Aboul El Hosn v. United States Department of Homeland Security

1 The Honorable Jamal N. Whitehead

7 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE RABIH ABOUL EL HOSN, Case No. 2:25-cv-00188-JNW Plaintiff, STIPULATED MOTION AND 11 v. [PROPOSED] ORDER TO STAY PROCEEDINGS U.S. DEPARTMENT OF HOMELAND SECURITY; KRISTI NOEM, Secretary of Homeland Security; CALEB VITELLO, Acting Director of U.S. Immigration and Customs Enforcement; DREW BOSTOCK, Field Office Director for Immigration and Customs Enforcement, Seattle; U.S. DEPARTMENT OF STATE; MARCO RUBIO, Secretary of State, Defendants.

19 Under Federal Rule of Civil Procedure 6 and Local Rules 7(d)(1), 10(g) and 16, Plaintiff and Defendants stipulate and jointly move to stay this case for six months until January 15, 2026.

21 Courts have “broad discretion” to stay proceedings. Clinton v. Jones, 520 U.S. 681, 706 (1997).

22 “[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.

1 Here, the parties ask for time to work toward a resolution that may resolve this case without the need for judicial intervention, conserving the parties’ and the Court’s resources. The parties agree an order by the Board of Immigration Appeals (BIA) reopening Plaintiff’s immigration proceedings restored his prior status as a legal permanent resident (LPR). Plaintiff requires a replacement LPR card and intends to complete a necessary biometrics appointment abroad to finalize his application for a replacement card. The parties request time for Plaintiff to schedule and complete that appointment, and for U.S. Citizenship and Immigration Services (USCIS) to adjudicate his application once completed. If USCIS is unable to adjudicate the application by the time the stay expires, it will provide a status report to the Court. If the application is approved, Plaintiff will dismiss this case, with each party to bear their own costs and fees, if any.

12 So stipulated.

13 Respectfully submitted July 15, 2025, 14 s/ Benjamin E. Stein BENJAMIN E. STEIN 15 Attorney for Plaintiff SRR Law Group 16 600 25th Ave S. Ste 104 St. Cloud, MN 56301 17 Phone: 320-448-8060 Email: [email protected] —and— TEAL LUTHY MILLER 20 Acting United States Attorney 21 s/ Annalisa L. Cravens ANNALISA L. CRAVENS 22 Assistant United States Attorney United States Attorney’s Office 23 700 Stewart Street, Suite 5220 Seattle, Washington 98101 24 Phone: 206-553-7970 1 Fax: 206-553-4067 Email: [email protected] s/ Michelle R. Lambert 3 MICHELLE R. LAMBERT Assistant United States Attorney 4 United States Attorney’s Office 1201 Pacific Avenue, Suite 1201 5 Tacoma, Washington 98402 Phone: 253-428-3824 6 Fax: 253-428-3826 Email: [email protected] Counsel for Defendants I certify this motion contains 252 words, 9 in compliance with the Local Civil Rules.

1 [PROPOSED] ORDER 2 It is hereby ORDERED the parties’ motion is GRANTED.

DATED this 17th day of July, 2025.

a HON. JAMAL N. WHITEHEAD United States District Judge