Dayan Cabrera Perez v. Laura Hermosillo, et al.

District Judge Ricardo S. Martinez

7 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE DAYAN CABRERA PEREZ, No. 2:25-cv-02542-RSM 10 Petitioners, STIPULATED MOTION TO EXTEND DEADLINE AND ORDER 11 v. Noted for Consideration: LAURA HERMOSILLO, et al., December 22, 2025 13 Respondents.

For good cause, Petitioners and Federal Respondents, 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 extend Federal Respondents’ return to the petition for habeas petition to December 29, 2025.

A court may modify a deadline for good cause. Fed. R. Civ. P. 6(b). Continuing pretrial and trial dates is within the discretion of the trial judge. See King v. State of California, 784 F.2d 910, 912 (9th Cir. 1986).

Recently, the Court issued a General Order announcing its closure on December 24, 2025 and December 26, 2025. Gen. Order 11-25. Pursuant to the current briefing schedule, Federal Respondents’ return is due on December 26, 2025. Dkt. No. 15. The parties agree that the return deadline be extended to December 29, 2025. Petitioners shall file any traverse and response to the return within five days of the filing of Federal Respondents’ return.

3 Dated: December 22, 2025 Respectfully submitted, 4 CHARLES NEIL FLOYD United States Attorney s/Michelle R. Lambert 6 MICHELLE R. LAMBERT, NYS #4666657 Assistant United States Attorney 7 United States Attorney’s Office 1201 Pacific Avenue, Suite 700 8 Tacoma, Washington 98402 Phone: 206-428-3824 9 Email: [email protected] Attorney for Federal Respondents I certify that this memorandum contains 161 11 words, in compliance with the Local Civil Rules.

s/Amanda Ng 13 AMANDA NG, WSBA #57181 Northwest Immigrant Rights Project 14 615 Second Avenue, Suite 400 Seattle, WA 98104 15 Phone: (206) 957-8611 Email: [email protected]

1 ORDER 2 The parties having stipulated and agreed, it is hereby so ORDERED. Federal || Respondents shall file their return to the habeas petition by December 29, 2025.

5 DATED this 31st day of December, 2025.

Awl sd RICARDO S. MA 8 United States District Judge 1] STIPULATED MOTION AND ORDER 2:25-cv-02542-RSM - 3