Sanchez Acosta v. Jaddou

1 District Judge Jamal N. Whitehead

7 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON 8 AT TACOMA HERIBERTO SANCHEZ ACOSTA, Case No. 3:24-cv-05584-JNW Plaintiff, STIPULATED MOTION TO HOLD 11 CASE IN ABEYANCE AND v. [PROPOSED] ORDER UR MENDOZA JADDOU, et al., Noted for Consideration: 13 September 24, 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 until January 27, 2025. 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. For good cause, the parties request that the Court hold this case in abeyance until January 27, 2025.

23 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. 3 P. 1.

4 With additional time, this case may be resolved without the need of further judicial intervention. USCIS has issued a Request for Evidence (“RFE”) to Plaintiff concerning the applications. Plaintiff has until December 19, 2024, to respond to the RFE. USCIS must receive and review this response before continuing with the processing of his applications. Accordingly, the parties respectfully request that the instant action be stayed until January 27, 2025. The parties will submit a joint status report on or before January 27, 2025.

10 DATED this 24th day of September, 2024.

11 Respectfully submitted, TESSA M. GORMAN RICH IMMIGRATION PC TESSA M. GORMAN United States Attorney s/ Katherine H. Rich 14 KATHERINE H. RICH, WSBA #46881 s/ Michelle R. Lambert 1207 N. 200th Street, Suite 214b MICHELLE R. LAMBERT, NYS #4666657 Shoreline, Washington 98133 Assistant United States Attorney Phone: (206) 853-4073 United States Attorney’s Office Email: [email protected] Western District of Washington 1201 Pacific Avenue, Suite 700 Attorney for Plaintiff Tacoma, Washington 98402 Phone: (253) 428-3824 Fax: (253) 428-3826 (253) 428-38 Email: [email protected] Attorneys for Defendants I certify that this memorandum contains 252 words, in compliance with the Local Civil Rules.

[PROPOSED] ORDER The stipulated motion, Dkt. No. 6, is GRANTED. This case is held in abeyance until January 27, 2025. The parties shall submit a joint status report on or before January 27, 2025.

It is so ORDERED.

DATED this 25th day of September, 2024.

A 9 JAMAL N. WHITEHEAD United States District Judge