Northwest Immigrant Rights Project et al v. United States Citizenship and Immigration Services et al

Filing 200

STIPULATION AND ORDER re Parties' 199 Stipulation. The Government will file its response to Plaintiffs' 196 Motion for Civil Contempt on 9/12/2022, and that Plaintiffs will file their reply by 9/16/2022. The Clerk is directed to renote Plaintiffs' motion for contempt and to enforce permanent injunction (Dkt. # 196 ) on 9/16/2022. Signed by Judge James L. Robart. (LH)

Case 2:15-cv-00813-JLR Document 200 Filed 08/31/22 Page 1 of 4

The Honorable James L. Robart
United States District Judge

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

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NORTHWEST IMMIGRANT RIGHTS
PROJECT, et al.,

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Plaintiffs,
v.
UNITED STATES CITIZENSHIP AND
IMMIGRATION SERVICES, et al.,

Case No. 2:15-cv-00813-JLR
STIPULATION AND PROPOSED ORDER
FOR AN EXTENSION
NOTE ON MOTION CALENDAR:
August 31, 2022

Defendants.
The Government requests an extension of the deadlines for filing the response and reply
with respect to Plaintiffs’ pending Motion for Civil Contempt and to Enforce Permanent
Injunction currently noticed for September 9, 2022 (Dkt. #196). Specifically, the Government
requests that its deadline to file a response to the Motion for Civil Contempt be extended until
September 12, 2022 and, accordingly, that the Plaintiffs’ deadline to file a reply be extended
until September 16, 2022.
The Government maintains that good cause is shown for the extension. The Government
represents that it has been working diligently to prepare its response to the Motion for Civil
Contempt but needs additional time to prepare a declaration in support of its response due to the

Stipulation and Proposed Order for an Extension
18-655-JLR - 1

U.S. DEPARTMENT OF JUSTICE
P.O. BOX 868, BEN FRANKLIN STATION
WASHINGTON, D.C. 20044
[phone]

Case 2:15-cv-00813-JLR Document 200 Filed 08/31/22 Page 2 of 4

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fact that the declarant is currently out of town. The Government asserts that the additional time

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will ensure that the response is thorough and comprehensive.

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Therefore, the parties agree that the Government will file its response to Plaintiffs’

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Motion for Civil Contempt on September 12, 2022, and that Plaintiffs will file their reply by

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September 16, 2022.

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Dated this 31st day of August 2022.

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By: s/ Emma C. Winger
Emma C. Winger (pro hac vice)
American Immigration Council
*1331 G Street, NW, Suite 200
Washington, DC 20005
[phone]
*Not admitted in D.C. Practice limited to
federal courts.
Matt Adams, WSBA No. 28287
Northwest Immigrant Rights Project
615 Second Avenue, Suite 400
Seattle, WA 98104
[phone]

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Devin Theriot-Orr, WSBA 33995
Open Sky Law, PLLC
20415 72nd Ave. S., Ste. 110
Kent, WA 98032
[phone]

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Marc Van Der Hout (pro hac vice)
Johnny Sinodis (pro hac vice)
Van Der Hout, LLP
180 Sutter Street, Suite 500
San Francisco, CA 94104
[phone]

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Robert H. Gibbs, WSBA 5932
Robert Pauw, WSBA 13613
Gibbs Houston Pauw
1000 Second Avenue, Suite 1600
Seattle, WA 98104-1003
[phone]

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Stipulation and Proposed Order for an Extension
18-655-JLR - 2

U.S. DEPARTMENT OF JUSTICE
P.O. BOX 868, BEN FRANKLIN STATION
WASHINGTON, D.C. 20044
[phone]

Case 2:15-cv-00813-JLR Document 200 Filed 08/31/22 Page 3 of 4

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Scott D. Pollock (pro hac vice)
Christina J. Murdoch (pro hac vice)
Kathryn R. Weber (pro hac vice)
Scott D. Pollock & Associates, P.C.
105 W. Madison, Suite 2200
Chicago, IL 60602
[phone]
Counsel for Plaintiffs

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BRIAN M. BOYNTON
Principal Deputy Assistant Attorney General
Civil Division

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WILLIAM C. PEACHEY
Director
Office of Immigration Litigation
District Court Section

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JEFFREY S. ROBINS
Deputy Director

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By: s/ Aaron S. Goldsmith
Aaron S. Goldsmith
Senior Litigation Counsel
United States Department of Justice
Civil Division
Office of Immigration Litigation
District Court Section
Washington, D.C. 20044
Tel.: [phone]
Email: [e-mail]

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Counsel for Defendants

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Stipulation and Proposed Order for an Extension
18-655-JLR - 3

U.S. DEPARTMENT OF JUSTICE
P.O. BOX 868, BEN FRANKLIN STATION
WASHINGTON, D.C. 20044
[phone]

Case 2:15-cv-00813-JLR Document 200 Filed 08/31/22 Page 4 of 4

ORDER

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The parties having so stipulated, IT IS ORDERED that the stipulation is granted. The

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parties will comply with the deadlines set forth above. The Clerk is directed to renote Plaintiffs’

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motion for contempt and to enforce permanent injunction (Dkt. # 196) on September 16, 2022.

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Dated this 31st day of August, 2022.

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A

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James L. Robart
United States District Judge

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Stipulation and Proposed Order for an Extension
18-655-JLR - 4

U.S. DEPARTMENT OF JUSTICE
P.O. BOX 868, BEN FRANKLIN STATION
WASHINGTON, D.C. 20044
[phone]