Sanchez Acosta v. Jaddou et al

Filing 7

ORDER granting Parties' 6 Stipulated Motion to Hold Case in Abeyance. This case is held in abeyance until 1/27/2025. The parties shall submit a joint status report on or before 1/27/2025. Signed by Judge Jamal N Whitehead. (KRA)

District Judge Jamal N. Whitehead

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UNITED STATES DISTRICT COURT FOR THE
WESTERN DISTRICT OF WASHINGTON
AT TACOMA

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HERIBERTO SANCHEZ ACOSTA,
Plaintiff,
v.
UR MENDOZA JADDOU, et al.,
Defendants.

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Case No. 3:24-cv-05584-JNW
STIPULATED MOTION TO HOLD
CASE IN ABEYANCE AND
[PROPOSED] ORDER
Noted for Consideration:
September 24, 2024

Plaintiff and Defendants, by and through their counsel of record, pursuant to Federal Rule

16 of Civil Procedure 6 and Local Rules 7(d)(1), 10(g) and 16, hereby jointly stipulate and move to
17 stay these proceedings until January 27, 2025. Plaintiff brings this litigation pursuant to the
18 Administrative Procedure Act and Mandamus Act seeking, inter alia, to compel the U.S.
19 Citizenship and Immigration Services (“USCIS”) to compel action on his Form I-918,
20 Application for U Nonimmigrant Status, and Form I-765, Application for Employment
21 Authorization. For good cause, the parties request that the Court hold this case in abeyance until
22 January 27, 2025.
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Courts have “broad discretion” to stay proceedings. Clinton v. Jones, 520 U.S. 681, 706

24 (1997). “[T]he power to stay proceedings is incidental to the power inherent in every court to
STIPULATED MOTION
[Case No. 3:24-cv-05584-JNW] - 1

UNITED STATES ATTORNEY
1201 PACIFIC AVE., STE. 700
TACOMA, WA 98402
[phone]

1 control the disposition of the causes on its docket with economy of time and effort for itself, for
2 counsel, and for litigants.” Landis v. N. Am. Co., 299 U.S. 248, 254 (1936); see also Fed. R. Civ.
3 P. 1.
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With additional time, this case may be resolved without the need of further judicial

5 intervention. USCIS has issued a Request for Evidence (“RFE”) to Plaintiff concerning the
6 applications. Plaintiff has until December 19, 2024, to respond to the RFE. USCIS must receive
7 and review this response before continuing with the processing of his applications. Accordingly,
8 the parties respectfully request that the instant action be stayed until January 27, 2025. The parties
9 will submit a joint status report on or before January 27, 2025.
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DATED this 24th day of September, 2024.

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Respectfully submitted,

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TESSA M. GORMAN

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TESSA M. GORMAN
United States Attorney

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s/ Michelle R. Lambert
MICHELLE R. LAMBERT, NYS #4666657
Assistant United States Attorney
United States Attorney’s Office
Western District of Washington
1201 Pacific Avenue, Suite 700
Tacoma, Washington 98402
Phone: [phone]
Fax: [phone]

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(253) 428-38
Email: [e-mail]

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Attorneys for Defendants

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I certify that this memorandum contains 252
words, in compliance with the Local Civil
Rules.

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RICH IMMIGRATION PC
s/ Katherine H. Rich
KATHERINE H. RICH, WSBA #46881
1207 N. 200th Street, Suite 214b
Shoreline, Washington 98133
Phone: [phone]
Email: [e-mail]
Attorney for Plaintiff

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STIPULATED MOTION
[Case No. 3:24-cv-05584-JNW] - 2

UNITED STATES ATTORNEY
1201 PACIFIC AVE., STE. 700
TACOMA, WA 98402
[phone]

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[PROPOSED] ORDER
The stipulated motion, Dkt. No. 6, is GRANTED. This case is held in abeyance until
January 27, 2025. The parties shall submit a joint status report on or before January 27, 2025.
It is so ORDERED.
DATED this 25th day of September, 2024.

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A

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JAMAL N. WHITEHEAD
United States District Judge

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STIPULATED MOTION
[Case No. 3:24-cv-05584-JNW] - 3

UNITED STATES ATTORNEY
1201 PACIFIC AVE., STE. 700
TACOMA, WA 98402
[phone]