Al Khateeb v. United States Citizenship and Immigration Services

1 District Judge Tana Lin

7 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE MUATAZ YAHYA ABDULJABBAR Case No. 2:24-cv-00836-TL AL KHATEEB, STIPULATED MOTION FOR 11 Plaintiff, EXTENSION OF DEADLINE AND v. [PROPOSED] ORDER UNITED STATES CITIZENSHIP AND Noted for Consideration: IMMIGRATION SERVICES, et al., February 13, 2025 14 Defendants.

16 Plaintiff and Defendants, pursuant to Federal Rule of Civil Procedure 6 and Local Rule 10(g), and hereby jointly stipulate and move to extend the deadline for U.S. Citizenship and Immigration Services (“USCIS”) to render a final determination on Plaintiff’s N-400, Application for Naturalization, to thirty days after the agency receives Plaintiff’s response to the Notice of Intent to Deny (“NOID”). A court may modify a deadline for good cause. Fed. R. Civ. P. 6(b).

21 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).

23 Plaintiff brought this litigation pursuant to 8 U.S.C. § 1447(b), seeking adjudication of his naturalization application. On December 17, 2025, this Court remanded Plaintiff’s naturalization application to USCIS with instructions. Dkt. No. 13, Order. First, the Order requires USCIS to conduct a follow-up interview with Plaintiff within 30 days. Order, at 4. USCIS conducted this interview on January 15, 2025. Second, the Order requires USCIS to issue a final determination on Plaintiff’s naturalization application within 30 days of the follow-up interview. Id. The parties seek to extend this February 14, 2025 deadline for good cause.

6 On February 10, 2025, USCIS issued a NOID to Plaintiff. Plaintiff has until March 17, 2025 to respond to the NOID by submitting either a rebuttal or evidence to show that he can overcome the listed grounds of denial. Plaintiff intends to submit a response. Once USCIS receives Plaintiff’s response, it will need additional time to review it and issue a decision. The parties agree that 30 days from the date USCIS receives Plaintiff’s response is a reasonable period for this to occur. Plaintiff’s counsel agrees to notify Defendants’ counsel when the response is submitted and provide tracking information.

13 As additional time is necessary for this to occur, the parties move to extend USCIS’s deadline to issue a determination to 30 days from the date that USCIS receives Plaintiff’s response to the NOID. The parties will submit a joint status report within 7 days of completion of adjudication by USCIS.

18 // // // // 1 DATED this 13th day of February, 2025 Respectfully submitted, TEAL LUTHY MILLER GAIRSON LAW, LLC Acting United States Attorney s/ Michelle R. Lambert s/ Jay Gairson MICHELLE R. LAMBERT, NYS #4666657 JAY GAIRSON, WSBA No. 43365 Assistant United States Attorney Gairson Law, LLC United States Attorney’s Office 4606 Martin Luther King Jr.. Way S.

Western District of Washington Seattle, Washington 98108 1201 Pacific Avenue, Suite 700 Phone: 206-357-4218 Tacoma, Washington 98402 Email: [email protected] Phone: (206) 553-7970 Attorneys for Plaintiff Fax: (206) 553-4067 Email: [email protected] Attorneys for Defendants I certify that this memorandum contains 345 words, in compliance with the Local Civil Rules.

[PROPOSED] ORDER IS SO ORDERED.

DATED this 14th day of February, 2025.

20 A 21 Tana Lin United States District Judge