MICHELE BECKWITH 1 Acting United States Attorney MATHEW W. PILE 2 Associate General Counsel 3 Office of Program Litigation, Office 7 Office of the General Counsel 4 Social Security Administration 5 MARGARET BRANICK-ABILLA Special Assistant United States Attorney 6 6401 Security Boulevard Baltimore, MD 21235 7 Telephone: (510) 570-4809 8 Email: [email protected] Attorneys for Defendant 9 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA 10

11 MARIANA TORRES GARCIA, ) Case No. 2:24-cv-01438-SCR ) 12 Plaintiff, ) STIPULATION FOR THE AWARD AND 13 ) PAYMENT OF ATTORNEY FEES vs. ) PURSUANT TO THE EQUAL ACCESS 14 ) TO JUSTICE ACT ,

(d); COMMISSIONER OF SOCIAL SECURITY, ) [PROPOSED] ORDER 15 ) 16 Defendant. ) ) 17 IT IS HEREBY STIPULATED by and between the parties, through their undersigned 18 counsel, subject to the approval of the Court, that Plaintiff be awarded attorney fees in the amount 19 of SEVEN THOUSAND DOLLARS AND ZERO CENTS ($7,000.00) under the Equal Access to 20 Justice Act (EAJA),

(d). This amount represents compensation for all legal 21 services rendered on behalf of Plaintiff by counsel in connection with this civil action, in 22 accordance with

(d). 23 After the Court issues an order for EAJA fees to Plaintiff, the government will consider the 24 matter of Plaintiff’s assignment of EAJA fees to counsel Francesco Benavides (Counsel). 25 Pursuant to Astrue v. Ratliff,

(2010), the ability to honor the assignment will 26 depend on whether the fees are subject to any offset allowed under the United States Department 27 of the Treasury’s Offset Program. After the order for EAJA fees is entered, the government will 28 determine whether they are subject to any offset. 1 Fees shall be made payable to Plaintiff, but if the Department of the Treasury determines 2 that Plaintiff does not owe a federal debt, then the government shall cause the payment of fees and 3 || costs to be made directly to Counsel pursuant to the assignment executed by Plaintiff. Any 4 || payments made shall be delivered to Counsel. 5 This stipulation constitutes a compromise settlement of Plaintiff's request for EAJA || attorney fees, and does not constitute an admission of liability on the part of Defendant under the , || EAJA or otherwise. Payment of the agreed amount shall constitute a complete release from, and 9 bar to, any and all claims that Plaintiff and/or Counsel, including Counsel’s law office and any associates, may have relating to EAJA attorney fees in connection with this action. This award is without prejudice to the rights of Counsel to seek Social Security Act attorney fees under

(b), subject to the savings clause provisions of the EAJA. 11 12 Respectfully submitted, 13 || Dated: February 7, 2025 LAW OFFICES OF FRANCESCO BENAVIDES By:/s/ Francesco Benavides 15 FRANCESCO BENAVIDES Attorneys for Plaintiff 16 [*As authorized by e-mail on Feb. 7, 2025] | Dated: February 11, 2025 MICHELE BECKWITH 18 Acting United States Attorney 19 By: /s/ Margaret Branick-Abilla 50 MARGARET BRANICK-ABILLA Special Assistant United States Attorney 21 Attorneys for Defendant 22 [PROPOSED] ORDER Pursuant to stipulation, IT IS SO ORDERED. 24 2° || Dated: February 11, 2025 26 . 27 SEAN C. RIORDAN 28 UNITED STATES MAGISTRATE JUDGE

Stipulation; Prepesed} Order 9IA_evy_-N1432_-SCR