Wang v. Jaddou

7 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE DONG WANG, Case No. 2:24-cv-01733-RSL Plaintiff, STIPULATED MOTION TO HOLD 11 v. CASE IN ABEYANCE AND ORDER UR MENDOZA JADDOU, et al., 13 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 July 10, 2025. Plaintiff 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 her Form I-589, Application for Asylum and for Withholding of Removal. Defendants’ response to the Complaint is currently due on December 10, 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 July 10, 2025.

1 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. 5 P. 1.

6 With additional time, this case may be resolved without the need of further judicial intervention. USCIS has scheduled Plaintiff’s asylum interview for March 12, 2025. USCIS agrees to diligently work towards completing the adjudication within 120 days of the interview, absent unforeseen or exceptional circumstances that would require additional time for adjudications. If the adjudication is not completed within that time, USCIS will provide a status report to the Court. Plaintiff will submit all supplemental documents and evidence, if any, to USCIS seven to ten days prior to the interview date. Plaintiff recognizes that failure to submit documents prior to the interview may require the interview to be rescheduled and the adjudication delayed. If needed, Plaintiff will bring an interpreter to the interview, otherwise the interview will need to be rescheduled and the adjudication delayed. After the interview, USCIS will need time to adjudicate Plaintiff’s asylum application. Once the application is adjudicated, Plaintiff 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 Plaintiff’s asylum interview and then process her asylum applications.

20 As additional time is necessary for this to occur, the parties request that the Court hold the case in abeyance until July 10, 2025. The parties will submit a joint status report on or before July 10, 2025.

23 // // 1 DATED this 10th day of January, 2025.

2 Respectfully submitted, TESSA M. GORMAN LAW OFFICES OF DENNIS LAM, PLLC United States Attorney s/ Michelle R. Lambert s/ Dennis Lam MICHELLE R. LAMBERT, NYS #4666657 DENNIS LAM, WSBA #22899 Assistant United States Attorney 15921 NE 8th Street, Ste. C-208 United States Attorney’s Office Bellevue, Washington 98008 Western District of Washington Phone: (206) 682-9233 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 412 words, in compliance with the Local Civil Rules.

1 ORDER 2 The case is held in abeyance until July 10, 2025. The parties shall submit a joint status report on or before July 10, 2025. It is so ORDERED.

5 DATED this 13th day of January, 2025.

8 ROBERT S. LASNIK United States District Judge