Castaneda Valenzuela v. Nolan

UNITED STATES DISTRICT COURT FOR THE 5 WESTERN DISTRICT OF WASHINGTON AT SEATTLE JAIME RAMON CASTANEDA Case No. 2:24-cv-01441-RSL VALENZUELA, 8 STIPULATED MOTION TO HOLD Plaintiff, CASE IN ABEYANCE AND ORDER 9 v. CONNIE NOLAN, et al., 11 Defendants.

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 17, 2025. 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 his Form I-918 and Form I-765. Defendants’ response to the Complaint is currently due on November 18, 2024. The parties are currently working towards a resolution to this litigation. For good cause, the parties request that the Court hold the case in abeyance until January 17, 2025.

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. 2 P. 1.

3 With additional time, this case may be resolved without the need of further judicial intervention. USCIS is in the process of reviewing Plaintiff’s applications. Once the applications are adjudicated, Plaintiff will dismiss the case. As additional time is necessary for this to occur, the parties request that the Court hold the case in abeyance until January 17, 2025.

7 The parties will submit a status update on or before January 17, 2025.

8 DATED this 18th day of November, 2024.

9 Respectfully submitted, TESSA M. GORMAN GLOBAL LAW ADVOCATES, PLLC United States Attorney s/ Michelle R. Lambert s/ Inna Scott MICHELLE R. LAMBERT, NYS #4666657 INNA SCOTT, WSBA #46864 Assistant United States Attorney 655 South Orcas Street, Ste. 210 United States Attorney’s Office Seattle, Washington 98108 Western District of Washington Phone: (206) 774-8758 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 250 words, in compliance with the Local Civil Rules.

1 ORDER 2 The case is held in abeyance until January 17, 2025. The parties shall submit a status update on or before January 17, 2025. It is so ORDERED.

5 Dated this 19th day of November, 2024.

7 Robert S. Lasnik United States District Judge