STIPULATION TO DISMISS MOTION AS MOOT

17-CV-0303-RS 1

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BRIAN J. STRETCH (CABN 163973)

United States Attorney

SARA WINSLOW (DCBN 457643)

Chief, Civil Division

RAVEN M. NORRIS (CABN. 232868)

Assistant United States Attorney

450 Golden Gate Avenue, Box 36055

San Francisco, California 94102-3495

Telephone: (415) 436-6915

Fax: (415) 436-6748

Raven.norris@usdoj.gov

Attorneys for Defendants

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

Judith Anne Moloney,

Plaintiff,

v.

LEON RODRIGUEZ, Director, United States 

Citizenship and Immigration Services; U.S. 

Department of Homeland Security; MARK 

HAZUDA, Nebraska Service Center Director, 

U.S. Citizenship and Immigration Services; and 

Jeh Johnson, Secretary, Department of 

Homeland Security.

Defendants.

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17-cv-0303-RS

STIPULATION TO DISMISS MOTION FOR 

TEMPORARY RESTRAINING ORDER AND 

MOTION FOR PRELIMINARY INJUNCTION 

AS MOOT AND [PROPOSED] ORDER

Plaintiff Judith Anne Moloney, and Defendants, by and through their attorneys of record, hereby 

stipulate, subject to the approval of the Court, to dismissal of Plaintiff’s Motion for Temporary 

Restraining Order, and Motion for Preliminary Injunction as moot in light of the fact that the United 

States Citizenship and Immigration Services adjudicated Plaintiff’s Applications for Employment 

Authorization and Advance Parole.

The Parties are not dismissing Plaintiff’s Petition for Writ of Mandamus at this time but are 

working toward a resolution that may result in dismissal of the Petition at a later date.

Case 3:17-cv-00303-RS Document 13 Filed 01/24/17 Page 1 of 3 Case 3:17-cv-00303-RS Document 14 Filed 01/24/17 Page 1 of 3
STIPULATION TO DISMISS MOTION AS MOOT

17-CV-0303-RS 2

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Each of the parties shall bear their own costs and fees.

SO STIPULATED.

Date: January 24, 2017 Respectfully Submitted,

/s/ Zachary Nightingale

ZACHARY NIGHTINGALE

Attorney for Plaintiff

Judith Anne Moloney

Dated: January 24, 2017 BRIAN J. STRETCH

United States Attorney

/s/Raven M. Norris

RAVEN M. NORRIS 1

Assistant United States Attorney 

Attorneys for United States

1 I, Raven M. Norris, hereby attest, in accordance with the Civil L.R. 5(i)(3), the concurrence in 

the filing of this document has been obtained from the other signatory listed here.

Case 3:17-cv-00303-RS Document 13 Filed 01/24/17 Page 2 of 3 Case 3:17-cv-00303-RS Document 14 Filed 01/24/17 Page 2 of 3
STIPULATION TO DISMISS MOTION AS MOOT

17-CV-0303-RS 3

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[PROPOSED] ORDER

The Court, having considered the Stipulation To Dismiss Plaintiff’s Motion for Temporary 

Restraining Order and Motion for Preliminary Injunction As Moot, and good cause appearing, hereby 

ORDERS the Motion DISMISSED AS MOOT, and the parties shall each bear their own costs and 

attorney’s fees.

IT IS SO ORDERED.

Dated:

RICHARD SEEBORG

United States District Judge

Case 3:17-cv-00303-RS Document 13 Filed 01/24/17 Page 3 of 3

1/24/17

Case 3:17-cv-00303-RS Document 14 Filed 01/24/17 Page 3 of 3