Haseli v. United States Department of State

1 District Judge Thomas S. Zilly

7 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE DR. SARA HASELI, et al., Case No. 2:23-cv-01753-TSZ Plaintiffs, STIPULATED MOTION TO HOLD 11 CASE IN ABEYANCE AND ORDER v. 12 Noted for Consideration: UNITED STATES DEPARTMENT OF March 26, 2024 STATE, et al., 14 Defendants.

16 Plaintiffs 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 through April 12, 2024. Plaintiffs bring this litigation pursuant to the Administrative Procedure Act to compel Defendants to complete processing of Plaintiff Nariman’s nonimmigrant visa application. For good cause, the parties request that this case be stayed through April 12, 2024.

22 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 litigation may be resolved in its entirety. Plaintiff Nariman’s visa was issued on March 25, 2024. It is anticipated that Nariman will receive the physical visa shortly. Once the visa is obtained, Plaintiffs will dismiss this litigation. Accordingly, the parties jointly stipulate and request that the Court stay these proceedings through April 12, 2024. The parties will submit a joint status report on or before April 12, 2024.

8 DATED this 26th day of March, 2024.

9 Respectfully submitted, TESSA M. GORMAN SOUND IM MIGRATIO N United States Attorney /s/Michelle R. Lambert s/Greg McLawsen MICHELLE R. LAMBERT, NYS #4666657 GREG MCLAWSEN, WSBA #41870 Assistant United States Attorney 113 Cherry Street, ECM# 45921 United States Attorney’s Office Seattle, Washington 98104 Western District of Washington Phone: (855) 809-5115 1201 Pacific Avenue, Suite 700 Email: [email protected] Tacoma, Washington 98402 Phone: (253) 428-3824 Email: [email protected] Attorneys for Defendants MCCANDLISH HOLTON, PC I certify that this memorandum contains 216 s/David E. Gluckman words, in compliance with the Local Civil DAVID E. GLUCKMAN, PHV, VA No.76773 Rules. 1111 East Main Street, Ste. 2100 19 Richmond, Virginia 23219 Phone: (804) 775-3826 20 Email: [email protected] Attorneys for Plaintiffs

1 ORDER The parties having stipulated and agreed, it is hereby so ORDERED. The parties shall file a joint status report on or before April 12, 2024.

4 DATED this 27th day of March, 2024.

A THOMAS S. ZILLY 7 United States District Judge