Vasquez Garcia v. Jaddou

UNITED STATES DISTRICT COURT 7 WESTERN DISTRICT OF WASHINGTON AT SEATTLE DINORA ELIZABETH VASQUEZ No. 2:23-cv-1345-RSL GARCIA, 10 STIPULATED MOTION TO HOLD Plaintiff, CASE IN ABEYANCE AND ORDER v. UR MENDOZA JADDOU, et al., 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 an additional 60 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 Form I-918s, Applications for U Nonimmigrant Status, and Form I-765s, Applications for Employment Authorization, as well as her derivative spouse’s and child’s applications. For good cause, the parties request that the Court continue to hold this case in abeyance until March 29, 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 adjudicated Plaintiff’s Form I-918. USCIS anticipates adjudicating Plaintiff’s Form I-765 and her derivative spouse’s Form I-918 by January 29, 2024. At that time, Plaintiff’s applications will be fully adjudicated. However, USCIS needs additional time to adjudicate the derivatives’ applications. Accordingly, the parties respectfully request that the instant action be stayed until March 29, 2024. The parties will submit a joint status report on or before March 29, 2024.

10 Dated: January 23, 2024 Respectfully submitted, TESSA M. GORMAN 12 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

ORDER The case is held in abeyance until March 29, 2024. The parties shall submit a joint status report on or before March 29, 2024. It is so ORDERED.

Dated this 24th day of January, 2024.

ROBERT S. LASNIK 8 United States District Judge