Barrows v. Schofer

1 District Judge Ricardo S. Martinez

7 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE JENNIFER LYNN BARROWS, Case No. 2:24-cv-00598-RSM Plaintiff, STIPULATED MOTION TO HOLD 11 CASE IN ABEYANCE AND ORDER v. 12 Noted for Consideration: ANDREW SCHOFER, et al., September 23, 2024 Defendants.

15 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 through November 22, 2024. Plaintiff brings this litigation pursuant to the Administrative Procedure Act and Mandamus Act seeking, inter alia, to compel Defendants to complete processing of Plaintiff’s husband’s immigrant visa application. This case is currently stayed at the request of the parties. Dkt. No. 8. For good cause, the parties request that the Court hold this case in abeyance through November 22, 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 As described previously, the U.S. Embassy in Islamabad, Pakistan, returned Plaintiff’s Form I-130, Petition for Alien Relative, to U.S. Citizenship and Immigration Services (“USCIS”) with a recommendation that the petition be revoked. Today, USCIS completed its review and reaffirmed its approval of the Form I-130. The reaffirmation has been sent to the Department of State’s National Visa Center. Due to the recency of this action, the parties need time to confer and to determine next steps for this litigation.

9 Accordingly, the parties respectfully request that the instant action be stayed until November 22, 2024. The parties will submit a joint status report on or before November 22, 2024.

12 DATED this 23rd day of September, 2024.

13 Respectfully submitted, TESSA M. GORMAN GOLDSTEIN IMMIGRATION LAWYERS United States Attorney s/ Michelle R. Lambert s/ Joshua L. Goldstein MICHELLE R. LAMBERT, NYS #4666657 JOSHUA L. GOLDSTEIN, WSBA #61773 Assistant United States Attorney 611 Wilshire Boulevard, Ste. 317 United States Attorney’s Office Los Angeles, California 90017 Western District of Washington Phone: (213) 425-1979 1201 Pacific Avenue, Suite 700 Email: [email protected] Tacoma, Washington 98402 Phone: (253) 428-3824 Attorney for Plaintiff Fax: (253) 428-3826 Email: [email protected] Attorneys for Defendants I certify that this memorandum contains 275 words, in compliance with the Local Civil Rules.

1 ORDER 2 The case is held in abeyance until November 22, 2024. The parties shall submit a joint status report on or before November 22, 2024. It is so ORDERED.

5 DATED this 24th day of September, 2024.

6 A RICARDO S. MARTINEZ 8 UNITED STATES DISTRICT JUDGE