1 John Metsker, Esq. SBN 268977 2 THE METSKER LAW FIRM 3 P.O. Box 590881 San Francisco, CA 94159 4 Phone: 866-342-6180 5 Fax: 415-500-4081 [email protected] 6 Attorney for Plaintiff 7

8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10

11 HANNAH M. PADUANO, No. 2:24-cv-01706-SCR 12 Plaintiff, 13 STIPULATION AND [PROPOSED] v. ORDER FOR THE AWARD OF 14 ATTORNEY FEES PURSUANT TO COMMISSIONER OF SOCIAL 15 SECURITY, THE EQUAL ACCESS TO JUSTICE ACT,

(d) 16 Defendant. 17 18 IT IS HEREBY STIPULATED by and between the parties through their 19 undersigned counsel, subject to the approval of the Court, that Plaintiff be awarded 20 21 attorney fees under the Equal Access to Justice Act (EAJA),

(d), 22 in the amount of FOUR THOUSAND SEVEN HUNDRED THIRTY-FOUR 23 24 DOLLARS AND FIFTY-NINE CENTS ($4,734.59) and no costs under 28 U.S.C. 25 § 1920. These amounts represent compensation for all legal services rendered and 26 costs incurred on behalf of Plaintiff, to date, by counsel in connection with this civil 27 28 action, in accordance with

(d) and 1920. 1 After the Court issues an order for EAJA fees to Plaintiff, the government 2 will consider the matter of Plaintiff’s assignment of EAJA fees and expenses to 3 Plaintiff's attorney. Pursuant to Astrue v. Ratliff,

(2010), the ability to 4 5 honor the assignment will depend on whether the fees are subject to any offset 6 allowed under the United States Department of the Treasury’s Offset Program. 7 8 After the order for EAJA fees and expenses is entered, the government will 9 determine whether they are subject to any offset. 10 Fees shall be made payable to Plaintiff, but if the Department of the Treasury 11 12 determines that Plaintiff does not owe a federal debt, then the government shall 13 cause the payment of fees to be made directly to Plaintiff’s counsel, John D. 14 Metsker, pursuant to the assignment executed by Plaintiff. Any payments made 15 16 shall be delivered to Plaintiff’s counsel. 17 This stipulation constitutes a compromise settlement of Plaintiff's request for 18 EAJA attorney fees, and does not constitute an admission of liability on the part of 19 20 Defendant under the EAJA. Payment of the agreed amount shall constitute a 21 complete release from, and bar to, any and all claims that Plaintiff and/or Plaintiff's 22 counsel may have relating to EAJA attorney fees, costs, and expenses in connection 23 24 with this action. 25 ///// 26 ///// 27 28 ///// | This award is without prejudice to the rights of Plaintiff's counsel to seek 2 Social Security Act attorney fees under

, subject to the offset 3 4 | provisions of the EAJA. 5 6 . Respectfully submitted, 7 8 | Dated: September 30, 2025 /s/ John David Metsker 9 JOHN DAVID METSKER Attorney for Plaintiff 10 11 12 | Dated: September 30, 2025 /s/ Marcelo Illarmo 13 MARCELO ILLARMO *As authorized via email on 14 September 30, 2025 15 Special Assistant United States Attorney 6 Attorney for Defendant

17 18 19 [PROPOSED] ORDER 20 Pursuant to the parties’ stipulation, IT IS SO ORDERED. 21 22 | DATE: October 6, 2025 23 24 /

25 SEAN C. RIORDAN UNITED STATES MAGISTRATE JUDGE 26 27 28