Aga v. Blinken

1 The Honorable Tana Lin 7 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE KADIR K. AGA, et al., Case No. 2:24-cv-00505-TL 10 Plaintiffs, STIPULATED MOTION TO HOLD CASE IN ABEYANCE AND 11 v. [PROPOSED] ORDER ANTHONY BLINKEN, et al., Noted for Consideration: June 21, 2024 13 Defendants.

15 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 until August 19, 2024. Plaintiffs bring this litigation pursuant to the Administrative Procedure Act and Mandamus Act seeking, inter alia, to compel the U.S. Embassy in Addis Ababa, Ethiopia, to complete processing of their visa applications.

20 Defendants’ response to the Complaint is currently due on June 21, 2024. For good cause, the parties request that the Court hold the case in abeyance until August 19, 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 case may be resolved without the need of further judicial intervention. The Embassy is currently reviewing information recently submitted by Plaintiffs. As additional time is necessary for this to occur, the parties request that the Court hold the case in abeyance until August 19, 2024. The parties will submit a status update on or before August 19, 2024.

8 DATED this 21th day of June, 2024.

9 Respectfully submitted, TESSA M. GORMAN OT’ESUSSLAL IMV.A GNO LRAMWA ONFFICE United States Attorney s/ Michelle R. Lambert s/ Jane Marie O’Sullivan MICHELLE R. LAMBERT, NYS #4666657 JANE MARIE O’SULLIVAN WSBA#34486 Assistant United States Attorney 2417 Pacific Avenue SE, 2nd Floor United States Attorney’s Office Olympia, Washington 98501 Western District of Washington Phone: (206) 340-9980 1201 Pacific Avenue, Suite 700 Email: [email protected] Tacoma, Washington 98402 Phone: (253) 428-3824 Fax: (253) 428-3826 (253) 428-38 Email: [email protected] Attorneys for Defendants Attorney for Plaintiffs I certify that this memorandum contains 231 words, in compliance with the Local Civil Rules.

1 [PROPOSED! ORDER 2 The case is held in abeyance until August 19, 2024. The parties shall submit a status || update on or before August 19, 2024. It is so ORDERED.

5 DATED this 25th day of June, 2024.

7 4.x Ze g ana Lin United States District Judge 1] STIPULATED MOTION FOR ABEYANCE UNITED STATES ATTORNEY [Case No. 2:24-cv-00505-TL] - 3 1201 PaciFiC AVE., STE. 700