M.S.G.L., by and through her parents Gregorio Guzman Reyes and Maricruz Lopez...

1 The Honorable Kymberly K. Evanson

7 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE M.S.G.L., by and through her parents Case No. 2:22-cv-01554-KKE GREGORIO GUZMAN REYES and MARICRUZ LOPEZ SANTOS, and STIPULATED MOTION AND ORDER individually, FOR EXTENSION OF PRETRIAL DEADLINES 12 Plaintiffs, v. Noted for Consideration: 13 October 21, 2025 UNITED STATES OF AMERICA, Defendant.

16 JOINT STIPULATION 17 The government respectfully requests an extension until November 18, 2025, of the dispositive motion deadline in this case due to the lapse of appropriations to the Department of Justice (the Department). Good cause exists for extending this deadline, and the interests of justice and judicial economy will be served by granting this motion. Plaintiffs’ counsel has authorized us to indicate that this motion is not opposed for the purposes of this specific deadline.

22 At the end of the day on September 30, 2025, funding to the Department expired and its appropriations lapsed. The same is true for most Executive agency clients with whom Department attorneys must coordinate their litigation activities. The Department does not know when funding will be restored by Congress.

3 Absent an appropriation, certain Department attorneys and employees of the federal government are prohibited from working, even on a voluntary basis, except in very limited circumstances, including “emergencies involving the safety of human life or the protection of property.” 31 U.S.C. § 1342. The term “‘emergencies involving the safety of human life or the protection of property’ does not include ongoing, regular functions of government the suspension of which would not imminently threaten the safety of human life or the protection of property.”

9 Id. Therefore, the lapse in appropriations requires a reduction in the workforce of the United States Attorney’s Office, particularly with respect to prosecution and defense of civil cases.

11 District courts have inherent power to stay proceedings in cases. Oregon Mut. Ins. Co. v. Ham & Rye, LLC, No. C10-579RJB, 2010 WL 2787852, at *3 (W.D. Wash. July 14, 2010). The “power to stay 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.’” Id. (citing Landis v. North American Co., 299 U.S. 248, 254 (1936)). When determining whether to stay proceedings, a court should weigh the “competing interests which will be effected by the granting or refusal to grant a stay,” including “the possible damage which may result from the granting of a stay, the hardship or inequity which a party may suffer in being required to go forward, and the orderly course of justice measured in terms of the simplifying or complicating of issues, proof, and questions of law which could be expected to result from a stay.” Lockyer v. Mirant Corp., 398 F.3d 1098, 1109 (9th Cir. 2005) (citing Landis, 299 U.S. at 254).

22 The above factors weigh in favor of extending the dispositive motion deadline in this case until November 18, 2025. In this case, the parties previously agreed to a scheduling order that was approved by the Court. See Dkt. 45. Prior to the lapse in appropriations, the parties agreed on October 27, 2025, as the deadline for dispositive motions. However, at this time, the lapse in appropriations limits further work on this matter. The government is unable to consult experts, review deposition transcripts, or draft motions.

4 The government therefore respectfully requests the dispositive motion deadline be extended until November 18, 2025.1 6 CONCLUSION 7 Based on the foregoing, the government respectfully requests that the dispositive motion deadline be reset until November 18, 2025.

9 DATED this 21st day of October, 2025.

10 Respectfully submitted, CHARLES NEIL FLOYD GEORGIA TREJO LOCHER, P.S.

United States Attorney s/ Kristen R. Vogel s/ Georgia Trejo Locher KRISTEN R. VOGEL, NY No. 5195664 GEORGIA TREJO LOCHER, WSBA No. 21450 MATT WALDROP, GA No. 349571 237 SW 153rd St. Assistant United States Attorneys Burien, WA 98166 United States Attorney’s Office Phone: 206-246-6100 Western District of Washington Fax: 206-246-6105 Stewart Street, Suite 5220 Email: [email protected] Seattle, Washington 98101-1271 Phone: 206-553-7970 Attorney for Plaintiffs Fax: 206-553-4073 Email: [email protected] Email: [email protected] Attorneys for United States of America I certify that this memorandum contains words, in compliance with the Local Civil Rules.

1 The government reserves the right to file a separate motion seeking a stay in the proceedings should the lapse in appropriations continue.

1 ORDER 2 It is hereby ORDERED that the Motion is GRANTED. The dispositive motion deadline is reset to November 18, 2025.

5 DATED this 28th day of October, 2025.

A Kymberly K. Evanson 9 United States District Judge