Pazouki v. Noem

1 The Honorable Tana Lin

7 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE AMIRHOSSEIN PAZOUKI, Case No. 2:25-cv-00211-TL Plaintiff, STIPULATED MOTION TO HOLD 11 CASE IN ABEYANCE AND v. [PROPOSED] ORDER KRISTI NOEM, et al.,1 Noted for Consideration: 13 March 3, 2025 Defendants.

15 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 June 17, 2025. Plaintiff brought this litigation pursuant to the Administrative Procedure Act seeking, inter alia, to compel U.S. Citizenship and Immigration Services (“USCIS”) to schedule an interview and then adjudicate his N-400, Application for Naturalization. Defendants’ response to the Complaint is currently due on April 8, 2025. 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 June 17, 2025.

1 Pursuant to Federal Rule of Civil Procedure 25(d), Defendants substitute Senior Official Performing the Duties of the Director Kika Scott for Jennifer B. Higgins.

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 Here, with additional time, this case may be resolved without the need of further judicial intervention. USCIS has scheduled Plaintiff’s naturalization interview for March 19, 2025. After the interview, USCIS will need additional time to process and adjudicate Plaintiff’s N-400. Once adjudicated, this case will be moot. The parties agree that holding this case in abeyance through June 17, 2025, is appropriate. Therefore, the parties believe good cause exists for a stay in these proceedings to save the parties and this Court from spending unnecessary time and judicial resources on this matter.

13 Accordingly, the parties request that the Court hold the case in abeyance until June 17, 2025. The parties will submit a status update on or before June 17, 2025.

15 DATED this 3rd day of March, 2025.

16 Respectfully submitted, TEAL LUTHY MILLER GIBBS HOUSTON PAUW Acting United States Attorney s/ Michelle R. Lambert s/ Kelly Vomacka MICHELLE R. LAMBERT, NY No. KELLY VOMACKA, WSBA No. 20090 4666657 1000 Second Avenue, Suite 1600 20 Seattle, Washington 98102 s/ Sarah Louise Bishop Phone: (206) 682-1080 SARAH LOUISE BISHOP, NY No. 5256359 Email: [email protected] Assistant United States Attorneys United States Attorney’s Office Attorney for Petitioner Western District of Washington 1201 Pacific Avenue, Suite 700 Tacoma, Washington 98402 Phone: (206) 553-7970 Fax: (206) 553-4067 Email: [email protected] 2 [email protected] Attorneys for Defendants I certify that this memorandum contains 302 words, in compliance with the Local Civil Rules.

1 [PROPOSED] ORDER 2 The case is held in abeyance until June 17, 2025. The parties shall submit a status update on or before June 17, 2025.

4 It is so ORDERED.

5 DATED this 3rd day of March, 2025 A Tana Lin United States District Judge