Nazeman v. Jaddou

1 District Judge Tana Lin

7 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE PANTEA NAZEMAN, et al., Case No. 2:25-cv-00080-TL Plaintiffs, STIPULATED MOTION TO HOLD 11 v. CASE IN ABEYANCE AND [PROPOSED] ORDER KIKA SCOTT, et al.,1 Noted for Consideration: 13 Defendants. March 13, 2025 15 Plaintiffs 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 May 8, 2025. Plaintiffs bring 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 Forms I-485, Applications to Register Permanent Residence or Adjust Status. Defendants’ response to the Complaint is currently due on March 24, 2025. The parties are currently working towards a resolution to this Pursuant to Federal Rule of Civil Procedure 25(d), Defendants substitute Senior Official Performing the Duties of the Director Kika Scott for Ur Jaddou.

1 litigation. For good cause, the parties request that the Court hold the case in abeyance until May 8, 2025.

3 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. 7 P. 1.

8 This case involves four separate Form I-485 application; however, only the applications concerning Plaintiffs Godefay and Araya, as well as Plaintiffs Ramirez Magana and Montes remain at issue. USCIS has issued a Notice of Intent to Revoke (“NOIR”) to Plaintiffs Godefay and Araya, who have until April 8, 2025, to respond. Once USCIS receives a response, it will need additional time to review the response and continue processing the application. In regard to the application concerning Plaintiffs Ramirez Magana and Montes, Plaintiffs’ counsel is seeking to terminate pending removal proceedings so that USCIS will have jurisdiction to adjudicate the Form I-485.

16 Accordingly, the parties request that the Court hold the case in abeyance until May 8, 2025. The parties will submit a joint status report on or before May 8, 2025.

18 // // // // 1 DATED this 13th day of March, 2025.

2 Respectfully submitted, TEAL LUTHY MILLER LAW OFFICES OF BART KLEIN Acting United States Attorney s/ Michelle R. Lambert s/ Bart Klein MICHELLE R. LAMBERT, NYS #4666657 BART KLEIN, WSBA# 10909 Assistant United States Attorney Law Offices of Bart Klein United States Attorney’s Office 605 First Avenue, #500 Western District of Washington Seattle, Washington 98104 1201 Pacific Avenue, Suite 700 Phone: 206-755-5651 Tacoma, Washington 98402 Email: [email protected] Phone: (206) 553-7970 Fax: (206) 553-4067 Attorney for Plaintiff Email: [email protected] Attorneys for Defendants I certify that this memorandum contains 316 words, in compliance with the Local Civil Rules.

1 PROPOSED] ORDER 2 The case is held in abeyance until May 8, 2025. The parties shall submit a joint status ||report on or before May 8, 2025. It is so ORDERED.

5 DATED this 13th day of March 2025.

TANA LIN 8 United States District Judge STIPULATED MOTION FOR ABEYANCE UNITED STATES ATTORNEY [Case No. 2:25-cv-00080-TL] - 4 1201 PACIFIC AVE., STE. 700