Ahmed v. Mayorkas

7 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE HAYAT A., Case No. 2:24-cv-01113-JHC Plaintiff, STIPULATED MOTION FOR 11 v. EXTENSION & ORDER ALEJANDRO MAYORKAS, et al., Noted for Consideration: September 26, 2024 13 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 for a 30-day extension of Defendants’ deadline to respond to the Complaint. Plaintiff brought this litigation pursuant to the Administrative Procedure Act and Mandamus Act, inter alia, to compel U.S. Citizenship and Immigration Services (“USCIS”) to adjudicate her asylum application.

20 Defendants’ response to the Complaint is currently due on September 30, 2024. The parties are currently working towards a resolution to this litigation. For good cause, the parties request that the Court extend the deadline until October 30, 2024. This is the first request for an extension of this deadline.

1 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).

4 USCIS is in the process of scheduling Plaintiff’s asylum interview. However, additional time is necessary to do so. The interview must occur prior to adjudication of the application at issue here. Once the interview is scheduled, the parties will discuss how to move forward with this litigation.

8 As additional time is necessary for this to occur, the parties request that the Court extend Defendants’ deadline to respond to the Complaint to October 30, 2024.

10 DATED this 26th day of September, 2024.

Respectfully submitted, TESSA M. GORMAN THE LAW OFFICES OF KARIN TOLGU United States Attorney PLLC s/ Michelle R. Lambert s/ Karin Tolgu MICHELLE R. LAMBERT, NYS #4666657 KARIN TOLGU, WSBA #42647 Assistant United States Attorney 110 Prefontaine Pl S.Ste. 304 United States Attorney’s Office Seattle, WA 98104 Western District of Washington Phone: (206) 218-9472 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 234 words, in compliance with the Local Civil Rules.

1 ORDER 2 The Defendants’ deadline to respond to the Complaint is extended to October 30, 2024.

3 is so ORDERED.

4 DATED this 26" day of September, 2024.

JOHN H. CHUN 7 United States District Judge 1]