1 Melissa Newel (CA #148563) NEWEL LAW 2 2625 Alcatraz Ave., Suite 132 Berkeley, CA 94705 3 (510) 316-3827 4 [email protected] Attorney for Plaintiff 5 JACQUELINE NAVARRO

6 MICHELE BECKWITH 7 Acting United States Attorney MATHEW W. PILE 8 Associate General Counsel Office of Program Litigation, Office 7 9 MICHELLE A. PAVELEK (CA #300642) Special Assistant United States Attorney 10 Office of Program Litigation, Office 7 11 Office of the General Counsel Social Security Administration 12 6401 Security Boulevard Baltimore, MD 21235 13 (510) 970-4862 [email protected] 14 Attorneys for Defendant 15 UNITED STATES DISTRICT COURT 16 EASTERN DISTRICT OF CALIFORNIA 17 18 19 JACQUELINE NAVARRO, No. 1:24-CV-01193 (BAM) 20 Plaintiff,

21 v. STIPULATION AND [PROPOSED] ORDER FOR AWARD AND PAYMENT 22 COMMISSIONER OF OF ATTORNEYS FEES PURSUANT TO SOCIAL SECURITY, THE EQUAL ACCESS TO JUSTICE ACT 23 (

(d)) Defendant. 24 25 26 27

28 1 IT IS HEREBY STIPULATED by and between the parties, through their undersigned 2 attorneys, subject to the approval of the Court, that Jacqueline Navarro (“Plaintiff”) be awarded 3 attorney fees under the Equal Access to Justice Act (“EAJA”),

(d), in the 4 amount of six thousand one hundred and ninety-five dollars and twenty-six cents ($6,195.26). 5 This represents compensation for all legal services rendered on behalf of Plaintiff by counsel in 6 connection with this civil action to date, in accordance with

(d). 7 After the Court issues an Order for EAJA fees to Plaintiff, the government will consider 8 the matter of Plaintiff’s assignment of EAJA fees to Plaintiff’s attorney. Pursuant to Astrue v. 9 Ratliff,

(2010), the ability to honor the assignment will depend on whether the 10 attorney fees are subject to any offset allowed under the United States Department of the 11 Treasury’s Offset Program. After the Order for EAJA fees is entered, the government will 12 determine whether they are subject to any offset. 13 Fees shall be made payable to Plaintiff, but if the Department of the Treasury determines 14 that Plaintiff does not owe a federal debt subject to offset, then the government shall cause the 15 payment of fees approved to be made payable to Melissa Newel or Newel Law (collectively 16 “Plaintiff’s counsel”), pursuant to the assignment executed by Plaintiff. Any and all payments 17 made shall be delivered to Plaintiff’s counsel by electronic transfer or by check. 18 This stipulation constitutes a compromise settlement of Plaintiff’s request for EAJA 19 attorney fees and does not constitute an admission of liability on the part of Defendant under 20 EAJA or otherwise. Payment of the agreed amount shall constitute a complete release from, and 21 bar to, any and all claims that Plaintiff and/or Plaintiff’s counsel may have relating to EAJA 22 attorney fees and expenses in connection with this action. 23 /// 24 /// 25 /// 26 /// 27 /// 28 //// 1 This award is without prejudice to the rights of Plaintiff’s counsel to seek Social Security 2 Act attorney fees under

(b), subject to the provisions of the EAJA.

3 Respectfully submitted, 4 Dated: April 10, 2025 NEWEL LAW 5

6 By: Melissa Newel 7 Melissa Newel Attorney for Plaintiff 8 JACQUELINE NAVARRO

9

10 Dated: April 10, 2025 MICHELE BECKWITH Acting United States Attorney 11 MATHEW W. PILE Associate General Counsel 12 Office of Program Litigation, Office 7

13 By: Michelle Pavelek 14 MICHELLE A. PAVELEK (*Authorized by email dated 04/10/2025) 15 Special Assistant U.S. Attorney Office of Program Litigation, Office 7 16 Social Security Administration 17 Attorneys for Defendant

18

19 ORDER

20 Based on the parties’ stipulation, IT IS HEREBY ORDERED that, pursuant to the Equal 21 Access to Justice Act,

(d), attorney fees in the amount of six thousand one 22 hundred ninety-five dollars and twenty-six cents ($6,195.26) be awarded subject to the terms 23 of the Stipulation. 24

25 IT IS SO ORDERED.

26 Dated: April 11, 2025 /s/ Barbara A. McAuliffe _ 27 UNITED STATES MAGISTRATE JUDGE

28