Ramirez v. Jaddou

District Judge Jamal N. Whitehead

7 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE MAYNOR ANTONIO RAMIREZ, No. 2:24-cv-550-JNW Plaintiff, STIPULATED MOTION TO HOLD 11 CASE IN ABEYANCE AND ORDER v. 12 Noted for Consideration on: UR MENDOZA JADDOU, et al., June 18, 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 August 23, 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 his Form I-918, Application for U Nonimmigrant Status, and Form I-765, Application for Employment Authorization.

Defendants’ deadline to respond to the Complaint is June 24, 2024. For good cause, the parties request that the Court hold this case in abeyance until August 23, 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 USCIS needs additional time to review this case for possible resolution. USCIS is assessing whether Plaintiff’s applications are eligible for expedited adjudication, which would moot this case. Because Plaintiff filed the applications approximately one month prior to commencing this litigation, Plaintiff’s applications may not be eligible for expedited adjudication.

7 In that case, the parties will confer about how to proceed with this litigation. Accordingly, the parties respectfully request that the instant action be stayed until August 23, 2024. The parties will submit a joint status report on or before August 23, 2024.

10 Dated: June 18, 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 2 The case is held in abeyance until August 23, 2024. The parties shall submit a joint status report on or before August 23, 2024. It is so ORDERED.

DATED this 20th day of June, 2024.

A Jamal N. Whitehead 9 United States District Judge