1 MARGARET LEHRKIND 2 SBCA # 314717 Lehrkind Law Office, P.C. 3 2625 Alcatraz Ave, # 208 Berkeley, CA 94705 4 Tel: 510-590-1907 5 [email protected] 6 7 UNITED STATES DISTRICT COURT 8 EASTERN DISTRICT OF CALIFORNIA 9 SANDRA FAYE BARGAS, Case No.: 1:25-cv-00740-SKO 10 Plaintiff, STIPULATION AND UNOPPOSED 11 MOTION FOR THE AWARD AND 12 vs. PAYMENT OF ATTORNEY FEES AND EXPENSES PURUSANT TO THE EQUAL 13 ACCESS TO JUSTICE ACT; ORDER COMMISSIONER OF SOCIAL SECURITY,

14 Defendant (Doc. 14) 15 16 The parties, through their respective counsel, hereby agree that attorney fees in the 17 amount of $2,191.00 shall be awarded to Plaintiff pursuant to the Equal Access to Justice Act 18 (EAJA),

, and costs of $0, pursuant to

. Such attorney fees 19 shall be subject to verification that Plaintiff has no debt that qualifies for offset, pursuant to the 20 Treasury Offset Program as discussed in Astrue v. Ratliff,

(2010). 21 If the U.S. Department of the Treasury determines that Plaintiff’s EAJA fees are not 22 subject to any offset allowed under the Department of the Treasury’s Offset Program, then the 23 check or electronic funds transfer for EAJA fees shall be made payable to Plaintiff’s attorney, 24 Margaret Lehrkind, based upon Plaintiff’s assignment of these amounts to her. See Exhibit – 25 Retainer Agreement. If Plaintiff has a debt, then any remaining funds after offset shall be made 26 payable to Plaintiff and mailed to counsel’s address. 27 This stipulation constitutes a compromise settlement of Plaintiff’s request for EAJA 28 attorney fees and expenses and does not constitute an admission of liability on the part of 1 Defendant under the EAJA. Payment of the agreed amount shall constitute a complete release 2 from, and bar to, any and all claims that Plaintiff and/or Plaintiff’s counsel may have relating to 3 EAJA attorney fees and expenses in connection with this action. 4 This award is without prejudice to the rights of Plaintiff’s counsel to seek Social Security 5 Act attorney fees under

, subject to the offset provisions of the EAJA. 6 DATE: September 30, 2025 Respectfully submitted, 7 8 Lehrkind Law Office, P.C. 9 10 By: /s/ Margaret Lehrkind MARGARET LEHRKIND 11 Attorney for Plaintiff

12 DATE: September 30, 2025 By: /s/ Oscar Gonzalez de Llano* 13 OSCAR GONZALEZ DE LLANO *As authorized via email on 9/30/25 14 Special Assistant United States Attorney Attorney for Defendant 15 16 17

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19 20 21 22 23 24 25 26 27 28 1 ORDER 2 Based upon the parties’ Stipulation and Unopposed Motion for the Award and Payment 3 of Equal Access to Justice Act Fees and Expenses, (Doc. 14), 4 IT IS ORDERED that fees and expenses in the amount of $2,191.00 as authorized by 28

, and no costs under

, be awarded subject to the terms of the 6 Stipulation. 7 IT IS SO ORDERED. 8 9 Dated: September 30, 2025 /s/ Sheila K. Oberto . 10 UNITED STATES MAGISTRATE JUDGE 11

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