JIANNAN CUI v. UNITED STATES DEPARTMENT OF STATE; MARCO RUBIO, Secretary of State; DAVID PERDUE, United States Ambassador to the People’s Republic of China; SCOTT WALKER, Consul General at the United States Consulate General in Shanghai, China

Opinion

7 UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE

9 JIANNAN CUI, Case No. 2:26-cv-00205-RSM 10 Plaintiff, STIPULATED MOTION TO STAY 11 AND ORDER v. 12 UNITED STATES DEPARTMENT OF 13 STATE; MARCO RUBIO, Secretary of State; DAVID PERDUE, United States Ambassador 14 to the People’s Republic of China; SCOTT WALKER, Consul General at the United 15 States Consulate General in Shanghai, China,

16 Defendants. 17 18 For good cause, Plaintiff and Defendants, by and through their counsel of record, pursuant 19 to Federal Rule of Civil Procedure 6 and Local Rules 7(d)(1), 10(g) and 16, hereby jointly 20 stipulate and move to stay these proceedings for 45 days. Plaintiff brought this litigation pursuant 21 to the Administrative Procedure Act and Mandamus Act seeking, inter alia, to compel Defendants 22 to adjudicate her visa application. 23 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 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.

4 With additional time, these claims may be resolved without the need for further judicial 5 intervention. Once the application at issue is adjudicated, Plaintiff will voluntarily dismiss this 6 case. Accordingly, the parties respectfully request that the instant action be stayed for 45 days. 7 The parties will submit a joint status report on or before the end of this period. 8 Dated this 6th day of April, 2026. 9 Respectfully submitted,

10 BECKNER IMMIGRATION LAW, PLLC

11 s/ Katie D. Fairchild s/Kelsey Beckner KATIE D. FAIRCHILD, WSBA #47712 KELSEY BECKNER (WA Bar No. 58670) 12 Assistant United States Attorney 4444 Woodland Park Avenue N., Suite B101 United States Attorney’s Office Seattle, WA 98103 13 700 Stewart Street, Suite 5220 Telephone: (360) 602-1570 Seattle, Washington 98101-1271 Fax: (206) 504-3704 14 Phone: 206-553-7970 Email: kbeckner@becknerimmigration.com Fax: 206-553-4073 15 Email: katie.fairchild@usdoj.gov REEVES IMMIGRATION LAW GROUP

16 Attorney for Defendants s/Meixuan Zhang MEIXUAN ZHANG, Pro Hac Vice 17 I certify that this memorandum contains 191 2 North Lake Avenue, Suite 950 words, in compliance with the Local Civil Pasadena, CA 91101 18 Rules. Telephone: (626) 795-6777 Fax: (626) 795-6999 19 Email: mzhang@reevesimmigration.com

20 Attorneys for Plaintiff

21 22 23 24 1 ORDER 2 The case is held in abeyance. The parties shall submit a status update within 45 days of 3 this Order. It is so ORDERED.

4 5 DATED this 7th day of April, 2026. 6 A

7 RICARDO S. MARTINEZ 8 UNITED STATES DISTRICT JUDGE

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