1 Laura E. Krank Attorney at Law: 220208 2 Law Offices of Lawrence D. Rohlfing, Inc., CPC 12631 East Imperial Highway Suite C-115 3 Santa Fe Springs, CA 90670 Tel.: (562) 868-5886 4 Fax: (562) 868-8868 E-mail: [email protected] 5 Attorneys for Plaintiff 6 Rosa Emma Villegas

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8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 ROSA EMMA VILLEGAS, ) Case No.: 2:24-cv-00908-AC ) 12 Plaintiff, ) STIPULATION AND PROPOSED ) ORDER FOR THE AWARD AND 13 vs. ) PAYMENT OF ATTORNEY FEES ) AND EXPENSES PURSUANT TO 14 LELAND DUDEK, ) THE EQUAL ACCESS TO JUSTICE Acting Commissioner of Social ) ACT,

(d) AND 15 Security, ) COSTS PURSUANT TO 28 U.S.C. § ) 1920 16 Defendant. ) ) 17 18 TO THE HONORABLE ALLISON CLAIRE, MAGISTRATE JUDGE OF 19 THE DISTRICT COURT: 20 IT IS HEREBY STIPULATED, by and between the parties through their 21 undersigned counsel, subject to the approval of the Court, that Rosa Emma 22 Villegas (“Villegas”) be awarded attorney fees and expenses in the amount of SIX 23 THOUSAND FIVE HUNDRED dollars ($6,500.00) under the Equal Access to 24 Justice Act (EAJA),

(d), and costs in the amount of zero dollars 25 ($0.00) under

. This amount represents compensation for all legal 26 1 services rendered on behalf of Plaintiff by counsel in connection with this civil 2 action, in accordance with

; 2412(d). 3 After the Court issues an order for EAJA fees to Villegas, the government 4 will consider the matter of Villegas's assignment of EAJA fees to Laura E. Krank. 5 The retainer agreement containing the assignment is attached as exhibit 1. 6 Pursuant to Astrue v. Ratliff,

(2010), the ability to honor the 7 assignment will depend on whether the fees are subject to any offset allowed under 8 the United States Department of the Treasury's Offset Program. After the order for 9 EAJA fees is entered, the government will determine whether they are subject to 10 any offset. 11 Fees shall be made payable to Villegas, but if the Department of the 12 Treasury determines that Villegas does not owe a federal debt, then the 13 government shall cause the payment of fees, expenses and costs to be made 14 directly to Law Offices of Lawrence D. Rohlfing, Inc., CPC, pursuant to the 15 assignment executed by Villegas.1 Any payments may be made by check or 16 electronic fund transfer (EFT) and shall be delivered to the Law offices of 17 Lawrence D. Rohlfing, Inc. 18 This stipulation constitutes a compromise settlement of Villegas's request

19 for EAJA attorney fees, and does not constitute an admission of liability on the part 20 of Defendant under the EAJA or otherwise. Payment of the agreed amount shall 21 constitute a complete release from, and bar to, any and all claims that Villegas 22 and/or Laura E. Krank including Law Offices of Lawrence D. Rohlfing, Inc., CPC 23 may have relating to EAJA attorney fees in connection with this action. 24

25 1 The parties do not stipulate whether counsel for the plaintiff has a cognizable lien under federal law against the recovery of EAJA fees that survives the Treasury 26 1 This award is without prejudice to the rights of Laura E. Krank and/or the 2 Law Offices of Lawrence D. Rohlfing, Inc., CPC to seek Social Security Act 3 attorney fees under

(b), subject to the savings clause provisions of 4 the EAJA. 5 DATE: April 15, 2025 Respectfully submitted, 6 LAW OFFICES OF LAWRENCE D. ROHLFING, INC., CPC

7 /s/ Laura E. Krank2 BY: _________________________ 8 Laura E. Krank Attorney for plaintiff Rosa Emma Villegas 9

10 DATED: April 15, 2025 MICHELE BECKWITH 11 ACTING United States Attorney 12 MATHEW W. PILE Associate General Counsel 13 Social Security Administration

14 /s/ Noah Schabacker 15

16 NOAH SCHABACKER Special Assistant United States Attorney 17 Attorneys for Defendant LELAND DUDEK, Acting Commissioner of 18 Social Security (Per e-mail authorization)

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25 2 Counsel for the plaintiff attests that all other signatories listed, and on whose behalf the filing is submitted, concur in the filing’s content and have authorized the 26 1 ORDER 2 Approved and so ordered: 3 || DATE: April 21, 2025 ~ (ite So

5 UNITED STATES MAGISTRATE JUDGE 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26