Singh v. Jaddou

] District Judge Robert S. Lasnik 7 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE INDERJIT SINGH, et al., Case No. 2:24-cv-01598-RSL Plaintiffs, STIPULATED MOTION TO 1] v. HOLD CASE IN ABEYANCE AND ORDER 12 JADDOU, et al., 13 Defendants.

15 Plaintiffs and Defendants, by and through their counsel of record, pursuant to Federal 16 of Civil Procedure 6 and Local Rules 7(d)(1), 10(g) and 16, hereby jointly stipulate and |}move to hold this case in abeyance until April 28, 2025. Plaintiffs brought this litigation ||/pursuant to the Administrative Procedure Act and Mandamus Act seeking, inter alia, to compel ||the U.S. Citizenship and Immigration Services (“USCIS”) adjudicate their Form 1-589, ||Application for Asylum and for Withholding of Removal. Defendants’ response to the ||}Complaint is currently due on December 9, 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 April 28, 2025.

STIPULATED MOTION FOR ABEYANCE UNITED STATES ATTORNEY [Case No. 2:24-cv-01598-RSL] - 1 1201 PAcIFIC AVE., STE. 700 1 Courts have “broad discretion” to stay proceedings. Clinton v. Jones, 520 U.S. 681, 706 |1(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.

6 With additional time, this case may be resolved without the need of further judicial ||intervention. USCIS has scheduled Plaintiffs’ asylum interview for January 28, 2025. USCIS |Jagrees to diligently work towards completing the adjudication within 90 days of the interview, ||absent unforeseen or exceptional circumstances that would require additional time for |Jadjudication. If the adjudication is not completed within that time, USCIS will provide a status ||report to the Court. Plaintiffs will submit all supplemental documents and evidence, if any, to ||USCIS seven to ten days prior to the interview date. Plaintiffs recognize that failure to submit |}documents prior to the interview may require the interview to be rescheduled and the ||adjudication delayed. If needed, Plaintiffs will bring an interpreter to the interview, otherwise 15 interview will need to be rescheduled and the adjudication delayed. After the interview, |}USCIS will need time to adjudicate Plaintiffs’ asylum application. Once the application is ||adjudicated, Plaintiffs will dismiss the case with each party to bear their own litigation costs and ||attorneys’ fees. Accordingly, the parties request this abeyance to allow USCIS to conduct 19 Plaintiffs’ asylum interview and then process their asylum application.

20 As additional time is necessary for this to occur, the parties request that the Court hold ||the case in abeyance until April 28, 2025. The parties will submit a joint status report on or ||before April 28, 2025.

23 |}// STIPULATED MOTION FOR ABEYANCE UNITED STATES ATTORNEY [Case No. 2:24-cv-01598-RSL] - 2 1201 PAcIFIC AVE., STE. 700 ] DATED this 9th day of December, 2024.

2 ||Respectfully submitted, || TESSA M. GORMAN GIBBS HOUSTON PAUW United States Attorney s/ Michelle R. Lambert s/ Emily Simcock |}MICHELLE R. LAMBERT, NYS #4666657 EMILY SIMCOCK, WSBA #55635 Assistant United States Attorney 1000 Second Avenue, Suite 1600 ||United States Attorney’s Office Seattle, Washington 98104-1003 Western District of Washington Phone: (206) 682-1080 7 Pacific Avenue, Suite 700 Email: [email protected] Tacoma, Washington 98402 || Phone: (253) 428-3824 Attorney for Plaintiffs Fax: (253) 428-3826 ||Email: michelle.lambert@usdo}.gov || Attorneys for Defendants 11 certify that this memorandum contains 417 words, in compliance with the Local Civil Rules.

STIPULATED MOTION FOR ABEYANCE UNITED STATES ATTORNEY [Case No. 2:24-cv-01598-RSL] - 3 1201 PAcIFIC AVE., STE. 700 1 ORDER 2 The case is held in abeyance until April 28, 2025. The parties shall submit a joint status ||report on or before April 28, 2025. It is so ORDERED.

5 DATED this 10th day of December , 2024.

7 _ ROBERT S. LASNIK 8 United States District Judge 1] STIPULATED MOTION FOR ABEYANCE UNITED STATES ATTORNEY [Case No. 2:24-cv-01598-RSL] - 4 1201 PAcIFIC AVE., STE. 700