Jean Philippe Seumegni v. United States Citizenship and Immigration Services,...

1 The Honorable James L. Robart

7 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE JEAN PHILIPPE SEUMEGNI, Case No. 2:25-cv-02505-JLR Plaintiff, STIPULATED MOTION TO HOLD 11 v. CASE IN ABEYANCE AND [PROPOSED] ORDER UNITED STATES CITIZENSHIP AND IMMIGRATION SERVICES, et al., Noted for Consideration: 13 January 20, 2026 Defendants.

15 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 June 4, 2026. Plaintiff brought this litigation pursuant to the Administrative Procedure Act and Mandamus Act seeking, inter alia, to compel U.S. Citizenship and Immigration Services (“USCIS”) to schedule an interview and adjudicate his asylum application. Defendants’ response to the Complaint is currently due on February 17, 2026. The parties are currently working towards a resolution to this litigation. For good cause, the parties request that the Court hold the case in abeyance until June 4, 2026.

23 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. 3 P. 1.

4 With additional time, this case may be resolved without the need of further judicial intervention. USCIS will complete Plaintiff’s asylum interview on February 4, 2026. USCIS agrees to diligently work towards moving Plaintiff’s application forward during the stay of 120 days after the asylum interview, absent unforeseen or exceptional circumstances that would require additional time.

9 Once the application is adjudicated, Plaintiff will dismiss the case with each party to bear their own litigation costs and attorneys’ fees. Accordingly, the parties request an abeyance until 120 days from Plaintiff’s interview date, to allow USCIS to process his asylum application.

13 // // // // // // 1 DATED this 20th day of January, 2026.

2 Respectfully submitted, CHARLES NEIL FLOYD HACKING IMMIGRATION LAW, LLC United States Attorney s/ Jennifer Wong s/ James O. Hacking, III JENNIFER WONG, CA No. 341634 JAMES O. HACKING, III* Assistant United States Attorney 10121 Manchester Road, Suite A United States Attorney’s Office St. Louis, Missouri 63122 Western District of Washington Phone: 314-961-8200 700 Stewart Street, Suite 5220 Email: [email protected] Seattle, Washington 98101-1271 *PHV Phone: 206-553-7970 Fax: 206-553-4067 Email: [email protected] LAW OFFICE OF NICHOLAS POWER Attorneys for Defendants s/ Nicholas E.D. Power I certify that this memorandum contains 279 NICHOLAS E.D. POWER, WSBA No. 45972 words, in compliance with the Local Civil Rules. 3660 Beaverton Valley Road, Suite 150 12 Friday Harbor, Washington 98250 Phone: 360-298-0464 13 Email: [email protected] 14 Attorneys for Plaintiff

1 [PROPOSED] ORDER 2 The case is held in abeyance until June 4, 2026. The parties shall submit a status update on or before June 4, 2026.

4 It is so ORDERED.

6 DATED this ____2_0_t_h_____ day of ______J_a_n_u_ar_y_ ________, 2026.

A _______________________________ 9 JAMES L. ROBART United States District Judge