1 KIMBERLY A. SANCHEZ Acting United States Attorney 2 MATHEW W. PILE Associate General Counsel 3 Office of Program Litigation, Office 7 MARGARET BRANICK-ABILLA (CABN 223600) 4 Special Assistant United States Attorney 5 Office of Program Litigation, Office 7 Office of the General Counsel 6 Social Security Administration 6401 Security Boulevard 7 Baltimore, MD 21235 8 Telephone: (510) 970-4809 Email: [email protected] 9 Attorneys for Defendant 10 UNITED STATES DISTRICT COURT 12 EASTERN DISTRICT OF CALIFORNIA 13 ALEJANDRO MARES, Civil No. 2:25-cv-00976-AC 14 Plaintiff, 15 STIPULATION FOR THE AWARD AND vs. PAYMENT OF ATTORNEY FEES PURSUANT 16 TO THE EQUAL ACCESS TO JUSTICE ACT , 17 COMMISSIONER OF SOCIAL SECURITY,

(d)

18 Defendant.

19

20 IT IS HEREBY STIPULATED by and between the parties, through their undersigned 21 counsel, subject to the approval of the Court, that Plaintiff be awarded attorney fees in the 22 amount of ONE THOUSAND, TWO HUNDRED DOLLARS AND ZERO CENTS ($1,200.00) 23 under the Equal Access to Justice Act (EAJA),

(d) and costs in the amount of 24 $405.00 (FOUR HUNDRED AND FIVE DOLLARS AND ZERO CENTS) under

1920. This amount represents compensation for all legal services rendered on behalf of Plaintiff 26 by counsel in connection with this civil action, in accordance with

(d). 27 After the Court issues an order for EAJA fees to Plaintiff, the government will consider 28 the matter of Plaintiff’s assignment of EAJA fees to counsel The Metsker Law Firm (Counsel). 1 Pursuant to Astrue v. Ratliff,

(2010), the ability to honor the assignment will 2 depend on whether the fees are subject to any offset allowed under the United States Department 3 of the Treasury’s Offset Program. After the order for EAJA fees is entered, the government will 4 determine whether they are subject to any offset. 5 Fees shall be made payable to Plaintiff, but if the Department of the Treasury determines 6 that Plaintiff does not owe a federal debt, then the government shall cause the payment of fees to 7 be made directly to Counsel, pursuant to the assignment executed by Plaintiff. Any payments 8 made shall be delivered to Counsel. Payments may be made by electronic funds transfer (EFT) or by check. 9 Plaintiff was an individual whose net worth did not exceed $2,000,000 at the time the 10 civil action was filed. 12 This stipulation constitutes a compromise settlement of Plaintiff’s request for EAJA 13 attorney fees, and does not constitute an admission of liability on the part of Defendant under the 14 EAJA or otherwise. Payment of the agreed amount shall constitute a complete release from, and 15 bar to, any and all claims that Plaintiff and/or Counsel, including Counsel’s law firm and any 16 associates, may have relating to EAJA attorney fees in connection with this action. 17 This award is without prejudice to the rights of Counsel to seek Social Security Act 18 attorney fees under

(b), subject to the savings clause provisions of the EAJA. 19 Respectfully submitted, 20 Dated: August 6, 2025 THE METSKER LAW FIRM 21 By: /s/ John Metsker* 22 JOHN METSKER Attorneys for Plaintiff 23 [*As authorized by e-mail Aug. 6, 2025]

24 Dated: August 6, 2025 KIMBERLY A. SANCHEZ Acting United States Attorney 25 MATHEW W. PILE Associate General Counsel 26 Office of Program Litigation, Office 7

27 By: /s/ Margaret Branick-Abilla MARGARET BRANICK-ABILLA 28 Special Assistant United States Attorney 1 Attorneys for Defendant > ORDER 3 || Pursuant to stipulation, IT IS SO ORDERED. 4 5 DATED: August 6, 2025 ~ 6 Cthten— Lape ALLISON CLAIRE 7 UNITED STATES MAGISTRATE JUDGE 8 9 10 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Stipulation; Order Page 3 Case No. 2:25-cv-00976-AC