Ibrahim v. Drake

1 The Honorable Benjamin H. Settle UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT SEATTLE ADAN YUSUF IBRAHIM, Plaintiff, No. 2:23-cv-01755-BHS-TLF v. STIPULATED MOTION AND 13 ORDER FOR RELIEF FROM A DRAKE, Corrections Officer Sergeant; DEADLINE EDMOND, Corrections Officer; PORTER, Corrections Officer; BATCHILY, Corrections Officer; MENDOZA, Corrections Officer; NOTED ON MOTION CALENDAR: VELASQUES, Corrections Officer, March 14, 2025 Defendants.

20 STIPULATION 21 Plaintiff Adan Yusuf Ibrahim respectfully seeks an extension of seven days, to March 28, 2025, to file his response to the Court’s Order to Show Cause, Dkt. No. 65.

23 The parties, by and through their counsel, have agreed and stipulate as follows: 24 1. At the request of Defendants, the Court ordered Mr. Ibrahim to provide information regarding a King County Superior Court judgment entered against Washington Department of Social Health and Services on his behalf in 2023 in Cause No. 21-1-06662 SEA. See Dkt. No. 63 at 4-7; Dkt. No. 65.

1 2. The Court entered its Order on February 26, 2025, and ordered Mr. Ibrahim to respond by March 21, 2025. Dkt. No. 65.

3 3. Under LCR 7(j), a motion for relief from a deadline “should, whenever possible, be filed sufficiently in advance of the deadline to allow the court to rule on the motion prior to the deadline.” But “such motions are disfavored,” and LCR 7(j) instead encourages “the parties to meet and confer to file a stipulation and proposed order.” Taber v. Cascade Designs, Inc., No. 2:20-CV- 01633-TL, 2022 WL 2872521, at *6 (W.D. Wash. July 21, 2022) (citing LCR 7(j)).

8 4. Mr. Ibrahim’s pro bono counsel continues to investigate the circumstances and gather the facts surrounding the judgment at-issue so Mr. Ibrahim may provide the Court with the full context of the judgment. See Declaration of Nicholas Valera in support of Stipulated Motion For Relief From a Deadline. Mr. Ibrahim’s incarceration, the related obstacles to attorney-client communications, as well as his limited ability to assist, make Mr. Ibrahim’s preparation of his response to the Court’s Order especially time intensive. See id. 14 5. Mr. Ibrahim’s counsel has conferred with Defendants’ counsel and the parties agree that a modest extension is appropriate for Mr. Ibrahim to respond to the Court’s Order.

16 6. For these reasons, Mr. Ibrahim respectfully requests for the Court to grant his stipulated motion to extend the deadline for his response to the Court’s Order from March 21, 2025, to March 28, 2025.

1 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

2 DATED this 14th day of March, 2025.

DAVIS WRIGHT TREMAINE LLP LEESA MANION (she/her) 4 . .

King County Prosecuting Attorney By: s/ Nicholas A. Valera By: s/ Santiago Viola Villanueva || Nicholas A. Valera, WSBA #54220 Santiago Viola Villanueva, WSBA #54071 John Goldmark, WSBA #40980 Senior Deputy Prosecuting Attorney || 920 Fifth Avenue, Suite 3300 701 5" Avenue, Suite 600 Seattle, WA 98104-1610 Seattle, WA 98104 Telephone: (206) 622-3150 Telephone: (206) 477-1120 g || Fax: (206) 757-7700 Email: sviolavillanueva @ kingcounty.gov Email: [email protected] || Email: johngoldmark @dwt.com Attorneys for Plaintiff Attorney for Defendants ORDER Pursuant to stipulation, Plaintiff Adan Yusuf’s request for an extension to respond to the Court’s Order, Dkt. No. 65, is extended from March 21, 2025, to March 28, 2025. IT IS SO ORDERED.

18 DATED this 14th day of March, 2025.

The Honorable Benjamin H. Settle 23 United States District Judge STIPULATED MOTION AND ORDER FOR RELIEF FROM A DEADLINE (2:23- Davis Wright Tremaine LLP cv-01755-BHS-TLF) 920 Fifth Avenue, Suite 3300 CERTIFICATE OF SERVICE I hereby certify that on this day I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system which will send notification of each filing to all counsel of record.

DATED this 14th day of March, 2025.

7 By: s/ Nicholas A. Valera Nicholas A. Valera, WSBA #54220