORMAN 12 Acting United States Attorney 13 s/Michelle R. Lambert MICHELLE R.LAMBERT, NYS #4666657 14 Assistant United States Attorney United States Attorney’s Office 1201 Pacific Avenue, Suite 700 16 Tacoma, Washington 98402 Phone: 253-428-3824 17 Email: [email protected] Attorneys for Defendants I certify that this memorandum contains words, in compliance with the Local 20 Civil Rules.

21 s/Katherine H. Rich KATHERINE H. RICH, WSBA#46881 22 Rich Immigration PC 1207 N. 200th Street, Suite 214b Shoreline, Washington 98133 24 Phone: 206-853-4073 Email: [email protected] 25 Attorney for Plaintiff ] 9 ORDER 3 The case is held in abeyance until January 29, 2024. The parties shall submit a joint || status report on or before January 29, 2024. The Order Regarding Initial Disclosures, Joint Status Report, and Early Settlement is vacated and stricken. Dkt. No. 6. It isso ORDERED.

7 DATED this 26th day of October, 2023.

MW S Carcwik ROBERT S. LASNIK 10 United States District Judge 1] STIPULATED MOTION -3 UNITED STATES ATTORNEY (23-cv-1345-RSL) 700 STEWART STREET, SUITE 5220