Chung v. United States Citizenship and Immigration Services

7 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE MYUNG BIN CHUNG, Case No. 2:25-cv-00202-JHC Plaintiff, STIPULATED MOTION TO HOLD 11 v. CASE IN ABEYANCE AND ORDER UNITED STATES CITIZENSHIP AND Noted for Consideration: IMMIGRATION SERVICES, et al., June 2, 2025 Defendants.

15 For good cause, Plaintiff 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 continue to stay these proceedings until July 3, 2025. Plaintiff brings this litigation pursuant to the Mandamus Act seeking to compel the U.S. Citizenship and Immigration Services (“USCIS”) to adjudicate her Form I-485, Application to Register Permanent Residence or Adjust Status. This case is currently stayed through June 3, 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. 2 P. 1.

3 With additional time, this case may be resolved without the need of further judicial intervention. USCIS received Plaintiff’s response to the Notice of Intent to Deny (“NOID”) the application on April 23, 2025. USCIS is finalizing its review of the application and is preparing to issue its decision shortly. As additional time is necessary for this to occur, the parties respectfully request that the instant action continue to be stayed until July 3, 2025. The parties will submit a joint status report on or before July 3, 2025.

9 DATED this 2nd day of June, 2025.

10 Respectfully submitted, 11 TEAL LUTHY MILLER Acting United States Attorney s/ Michelle R. Lambert 13 MICHELLE R. LAMBERT, NYS #4666657 Assistant United States Attorney 14 United States Attorney’s Office Western District of Washington 15 1201 Pacific Avenue, Suite 700 Tacoma, Washington 98402 16 Phone: (253) 428-3800 Fax: (253) 428-3800 17 Email: [email protected] 18 Attorneys for Defendants 19 I certify that this memorandum contains 241 words, in compliance with the Local Civil 20 Rules.

21 s/ Myung Bin Chung MYUNG BIN CHUNG 22 22920 80th Park West Edmonds, Washington 98026 23 Phone: 360-213-4916 Email: [email protected] 24 Pro Se Plaintiff 2 ORDER 3 The case is held in abeyance until July 3, 2025. The parties shall submit a joint status |{report on or before July 3, 2025. It is so ORDERED.

5 DATED this 2"¢ day of June, 2025.

g United States District Judge 1]