Mogha v. United States

1 District Judge Robert S. Lasnik 7 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE ATUL MOGHA, et al, Case No. 2:25-cv-00296-RSL Plaintiffs, STIPULATED MOTION TO HOLD 11 v. CASE IN ABEYANCE AND ORDER |} UNITED STATES OF AMERICA, et al., 13 Defendants.

15 For good cause, 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 September 15, 2025. Plaintiffs brought |/this litigation pursuant to the Administrative Procedure Act and Mandamus Act seeking, inter |lalia, to compel Defendants to adjudicate Plaintiffs’ Form I-485, Application to Register 20 Permanent Residence or Adjust Status. Defendants’ response to the Complaint is currently due 21 April 25, 2025.

22 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 STIPULATED MOTION FOR ABEYANCE UNITED STATES ATTORNEY [Case No. 2:25-cv-00296-RSL] - 1 1201 PAcIFIC AVE., STE. 700 ] |Jcounsel, and for litigants.” Landis v. N. Am. Co., 299 U.S. 248, 254 (1936); see also Fed. R. Civ. 2 1.

3 With additional time, this case may be resolved without the need of further judicial |Jintervention. U.S. Citizenship and Immigration Services (“USCIS”) issued a Request for ||Evidence (“RFE”) to Plaintiffs last week. Plaintiffs have until July 14, 2025, to respond to the 6 USCIS will need additional time to review the RFE response and then continue processing Plaintiffs’ Form I-485. Therefore, the parties believe good cause exists to stay these proceedings ||to save the parties and this Court from spending unnecessary time and judicial resources on this |}matter.

10 Accordingly, the parties request that the Court hold the case, including all interim ||deadlines, in abeyance until September 15, 2025. If this case is not resolved, the parties will ||submit a proposed briefing schedule by September 15, 2025.

16 ||// ||// STIPULATED MOTION FOR ABEYANCE UNITED STATES ATTORNEY [Case No. 2:25-cv-00296-RSL] - 2 1201 PACIFIC AVE., STE. 700 1 DATED this 22nd day of April, 2025.

2 ||Respectfully submitted, TEAL LUTHY MILLER NIMER LAW LLC Acting United States Attorney Michelle R. Lambert s/ Jennifer Nimer || MICHELLE R. LAMBERT, NYS #4666657 JENNIFER NIMER (61962) Assistant United States Attorney Nimer Law LLC ||United States Attorney’s Office 6500 Emerald Parkway, Suite 100 Western District of Washington Dublin, Ohio 43016 7 Pacific Avenue, Suite 700 Phone: 614-927-0550 Tacoma, Washington 98402 Email: [email protected] Phone: (253) 428-3800 Fax: (253) 428-3826 SARRAF GENTILE LLP ||Email: [email protected] s/ Ronen Sarraf || Attorneys for Defendants RONAN SARRAF, PHV Sarraf Gentile LLP ||/ certify that this memorandum contains 279 10 Bond Street, Suite 212 words, in compliance with the Local Civil Great Neck, New York 11021 12 Rules. Phone: 516-699-8890 Email: [email protected] 13 Attorney for Plaintiff STIPULATED MOTION FOR ABEYANCE UNITED STATES ATTORNEY [Case No. 2:25-cv-00296-RSL] - 3 1201 PAcIFIC AVE., STE. 700 1 ORDER 2 The case, including all interim deadlines, is held in abeyance until September 15, 2025.

3 || The parties shall submit a status report on or before September 15, 2025. It is so ORDERED.

5 DATED this23rd day of April, 2025.

Mt S Carcwk ROBERT S. LASNIK 8 United States District Judge STIPULATED MOTION FOR ABEYANCE UNITED STATES ATTORNEY [Case No. 2:25-cv-00296-RSL] - 4 1201 PAcIFIC AVE., STE. 700