Rahul Sathe, et al. v. Joseph B. Edlow, Director, United States Citizenship and...

1 District Judge James L. Robart

7 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE RAHUL SATHE, et al., Case No. 2:25-cv-02271-JLR Plaintiffs, STIPULATED MOTION AND 11 v. [PROPOSED] ORDER FOR EXTENSION OF TIME JOSEPH B. EDLOW, Director, United States Citizenship and Immigration Services, Noted for Consideration: 13 January 14, 2026 Defendant.

15 JOINT STIPULATION 16 Plaintiffs filed their mandamus complaint on November 13, 2025 and served the Defendants on November 24, 2025. (Dkts. 1, 6). Defendants’ Answer is due on January 23, 2026.

18 Defendants recently issued a request for additional evidence for one family and will need to review any materials submitted by Plaintiffs before making an adjudication decision.

20 The Parties, through undersigned counsel, jointly file this stipulation asking the Court to extend the deadline for the filing of Defendants’ Answer. A brief extension will allow Defendants to review any additional materials submitted by Plaintiffs and continue their work on adjudicating the applications.

1 Proposed New Deadline Current Deadline Deadline Defendants’ Answer to the Complaint 1/23/2026 3/23/2026 A court may modify a schedule for good cause. Fed. R. Civ. P. 16(b)(4). Continuing pretrial and trial dates is within the discretion of the trial judge. King v. State of California, 784 F.2d 910, (9th Cir. 1986). For the reasons set forth above, the parties believe that there is good cause to modify the current deadline and respectfully request that the Court grant their motion.

SO STIPULATED.

DATED this 14th day of January, 2026.

Respectfully submitted, CHARLES NEIL FLOYD THE GALATI LAW FIRM United States Attorney s/ Matt Waldrop s/ Matthew T. Galati MATT WALDROP, GA No. 349571 MATTHEW T. GALATI*, PA #312013 Assistant United States Attorney 8080 Old York Road, Ste. 204 United States Attorney’s Office Elkins Park, PA 19027 Western District of Washington Phone: (215) 310-0231 Stewart Street, Suite 5220 Email: [email protected] Seattle, Washington 98101-1271 *Pro Hac Vice Phone: 206-553-7970 Fax: 206-553-4067 Email: [email protected] GEORGE IMMIGRATION PLLC Attorneys for Defendant s/ Anahita George 18 ANAHITA GEORGE, WSBA No. 57799 I certify that this memorandum contains 182 George Immigration PLLC words, in compliance with the Local Civil Rules. 5719 Stetson Court Northwest Olympia, WA 98502 20 Phone: 425-328-9339 Email: [email protected] Attorneys for Plaintiffs 1 [PROPOSED] ORDER 2 It is hereby ORDERED that the parties’ motion is GRANTED.

4 DATED this 14th day of January, 2026.

6 A JAMES L. ROBART United States District Judge