LNU v. United States

1 District Judge James L. Robart 7 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE RANJANI RAVI LNU, et al., No. 2:25-cv-330-JLR 10 Plaintiffs, STIPULATED MOTION TO HOLD CASE IN ABEYANCE AND 11 v. [P_R__O_P_O__S_E_D_] ORDER UNITED STATES OF AMERICA, et al., Noted for: April 23, 2025 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 alia, to compel Defendants to adjudicate Plaintiffs’ Form I-485, Application to Register Permanent Residence or Adjust Status. Defendants’ response to the Complaint is currently due on April 25, 2025.

21 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. P. 1.

2 With additional time, this case may be resolved without the need of further judicial intervention. U.S. Citizenship and Immigration Services (“USCIS”) has indicated that it is reviewing Plaintiffs’ Form I-485 applications and may be able to be issue a final decision shortly.

5 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.

7 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.

10 Dated: April 23, 2025 Respectfully submitted, s/ Jennifer Nimer TEAL LUTHY MILLER JENNIFER NIMER (61962) Acting United States Attorney Nimer Law LLC 6500 Emerald Parkway, Suite 100 s/ Kristen R. Vogel Dublin, Ohio 43016 KRISTEN R. VOGEL (NY NO. 519664) Phone: 614-927-0550 Assistant United States Attorney Email: [email protected] United States Attorney’s Office Stewart Street, Suite 5220 s/ Ronen Sarraf Seattle, Washington 98101-1271 RONEN SARRAF (Admitted pro hac vice) Phone: 206-553-7970 Sarraf Gentile LLP Email: [email protected] Bond Street, Suite 212 Great Neck, New York 11021 Attorneys for Defendants Phone: 516-699-8890 Email: [email protected] Attorneys for Plaintiffs I certify that this memorandum contains 262 words, in compliance with the Local Civil Rules.

1 [_P_R_O__P_O__S_E_D_] ORDER The case, including all interim deadlines, is held in abeyance until September 15, 2025. The parties shall submit a status report on or before September 15, 2025. It is so ORDERED.

4 DATED this 24th day of April, 2025.

A _______________________________ 7 JAMES L. ROBART United States District Judge