Li v. Director of United States Citizenship and Immigration Services

7 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE HAO LI, Case No. 2:24-cv-00225-JHC Plaintiff, STIPULATED MOTION AND ORDER 11 TO CONTINUE DEADLINE v. 12 Noted for Consideration: DIRECTOR OF U.S. CITIZENSHIP AND April 18, 2024 IMMIGRATION SERVICES, 14 Defendant.

16 The parties, through their respective counsel, pursuant to Federal Rule of Civil Procedure 6 and Local Rules 10(g) and 16, hereby jointly stipulate and move for a 60-day extension of the deadline for Defendant to respond to the Complaint. The current deadline is April 26, 2024.

19 Good cause exists to extend this deadline to June 25, 2024.

20 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).

23 U.S. Citizenship and Immigration Services is in the process of procuring a copy of Plaintiff’s previously approved petition to assess the next steps in this case, including a possible resolution that would not require further judicial intervention. Once this petition is reviewed by an officer, the parties will be able to discuss how to move forward with this litigation.

3 Accordingly, the parties jointly stipulate and request that the Court extend Defendant’s deadline to respond to the Complaint to June 25, 2024.

5 DATED this 18th day of April, 2024.

6 Respectfully submitted, TESSA M. GORMAN KARR, TUTTLE, CAMPBELL TESSA M. GORMAN United States Attorney s/ Kripa Upadhyay 9 KRIPA UPADHYAY, WSBA #40063 s/ Michelle R. Lambert 701 Fifth Ave, Suite 3300 MICHELLE R. LAMBERT, NYS #4666657 Seattle, Washington 98104 Assistant United States Attorney Phone: (206) 224-8092 United States Attorney’s Office Email: [email protected] Western District of Washington 1201 Pacific Avenue, Suite 700 Tacoma, Washington 98402 Phone: (253) 428-3824 Fax: (253) 428-3826 Email: [email protected] Attorney for Plaintiff Attorneys for Defendant I certify that this memorandum contains 178 words, in compliance with the Local Civil Rules.

2 ORDER 3 It is so ORDERED. Defendant’s deadline to respond to the Complaint is extended to || June 25, 2024.

6 DATED this 18th day of April, 2024.

4. Chua JOHN H. CHUN 9 United States District Judge STIPULATED MOTION & ORDER UNITED STATES ATTORNEY [Case No. 2:24-cv-00225-JHC] - 3 1201 PaciFIC AVE.» STE. 700