Doe v. Bostock

Opinion

District Judge James L. Robart Magistrate Judge S. Kate Vaughan

WESTERN DISTRICT OF WASHINGTON

JANE DOE, Ca se No. C24-0326-JLR-SKV

Petitioner-Plaintiff, STIPULATED MOTION TO EXTEND DEADLINE AND [PROPOSED] v. ORDER

DREW BOSTOCK, et al., Noted for Consideration: Respondents- July 9, 2024 Defendants. The parties, 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 extend Respondents’ deadline to file a return to the habeas petition to July 29, 2024. Dkt. 21. Respondents’ current deadline to file a return is July 15, 2024. Dkt. No. 20, Order for Return and Status Report, § 2241 Petition. A court may modify a deadline for good cause. Fed. R. Civ. P. 6(b). Continuing pretrial and trial dates is within the discretion of the trial judge. See King v. State of California, 784 F.2d 910, 912 (9th Cir. 1986). The parties submit that there is good cause for the two-week extension of the deadline. Petitioner’s next hearing date in her removal proceedings is scheduled for July 16, 2024. The results of the hearing may be determinative of how this litigation proceeds. Accordingly, an

extension will allow the parties to confer, if appropriate, after the administrative hearing date and for Respondents to complete a return based on the posture of the administrative proceedings after the hearing. Accordingly, the parties respectfully request that the Respondents’ deadline to file a return be extended to July 29, 2024. DATED this 9th day of July, 2024.

Respectfully submitted,

United States Attorney s/ Adam W. Boyd ADAM W. BOYD, WSBA# 49849 s/ Michelle R. Lambert 1000 Second Avenue, Suite 1600 MICHELLE R. LAMBERT, NYS #4666657 Seattle, Washington 98104 Assistant United States Attorney Phone: (206) 682-1080 United States Attorney’s Office Email: adam.boyd@ghp-law.net Western District of Washington 1201 Pacific Avenue, Suite 700 RIGHTS BEHIND BARS Tacoma, Washington 98402 Phone: (253) 428-3824 s/ Oren Nimni Fax: (253) 428-3826 OREN NIMNI*, MA # 691821 416 Florida Avenue, NW #26152 (253) 428-38 Washington, DC 20001 Email: michelle.lambert@usdoj.gov Phone: (202) 455-4399 Email: oren@rightsbehindbars.org Attorneys for Defendants *Pro Hac Vice

I certify that this memorandum contains 203 Attorneys for Plaintiff words, in compliance with the Local Civil Rules.

/ / /

/ / / [PROPOSED] ORDER For good cause, Respondents’ deadline to file a return is extended to July 29, 2024. It is so ORDERED.

DATED this 10th day of July, 2024. A United States Magistrate Judge