Jeronimo Aguilar v. Jaddou et al

Filing 13

ORDER GRANTING 12 STIPULATION TO STAY PROCEEDINGS: The proceedings in this case shall be stayed until 4/17/2024, at which time the parties will filea joint status report with the court. At that time, the parties may request a further continuance of the stay of proceedings, dismissal of the litigation if appropriate, or placement of the case back on the Court's active docket. Signed by Chief Magistrate Judge Donna M. Ryu on 11/15/2023. (ig, COURT STAFF) (Filed on 11/15/2023)

1 ISMAIL J. RAMSEY (CABN 189820)
United States Attorney
2 MICHELLE LO (NYRN 4325163)
Chief, Civil Division
3 ELIZABETH KURLAN (CABN 255869)
Assistant United States Attorney
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450 Golden Gate Avenue, Box 36055
San Francisco, California 94102-3495
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Telephone: [phone]
Facsimile: [phone]
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[e-mail]
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Attorneys for Defendants
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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OAKLAND DIVISION
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12 RAMIRO M. JERONIMO AGUILAR,
Plaintiff,

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v.

15 UR JADDOU, in her official capacity as
Director of United States Citizenship Services
16 (USCIS), USCIS,
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4:23-cv-04380 DMR
STIPULATION TO STAY PROCEEDINGS;
ORDER

Defendants.

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The parties, through their undersigned attorneys, hereby stipulate and respectfully request the
Court to stay proceedings in this case for a limited time, until April 17, 2024. The parties make this joint
request because they are pursuing an administrative resolution that may render further litigation of this
case unnecessary.
Plaintiff filed this mandamus action seeking adjudication of their Form I-589, Application for
Asylum and for Withholding of Removal. United States Citizenship and Immigration Services
(“USCIS”) has scheduled the asylum interview to take place on December 19, 2023, and it agrees to
work diligently towards completing adjudication of Plaintiff’s petition, absent the need for further
adjudicative action or unforeseen circumstances that would require additional time for adjudication. If
Stip to Stay Proceedings
4:23-cv-04380 DMR

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1 USCIS cancels or reschedules Plaintiff’s interview, USCIS will reschedule the interview for a date not
2 more than four weeks from the originally scheduled date, absent unforeseen or exceptional
3 circumstances.
Upon receipt of USCIS’ decision, Plaintiff agrees to voluntarily dismiss this case and, in that

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5 event, the parties agree to bear their own attorney’s fees and costs. Accordingly, the parties stipulate and
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request that the proceedings in this case be stayed until April 17, 2024, at which time the parties will file
a joint status report with the Court. At that time, the parties may request a further continuance of the stay

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of proceedings, dismissal of the litigation if appropriate, or placement of the case back on the Court’s
active docket. A stay of proceedings in this case will benefit the parties and conserve the Court’s

11 resources while the parties pursue a potential administrative resolution.
12 Dated: November 14, 2023

Respectfully submitted i,

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ISMAIL J. RAMSEY
United States Attorney

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/s/ Elizabeth Kurlan
ELIZABETH D. KURLAN
Assistant United States Attorney
Attorneys for Defendants

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Date: November 15, 2023

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. Ryu

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F
D IS T IC T O
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HON. DONNA M. RYU
United States Chief Magistrate Judge

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ER

onna M

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Judge D

RT

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NO

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ERED

O ORD

IT IS S

R NIA

Pursuant to stipulation, IT IS SO ORDERED.

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UNIT
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S DISTRICT
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RT
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ORDER

FO

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/s/ Jessica Arena
JESSICA T. ARENA
Law Office of Jessica T. Arena
Attorney for Plaintiff

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A

18 Dated: November 14, 2023

In accordance with Civil Local Rule 5-1(i)(3), the filer of this document attests that all signatories
listed below concur in the filing of this document.
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Stip to Stay Proceedings
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