Zheyuan Ding and Zheyuan Han v. United States Citizenship & Immigration...

1 District Judge James L. Robart

7 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE ZHEYU DING and ZHEYU HAN, Case No. 2:25-cv-02214-JLR Plaintiffs, STIPULATED MOTION TO HOLD CASE 11 v. IN ABEYANCE AND [PROPOSED] ORDER UNITED STATES CITIZENSHIP & IMMIGRATION SERVICES (USCIS); et al., Noted for Consideration: 13 January 20, 2026 Defendants.

15 For good cause, Plaintiffs 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 May 1, 2026. Plaintiffs 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 adjudicate their Forms I-129, I-539, and I- 765. The parties are currently working towards a resolution to this litigation.

21 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. 1 P. 1.

2 With additional time, this case may be resolved without the need of further judicial intervention. USCIS recently issued a Notice of Intent to Deny (“NOID”) the Form I-129. USCIS must receive Plaintiff’s response to the NOID by February 18, 2026. Once Plaintiff has submitted the response, USCIS will need time to review it and continue with processing of the Form I-129.

6 Because further litigation may not be necessary after the review is completed, the parties agree that holding this case in abeyance through May 1, 2026, is appropriate. Therefore, the parties believe good cause exists for a stay in these proceedings to save the parties and this Court from spending unnecessary time and judicial resources on this matter.

10 Accordingly, the parties request that the Court hold the case in abeyance until May 1, 2026.

11 The parties will submit a joint status report on or before May 1, 2026 // // // // // // // 1 DATED this 20th day of January , 2026.

Respectfully submitted, CHARLES NEIL FLOYD 4 United States Attorney 5 s/ Michelle R. Lambert MICHELLE R. LAMBERT, NYS #4666657 6 Assistant United States Attorney United States Attorney’s Office 7 Western District of Washington 1201 Pacific Ave., Ste. 700 8 Tacoma, WA 98402 Phone: (253) 428-3824 9 Fax: (253) 428-3826 Email: [email protected] Attorneys for Defendants I certify that this memorandum contains 301 words, 12 in compliance with the Local Civil Rules.

13 s/ Adam Boyd ADAM BOYD WSBA# 49849 14 Gibbs Houston Pauw 1000 Second Avenue, Suite 1600 15 Seattle, Washington 98104-1003 Phone: 206-682-1080 16 Email: [email protected] Attorneys for Plaintiffs 1 [PROPOSED] ORDER 2 The case is held in abeyance until May 1, 2026. The parties shall submit a status update on or before May 1, 2026. It is so ORDERED.

DATED this ___2_1_s_t______ day of ______J_a_n_u_a_r_y_ _______, 2026.

6 A 7 _______________________________ JAMES L. ROBART United States District Judge