Song v. Noem

1 District Judge Barabara J. Rothstein

7 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE SHENZHAO SONG, et al., Case No. 2:25-cv-00524-BJR Plaintiffs, STIPULATED MOTION TO HOLD 11 v. CASE IN ABEYANCE AND ORDER KRISTI NOEM, Secretary of U.S. Department of Homeland Security, et al., 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 August 2, 2025. Plaintiffs brought 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-130, Petitions for Alien Relatives, and Forms I-485, Applications to Register Permanent Residence or Adjust Status.

21 Defendants’ response to the Complaint is currently due on June 2, 2025. The parties are currently working towards a resolution to this litigation.

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 With additional time, this case may be resolved without the need of further judicial intervention. USCIS has scheduled Plaintiffs’ interviews for May 13, 2025. USCIS will continue processing the applications after the interviews are conducted. As additional time is necessary for this to occur, the parties request that the Court hold the case in abeyance until August 2, 2025. The parties will submit a joint status report on or before August 2, 2025.

11 DATED this 23rd day of April, 2025.

12 Respectfully submitted, TEAL LUTHY MILLER LAW OFFICES OF DENNIS LAM, PLLC Acting United States Attorney s/ Michelle R. Lambert s/ Dennis Lam MICHELLE R. LAMBERT, NYS #4666657 DENNIS LAM, WSBA# 22899 Assistant United States Attorney Law Offices of Dennis Lam, PLLC United States Attorney’s Office 15921 NE 8th Street, Ste. C-208 Western District of Washington Bellevue, Washington 98008 1201 Pacific Avenue, Suite 700 Phone: 206-682-9233 Tacoma, Washington 98402 Email: [email protected] Phone: (253) 428-3800 Attorneys for Plaintiffs Fax: (253) 428-3826 Email: [email protected] Attorneys for Defendants I certify that this memorandum contains 250 words, in compliance with the Local Civil Rules.

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

5 DATED this 24th day of April, 2025.

A 9 Barbara Jacobs Rothstein U.S. District Court Judge