Mahmood v. Bitter

1 District Judge Tana Lin

7 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE SONYA SHAFQAT MAHMOOD, Case No. 2:24-cv-01646-TL Plaintiff, STIPULATED MOTION TO HOLD 11 v. CASE IN ABEYANCE AND [PROPOSED] ORDER RENA BITTER, et al., Noted for Consideration: 13 Defendants. June 18, 2025 15 Pursuant 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 stay these proceedings until July 18, 2025. Plaintiff brought this litigation pursuant to the Mandamus Act and the Administrative Procedure Act seeking, inter alia, to compel Defendants to readjudicate Plaintiff’s fiancé’s nonimmigrant visa application. On May 30, 2025, this Court granted in part and denied in part Defendants’ Motion to Dismiss and denied Plaintiff’s cross-motion for summary judgment. Dkt. No. 23, Order. As a result, Defendants’ response to the Amended Complaint (Dkt. No. 9) is currently due on June 19, 2025. The Court also issued an Order setting initial scheduling dates. Dkt. No. 24. Due to recent developments, 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. Plaintiff’s fiancé’s visa application is currently refused under 8 U.S.C. § 1201(g), as additional security screening was required. On May 19, 2025, the U.S. Embassy in Islamabad, Pakistan, reached out to Plaintiff’s fiancé to obtain additional documentation. Additional time is needed to allow for this information to be submitted and then for the Embassy to review and process this information, which may lead to readjudication of the visa application. The parties agree that a readjudication of the visa application may moot out this litigation in its entirety.

13 Accordingly, the parties request that the Court hold the case in abeyance until July 18, 2025. The parties further request that the Order Regarding Initial Disclosures, Joint Status Report, and Early Settlement be vacated. Dkt. No. 24. The parties will submit a joint status report on or before July 18, 2025.

17 // // // // 24 DATED this 18th day of June, 2025.

Respectfully submitted, TEAL LUTHY MILLER DAVIS NDANUSA IKHLAS & SALEEM Acting United States Attorney LLP s/ Michelle R. Lambert s/ Mohammed A. Saleem MICHELLE R. LAMBERT, NYS #4666657 MOHAMMED A. SALEEM, PHV Assistant United States Attorney Davis Ndanusa Ikhlas & Saleem LLP United States Attorney’s Office 26 Court Street, Suite 603 Western District of Washington Brooklyn, New York 11242 1201 Pacific Avenue, Suite 700 Phone: 718-783-6819 Tacoma, Washington 98402 Email: [email protected] Phone: (253) 428-3824 Fax: (253) 428-3826 OPEN SKY LAW, PLLC Email: [email protected] 9 s/ Devin T. Theriot-Orr Attorneys for Defendants DEVIN T. THERIOT-ORR, WSBA# 33995 10 Open Sky Law, PLLC I certify that this memorandum contains 365 20415 72nd Avenue S. Suite 110 words, in compliance with the Local Civil Rules. Kent, Washington 98032 Phone: 206-962-5052 12 Email: [email protected] Attorneys for Plaintiff 1 [PROPOSED] ORDER 2 The case is held in abeyance until July 18, 2025. The Order Regarding Initial Disclosures, Joint Status Report, and Early Settlement is vacated. Dkt. No. 24. The parties shall submit a joint status report on or before July 18, 2025. It is so ORDERED.

6 DATED this 20th day of June, 2025.

A Tana Lin 9 United States District Judge