1 FORSLUND LAW, LLC Jacqueline A. Forslund # 154575 2 P.O. Box 4476 Sunriver, OR 97707 3 Telephone: 541-419-0074 4 Fax: 541-593-4452 Email: [email protected] 5 Attorney for Plaintiff 6

7 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA 8 JASON RUSSELL LOPEZ, ) Case No. 2:24-CV-01721-JDP 9 ) 10 Plaintiff ) STIPULATION AND PROPOSED ) ORDER FOR AWARD OF ATTORNEY’S 11 v. ) FEES UNDER THE EQUAL ACCESS TO ) JUSTICE ACT (EAJA), 12 LELAND DUDEK1, ) 13 Acting Commissioner of Social Security, ) ) 14 Defendant ) ) 15 ____________________________________) 16 IT IS HEREBY STIPULATED by and between the parties through their undersigned counsel, 17 subject to the approval of the Court, that Plaintiff be awarded attorney’s fees under the Equal Access 18 to Justice Act (EAJA), 28 U.S.C sec. 2412(d) in the amount of NINE THOUSAND SEVEN 19 HUNDRED dollars and ZERO cents ($9,700.00). This amount represents compensation for all legal 20 services rendered on behalf of Plaintiff by counsel in connection with this civil action, in accordance 21 with 28 U.S.C sec. 2412(d). 22 After the Court issues and order for payment of EAJA fees and expenses to Plaintiff, the government will consider the matter of Plaintiff’s assignment of EAJA fees and expenses to 23 Plaintiff’s attorney. The government’s ability to honor the assignment will depend on whether the 24 fees and expenses are subject to an offset allowed under the United States Department of the 25 26

27 1 Leland Dudek became the Acting Commissioner of Social Security on February 16, 2025. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, Leland Dudek should be substituted for Michelle King as the defendant in this suit. No further action need be 28 taken to continue this suit by reason of the last sentence of section 205(g) of the Social Security Act,

(g). 1 Treasury’s Offset Program pursuant to Astrue v. Ratliff,

(2010). After the order of 2 EAJA fees and expenses is entered, the government will determine if they are subject to an offset. If it is determined that Plaintiff’s EAJA fees and expenses are not subject to an offset under 3 Astrue v. Ratliff,

(2010) and the Department of Treasury’s Offset Program, then the 4 check for EAJA fees and expenses shall be made payable to Jacqueline A. Forslund, based upon 5 Plaintiff’s assignment of these amounts to Plaintiff’s attorney. The parties agree that whether these 6 checks are made payable to Plaintiff or Jacqueline A. Forslund, such checks shall be mailed to 7 Plaintiff’s attorney. 8 This stipulation constitutes a compromise settlement of Plaintiff’s request for EAJA attorney 9 fees, and does not constitute an admission of liability on the part of Defendant under the EAJA or 10 otherwise. Payment of the agreed amount shall constitute a complete release from, and bar to, any and all claims that Plaintiff and/or Plaintiff’s Counsel may have relating to EAJA attorney fees in 11 connection with this action. 12

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15 Respectfully submitted, 16 Date: April 30, 2025 JACQUELINE A. FORSLUND 17 Attorney at Law

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19 /s/Jacqueline A. Forslund JACQUELINE A. FORSLUND 20 Attorney for Plaintiff

21 Date: April 30, 2025 MICHELLE BECKWITH 22 Acting United States Attorney MATHEW W. PILE 23 Associate General Counsel Social Security Administration 24 /s/James Ki 25 James Ki 26 Special Assistant United States Attorney *By email authorization 27 Attorney for Defendant

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1 2 3 4 ORDER 5 © IS SO ORDERED. 7 / ® Dated: __May 2, 2025 gyre Wns 9 JEREMY D. PETERSON UNITED STATES MAGISTRATE JUDGE 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Lopez v Dudek Stipulation and Prepesed Order E.D. Cal. 2:24-cv-01721-JDP