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IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
UNITED METHODIST CHURCH
OF THE GOOD SHEPHERD,...
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
UNITED METHODIST CHURCH
OF THE GOOD SHEPHERD,...
2
If the final result of the reopened proceedings is a denial of any portion of the case, then
the Parties agree that the ...
CERTIFICATE OF SERVICE
I certify that the enclosed Joint Motion to Hold Matter In Abeyance with was served on
the person w...
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United Methodist Church of the Good Shepard, et al., v. Jeh Johnson (USCIS) et al. (11 09-2015) motion for stay pending reopened I-129 and I-360

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United Methodist Church of the Good Shepard, et al., v. Jeh Johnson (USCIS) et al. (11 09-2015) motion for stay pending reopened I-129 and I-360

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United Methodist Church of the Good Shepard, et al., v. Jeh Johnson (USCIS) et al. (11 09-2015) motion for stay pending reopened I-129 and I-360

  1. 1. IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA UNITED METHODIST CHURCH OF THE GOOD SHEPHERD, et al., Plaintiffs, v. JEH JOHNSON, et al., Defendants. : : : : : : : : : : : CIVIL ACTION NO. 15-5037 ORDER AND NOW, this ______________ day of ____________________________, 2015, on consideration of the parties’ Joint Motion to Hold this Matter in Abeyance, it is ORDERED that the motion is GRANTED. It is further ORDERED that on or before February 5, 2016, the parties shall file a Joint Notice with the Court regarding the status of the reopened proceedings and submit a proposed schedule, for the Court’s approval, regarding any further proceedings as may be necessary to resolve this matter. BY THE COURT: R. BARCLAY SURRICK United States District Judge Case 2:15-cv-05037-RBS Document 5 Filed 11/06/15 Page 1 of 4
  2. 2. IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA UNITED METHODIST CHURCH OF THE GOOD SHEPHERD, et al., Plaintiffs, v. JEH JOHNSON, et al., Defendants. : : : : : : : : : : : CIVIL ACTION NO. 15-5037 JOINT MOTION TO HOLD MATTER IN ABEYANCE The parties jointly move the Court to hold this matter in abeyance, and agree that any further requirements for service, pleadings, responsive pleadings, or answers should be suspended until completion of the process described below: The Defendants will reopen and reconsider the government’s prior decisions in both portions of this matter (i.e., the denials of Plaintiffs’ I-360 application, WAC 07 223 53488, filed on July 20, 2007, and I-129 petition, WAC 08 021 50266, filed on October 29, 2007). The Defendants believe that this reopened process will result either in approval of the Plaintiffs’ cases, or a more complete record of proceedings for the Court to review. The Defendants will take action on the reopened proceedings by January 29, 2016. If the Defendants’ action is to grant the immigration status sought by the Plaintiffs (i.e., lawful permanent residence), the Plaintiffs will voluntarily dismiss the case. If the Defendants’ action is to request additional evidence, the parties will endeavor to complete the case as expeditiously as possible. Case 2:15-cv-05037-RBS Document 5 Filed 11/06/15 Page 2 of 4
  3. 3. 2 If the final result of the reopened proceedings is a denial of any portion of the case, then the Parties agree that the Plaintiffs should be granted leave to amend to include the new actions and denials, if any, and any additional claims that may arise therefrom. The parties agree that the deadline for Plaintiffs to file an amended complaint should be March 15, 2016, or 45 days after the final denial, if any, whichever is later. The parties agree that on or before February 5, 2016, they will file a Joint Notice with the Court regarding the status of the reopened proceedings and submit a proposed schedule, for the Court’s approval, regarding any further proceedings as may be necessary to resolve this matter. A proposed form of Order is attached. Respectfully submitted, /s/ Joseph C. Hohenstein JOSEPH C. HOHENSTEIN Law Office of Joseph C. Hohenstein 190 N. Independence Mall West, Suite 602 Philadelphia, PA 19106 Tel: (267)405-6301 Fax: (215) 925-5105 joe.hohen11@gmail.com Attorney for Plaintiffs /s/Joseph A. Darrow JOSEPH A. DARROW Trial Attorney Office of Immigration Litigation – District Court Section U.S. Department of Justice, Civil Division P.O. Box 868, Ben Franklin Station Washington, D.C. 20044 Telephone: (202) 598-2445 Fax: (202) 305-7000 joseph.a.darrow@usdoj.gov Attorney for Defendants Dated: November 6, 2015 Case 2:15-cv-05037-RBS Document 5 Filed 11/06/15 Page 3 of 4
  4. 4. CERTIFICATE OF SERVICE I certify that the enclosed Joint Motion to Hold Matter In Abeyance with was served on the person whose name and address appears below via ECF electronic filing: JOSEPH C. HOHENSTEIN Law Office of Joseph C. Hohenstein 190 N. Independence Mall West, Suite 602 Philadelphia, PA 19106 Tel: (267) 405-6301 Fax: (215) 925-5105 joe.hohen11@gmail.com Dated: November 6, 2015 /s/Joseph A. Darrow JOSEPH A. DARROW Trial Attorney Office of Immigration Litigation District Court Section U.S. Department of Justice Civil Division P.O. Box 868, Ben Franklin Station Washington, D.C. 20044 Telephone: (202) 598-2445 Fax: (202) 305-7000 joseph.a.darrow@usdoj.gov Case 2:15-cv-05037-RBS Document 5 Filed 11/06/15 Page 4 of 4

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