Nguyen v. Corsano ( 2022 )

1 District Judge Marsha J. Pechman 2 3 4 5 6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 9 10 HOA T. NGUYEN, TIEN N. NGUYEN, NAM H. Case No. 2:21-cv-01520-MJP NGUYEN, and T-H-N, 11 STIPULATION FOR EXTENSION OF Plaintiffs, TIME 12 v. Note on Motion Calendar: 13 January 18, 2022 14 ANNE ARRIES CORSANO, Seattle District Director of U.S. Citizenship and Immigration 15 Services; UR MENDOZA JADDOU, Director of U.S. Citizenship and Immigration Services; 16 ALEJANDRO MAYORKAS, Secretary, U.S. Department of Homeland Security, 17 18 Defendants. 19 20 COME NOW, Plaintiffs and Federal Defendants, by and through their counsel of record, 21 pursuant to Federal Rule of Civil Procedure 6 and Local Rules 10(g) and 16, and hereby jointly 22 stipulate and move for an extension of 30 days for Defendants to respond to the Complaint. 23 Defendants’ responsive pleading to the Complaint is due January 21, 2022. 24 A court may modify a deadline for good cause. Fed. R. Civ. P. 6(b). Continuing pretrial 25 and trial dates is within the discretion of the trial judge. See King v. State of California, 26 784 F.2d 910, 912 (9th Cir. 1986). The parties are currently attempting to resolve this matter 27 without the need for litigation. Therefore, the parties believe good cause exists for a brief stay 1 to allow the parties to continue their efforts and to save the Court and the parties from spending 2 unnecessary time and resources on this matter. 3 In light of the above, the parties jointly stipulate and request that the Court: 4 1. Extend Defendants’ time to respond to Plaintiffs’ Complaint by 30 days to February 5 18, 2022. 6 7 Stipulated to and presented this 18th day of January, 2022. 8 OPEN SKY LAW, PLLC NICHOLAS W. BROWN United States Attorney 9 10 s/ Devin T. Theriot-Orr s/ Nickolas Bohl DEVIN T. THERIOT-ORR, WSBA #33995 NICKOLAS BOHL WSBA #48978 11 20415 72nd Avenue S., Suite 110 Assistant United States Attorney Kent, WA 98032 United States Attorney’s Office 12 Phone: 206-962-5052 700 Stewart Street, Suite 5220 Email: devin@opensky.law Seattle, Washington 98101-1271 13 Phone: 206-553-7970 14 Counsel for Plaintiffs Fax: 206-553-4067 Email: nickolas.bohl@usdoj.gov 15 Counsel for Defendants 16 17 18 19 20 21 22 23 24 25 26 27 ORDER 1 The parties having stipulated and agreed, it is hereby so ORDERED. 2 3 DATED this 19th day of January, 2022. 4 5 A 6 7 JAMES L. ROBART United States District Court Judge 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27