Andrew v. Mayorkas

1 District Judge James L. Robart 7 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE RWANGOKO ANDREW, Case No. 2:24-cv-01375-JLR Plaintiff, STIPULATED MOTION TO CONTINUE 1] v. DEADLINE AND [PROPOSED] ORDER || ALEJANDRO MAYORKAS, et al., Noted for Consideration: November 12, 2024 13 Defendants.

15 Plaintiff Rwangoko Andrew and Defendants, through their respective counsel, pursuant ||to Federal Rule of Civil Procedure 6 and Local Rules 10(g) and 16, and hereby jointly stipulate ||and move for a 45-day extension of the deadline for Defendants to respond to the Complaint. 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, 20 (9th Cir. 1986). Good cause exists to extend Defendants’ response deadline to December 21 2024.

22 Plaintiff brings this lawsuit pursuant to the Administrative Procedure Act and the ||Mandamus Act to compel the U.S. Citizenship and Immigration Services (“USCIS”) to |}adjudicate the Forms I-730, Refugee/Asylee Relative Petitions, that Plaintiff filed on behalf of STIPULATED MOTION AND [PROPOSED ORDER UNITED STATES ATTORNEY [Case No. 2:24-cv-01375-JLR] - 1 1201 PACIFIC AVE., STE. 700 his wife and children in December 2018. Recently, USCIS has transferred the petitions to the USCIS Nairobi Field Office for scheduling of the interviews. The parties seek this extension to allow the petitions to reach the Nairobi Field Office. At that time, the parties will have a better understanding of the timeframe required to complete the processing of the petitions.

5 Therefore, the parties agree to and propose that Defendants’ deadline to respond to the Complaint be extended to December 27, 2024.

7 DATED this 12th day of November, 2024.

8 Respectfully submitted, TESSA M. GORMAN SUMMIT LAW GROUP, PLLC United States Attorney s/ Michelle R. Lambert s/ Diana Siri Breaux MICHELLE R. LAMBERT, NYS #4666657 DIANA SIRI BREAUX, WSBA #46112 Assistant United States Attorney 315 Fifth Avenue S., Suite 1000 United States Attorney’s Office Seattle, WA 98104 Western District of Washington Phone: (206) 676-7000 1201 Pacific Avenue, Suite 700 Email: [email protected] Tacoma, Washington 98402 Phone: (253) 428-3824 Fax: (253) 428-3826 PATTERSON BELKNAP WEBB & TYLER Email: [email protected] LLP Attorneys for Defendants s/ Steven A. Zalesin STEVEN A. ZALESIN*, NYS #2070134 I certify that this memorandum contains 213 words, in compliance with the Local Civil Rules. s/ Stephanie Sofer 18 STEPHANIE SOFER*, NYS #5882477 19 s/ Emma Guido Brill EMMA GUIDO BRILL*, NYS #5562699 20 1133 Avenue of the Americas New York, NY 10036 21 Phone: (212) 336-2000 Email: [email protected] 22 Email: [email protected] Email: [email protected] 23 *Pro Hac Vice Admitted 24 Attorneys for Plaintiff 1 [PROPOSED] ORDER 2 Defendants’ deadline to respond to the Complaint is extended to December 27, 2024. It is so ORDERED.

5 DATED this _13th_ day of ____November_____, 2024.

6 A JAMES L. ROBART 8 United States District Judge