Salazar Segura v. Jaddou

District Judge John H. Chun 7 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE OCTAVIO NOE SALAZAR SEGURA, No. 2:23-cv-1528-JHC Plaintiff, STIPULATED MOTION TO HOLD 11 CASE IN ABEYANCE AND v. [PROPOSED] ORDER UR MENDOZA JADDOU, et al., Noted for Consideration on: January 8, 2024 14 Defendants.

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 March 15, 2024. 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 May 6, 2024.

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 has issued a Request for Evidence (“RFE”) to Plaintiff concerning the applications. Plaintiff has until April 4, 2024, to respond to the RFE. USCIS must receive and review this response before continuing with the processing of her applications. Accordingly, the parties respectfully request that the instant action be stayed until May 6, 2024. The parties will submit a joint status report on or before May 6, 2024.

9 Dated: January 8, 2024 Respectfully submitted, TESSA M. GORMAN 11 Acting United States Attorney 12 s/Michelle R. Lambert MICHELLE R. LAMBERT, NYS #4666657 13 Assistant United States Attorney United States Attorney’s Office 1201 Pacific Avenue, Suite 700 15 Tacoma, Washington 98402 Phone: 253-428-3824 16 Email: [email protected] Attorneys for Defendants I certify that this memorandum contains words, in compliance with the Local 19 Civil Rules.

20 s/Katherine H. Rich KATHERINE H. RICH, WSBA#46881 21 Rich Immigration PC 1207 N. 200th Street, Suite 214b Shoreline, Washington 98133 23 Phone: 206-853-4073 Email: [email protected] 24 Attorney for Plaintiff i ORDER 2 The case is held in abeyance until May 6, 2024. The parties shall submit a joint status report on or before May 6, 2024. It is so ORDERED.

5 DATED this 8 day of January, 2024. ok 4. Chua JOHN H. CHUN 8 United States District Judge MOTION 10 HOLD CASEIN ABEYANCE -3