G.B.E. v. Noem

7 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE G.B.E., Case No. 2:25-cv-01119-JHC Plaintiff, STIPULATED MOTION TO HOLD 11 v. CASE IN ABEYANCE AND ORDER KRISTI LA NOEM, et al., 13 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 stay these proceedings until January 8, 2026. Plaintiff brought this litigation pursuant to the Administrative Procedure Act and Mandamus Act, inter alia, to compel U.S. Citizenship and Immigration Services (“USCIS”) to adjudicate their asylum application. Defendants’ response to the Complaint is currently due on August 19, 2025. The parties are currently working towards a resolution to this litigation.

22 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 has scheduled Plaintiff’s asylum interview for September 10, 2025. USCIS agrees to diligently work towards completing the adjudications within 120 days of the interview, absent unforeseen or exceptional circumstances that would require additional time for adjudication. If the adjudication is not completed within that time, USCIS will provide a status report to the Court. Plaintiff will submit all supplemental documents and evidence, if any, to USCIS seven to ten days prior to the interview date. Plaintiff recognizes that failure to submit documents prior to the interview may require the interview to be rescheduled and the adjudication delayed. If needed, Plaintiff will bring an interpreter to the interview, otherwise the interview will need to be rescheduled and the adjudications delayed. Once the application is adjudicated, Plaintiff will dismiss the case. Accordingly, the parties request this abeyance to allow USCIS to conduct Plaintiff’s asylum interview and then process his asylum application.

15 As additional time is necessary for this to occur, the parties request that the Court hold the case in abeyance until January 8, 2026. The parties will submit a status update on or before January 8, 2026.

18 // // // // 1 DATED this 7th day of August, 2025.

2 Respectfully submitted, TEAL LUTHY MILLER O'SULLIVAN LAW OFFICE Acting United States Attorney s/ Michelle R. Lambert s/ Jane Marie O'sullivan MICHELLE R. LAMBERT, NYS #4666657 JANE MARIE O'SULLIVAN, WSBA #34486 Assistant United States Attorney O'Sullivan Law Office United States Attorney’s Office 2417 Pacific Ave Se Ste C Western District of Washington Olympia, WA 98501 1201 Pacific Ave., Ste. 700 Phone: (206) 340-9980 Tacoma, WA 98402 Fax: (360) 637-3574 Phone: (253) 428-3824 Email: [email protected] Fax: (253) 428-3826 Email: [email protected] Attorney for Plaintiff Attorneys for Defendants I certify that this memorandum contains 363 words, in compliance with the Local Civil Rules.

1 ORDER 2 The case is held in abeyance until January 8, 2026. The parties shall submit a status |Jupdate on or before January 8, 2026. It is so ORDERED.

5 DATED this 8th day of August, 2025.

Cbs. 4, Chua J H. CHUN 8 United States District Judge 1]