University of Washington v. United States Department of Homeland Security

1 District Judge Tana Lin

UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT SEATTLE THE UNIVERSITY OF WASHINGTON, a Case No. 2:22-cv-01329-TL Washington State Agency; THE CENTER FOR HUMAN RIGHTS AT THE UNIVERSITY OF STIPULATION AND ORDER FOR WASHINGTON, a research center created by state EXTENSION OF TIME law; and ANGELA GODOY, Director of the Center for Human Rights at the University of Noted For Consideration: Washington, November 30, 2023 Plaintiffs, v. UNITED STATES DEPARTMENT OF HOMELAND SECURITY; and UNITED STATES IMMIGRATION AND CUSTOMS ENFORCEMENT, 18 Defendants.

The parties make the following stipulation and move to extend the trial date and related deadlines.

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).

1 The parties submit there is good cause for an extension of the deadline. Since the last extension, ICE has produced additional information and the parties have exchanged proposals in good faith on one remaining request. The parties are continuing to narrow the issues and remain hopeful that the matter can be resolved without briefing on the merits. The parties want to work through the few remaining issues expeditiously with using as little Court resources as possible.

6 Counsel have conferred and the parties jointly request that the below dates be extended based on the parties’ continuing efforts to date. The parties both agree that additional time is necessary in order to properly work through the issues in this case and resolve it without the need for motion practice or at least minimizing the number of issues that need to be brought to the Court’s attention. Continuing the existing deadlines for a limited time will allow the parties to efficiently address all issues for the Court’s review.

12 The parties propose the following deadlines: Deadline Current Date Extended Date Discovery Cutoff November 30, 2023 January 29, 2024 Dispositive Motions January 5, 2024 March 5, 2024 DATED this 30th day of November, 2023 // // DAVIS, WRIGHT, TREMAINE, LLP TESSA GORMAN Special Assistant Attorneys General Acting United States Attorney 3 s/ Nickolas Bohl s/ Daniel A. Fiedler NICKOLAS BOHL WSBA #48978 DANIEL A. FIEDLER, WSBA #56436 Assistant United States Attorney Fifth Avenue, Suite 3300 United States Attorney’s Office Seattle, WA 98104-1610 700 Stewart Street, Suite 5220 Phone: 206-622-3150 Seattle, Washington 98101-1271 Fax: 206-757-7700 Phone: 206-553-7970 Email: [email protected] Fax: 206-553-4067 7 Email: [email protected] Thomas R. Burke, Pro Hac Vice 505 Montgomery Street, Suite 800 Counsel for Defendants San Francisco, CA 94111-6533 Phone: 415-276-6552 I certify that this memorandum contains 248 Fax: 415-276-6599 words in compliance with the Local Rules.

10 Email: [email protected] Counsel for Plaintiffs

13 ORDER 14 The Parties having stipulated and agreed, it is hereby so ORDERED.

15 Dated this 30th day of November 2023.

A 17 Tana Lin United States District Judge