Case 2:18-cv-00928-MJP Document 77 Filed 10/01/18 Page 1 of 4

The Honorable Marsha J. Pechman

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

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YOLANY PADILLA, on behalf of herself and her 6-year-old
son J.A.; IBIS GUZMAN, on behalf of herself and her
5-year-old son R.G.; BLANCA ORANTES, on behalf of
herself and her 8-year-old son A.M.;
BALTAZAR
VASQUEZ, on behalf of himself;
Plaintiffs-Petitioners,
v.

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U.S. IMMIGRATION AND CUSTOMS ENFORCEMENT
(“ICE”); U.S. DEPARTMENT OF HOMELAND
SECURITY (“DHS”); U.S. CUSTOMS AND BORDER
PROTECTION (“CBP”); U.S. CITIZENSHIP AND
IMMIGRATION SERVICES (“USCIS”); EXECUTIVE
OFFICE FOR IMMIGRATION REVIEW (“EOIR”);
THOMAS HOMAN, Acting Director of ICE; KIRSTJEN
NIELSEN, Secretary of DHS; KEVIN K. McALEENAN,
Acting Commissioner of CBP; L. FRANCIS CISSNA,
Director of USCIS; MARC J. MOORE, Seattle Field Office
Director,
ICE,
JEFFERSON
BEAUREGARD
SESSIONS III, United States Attorney General; LOWELL
CLARK, warden of the Northwest Detention Center in
Tacoma, Washington; CHARLES INGRAM, warden of the
Federal Detention Center in SeaTac, Washington; DAVID
SHINN, warden of the Federal Correctional Institute in
Victorville, California; JAMES JANECKA, warden of the
Adelanto Detention Facility;

No. 2:18-cv-928 MJP

JOINT STIPULATION
AND [PROPOSED]
ORDER REGARDING
MOTION FOR
PRELIMINARY
INJUNCTION BRIEFING
SCHEDULE

NOTE ON MOTION
CALENDAR: OCTOBER
1, 2018.

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Defendants-Respondents.

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Pursuant to Local Civil Rules 7(d)(1) and 10(g), Plaintiffs and Defendants hereby stipulate
and jointly move the Court for an Order revising the schedule for the filing of Defendants’ response
in opposition to Plaintiffs’ motion for preliminary injunction, and Plaintiffs’ reply in support of
their motion.
Currently Defendants’ response to Plaintiffs’ motion for preliminary injunction is due
October 8, 2018, which is the Columbus Day holiday, and Plaintiffs’ reply is October 12, 2018.
JOINT STIPULATION AND [PROPOSED]
ORDER REGARDING MOTION FOR
PRELIMINARY INJUNCTION BRIEFING
SCHEDULE - 1
CASE NO. 2:18-cv-928 MJP

U.S. Department of Justice, Civil Division
Office of Immigration Litigation, District Court Section
PO Box 868, Ben Franklin Station
Washington, DC 20044
Telephone (202) 616-4458

 Case 2:18-cv-00928-MJP Document 77 Filed 10/01/18 Page 2 of 4

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After consultation between the parties’ counsel, the parties stipulate to an extension until October

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17, 2018, for Defendants to file their response to Plaintiffs’ motion, and an extension until October

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26, 2018, for Plaintiffs’ to file their reply in support of their motion. Plaintiffs will re-note their

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motion for October 26, 2018.

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The reason for this stipulation is to allow both sides sufficient time to brief these important

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issues thoroughly for the Court. This requested extension will not impact any other deadlines in

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the case.

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RESPECTFULLY SUBMITTED this 1st day of October, 2018.

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s/ Matt Adams
Matt Adams, WSBA No. 28287
Email: matt@nwirp.org
Glenda M. Aldana Madrid, WSBA No. 46987
Email: glenda@nwirp.org
Leila Kang, WSBA No. 48048
Email: leila@nwirp.org

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NORTHWEST IMMIGRANT
RIGHTS PROJECT
615 Second Avenue, Suite 400
Seattle, WA 98104
Telephone: (206) 957-8611
Facsimile: (206) 587-4025
Attorneys for Plaintiffs-Petitioners

Kristin Macleod-Ball*
Trina Realmuto*
AMERICAN IMMIGRATION COUNCIL
100 Summer Street, 23rd Floor
Boston, MA 02110
(857) 305-3600
trealmuto@immcouncil.org
kmacleod-ball@immcouncil.org
*Admitted pro hac vice
Attorneys for Plaintiffs-Petitioners

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JOSEPH. H. HUNT
Assistant Attorney General
Civil Division
WILLIAM C. PEACHEY
Director, District Court Section
Office of Immigration Litigation
EREZ REUVENI
Assistant Director, District Court Section
Office of Immigration Litigation
JOINT STIPULATION AND [PROPOSED]
ORDER REGARDING MOTION FOR
PRELIMINARY INJUNCTION BRIEFING
SCHEDULE - 2
CASE NO. 2:18-cv-928 MJP

/s/ Lauren C. Bingham
LAUREN C. BINGHAM, Fl. Bar #105745
Trial Attorney, District Court Section
Office of Immigration Litigation
Civil Division
P.O. Box 868, Ben Franklin Station
Washington, DC 20044
(202) 616-4458; (202) 305-7000 (fax)
lauren.c.bingham@usdoj.gov
Attorneys for Defendants-Respondents
U.S. Department of Justice, Civil Division
Office of Immigration Litigation, District Court Section
PO Box 868, Ben Franklin Station
Washington, DC 20044
Telephone (202) 616-4458

 Case 2:18-cv-00928-MJP Document 77 Filed 10/01/18 Page 3 of 4

[PROPOSED] ORDER

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Based on the foregoing stipulation of the parties, IT IS SO ORDERED. Defendants’

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response to Plaintiffs’ motion for preliminary injunction will be due October 17, 2018. Plaintiffs’

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reply to their motion for preliminary injunction will be due October 26, 2018, and their motion

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will be noted for that date.

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DATED this

day of _________________, 2018.

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_____________________________________
THE HONORABLE MARSHA J. PECHMAN
UNITED STATES DISTRICT JUDGE

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JOINT STIPULATION AND [PROPOSED]
ORDER REGARDING MOTION FOR
PRELIMINARY INJUNCTION BRIEFING
SCHEDULE - 3
CASE NO. 2:18-cv-928 MJP

U.S. Department of Justice, Civil Division
Office of Immigration Litigation, District Court Section
PO Box 868, Ben Franklin Station
Washington, DC 20044
Telephone (202) 616-4458

 Case 2:18-cv-00928-MJP Document 77 Filed 10/01/18 Page 4 of 4

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CERTIFICATE OF SERVICE
I hereby certify that on October 1, 2018, I had the foregoing electronically filed with the
Clerk of the Court using the CM/ECF system, which will send notification of such filing to those
attorneys of record registered on the CM/ECF system. All other parties (if any) shall be served in

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accordance with the Federal Rules of Civil Procedure.

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/s/ Lauren C. Bingham
LAUREN C. BINGHAM, Fl. Bar #105745
Trial Attorney, District Court Section
Office of Immigration Litigation
Civil Division
P.O. Box 868, Ben Franklin Station
Washington, DC 20044
(202) 616-4458; (202) 305-7000 (fax)
lauren.c.bingham@usdoj.gov

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Attorney for Defendants

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JOINT STIPULATION AND [PROPOSED]
ORDER REGARDING MOTION FOR
PRELIMINARY INJUNCTION BRIEFING
SCHEDULE - 4
CASE NO. 2:18-cv-928 MJP

U.S. Department of Justice, Civil Division
Office of Immigration Litigation, District Court Section
PO Box 868, Ben Franklin Station
Washington, DC 20044
Telephone (202) 616-4458