1 MARGARET LEHRKIND SBCA # 314717 2 Lehrkind Law Office, P.C. 3 2625 Alcatraz Ave, # 208 Berkeley, CA 94705 4 Tel: 510-590-1907 [email protected] 5

6 7 UNITED STATES DISTRICT COURT 8 EASTERN DISTRICT OF CALIFORNIA 9 CHELSEA ROSE SEXSON, CASE NO.: 2:25-cv-01800-SCR 10 Plaintiff, STIPULATION FOR THE AWARD AND 11 PAYMENT OF ATTORNEY FEES AND vs. EXPENSES PURSUANT TO THE EQUAL 12 ACCESS TO JUSTICE ACT; ORDER COMMISSIONER OF SOCIAL SECURITY, 13 14 Defendant

15 The parties, through their respective counsel, hereby agree that attorney fees in the 16 17 amount of $9,900 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 23 subject to any offset allowed under the Department of the Treasury’s Offset Program, then the 24 check or electronic funds transfer for EAJA fees shall be made payable to Plaintiff’s attorney, 25 Margaret Lehrkind, based upon Plaintiff’s assignment of these amounts to her. See Exhibit – 26 27 STIPULATION FOR THE AWARD AND PAYMENT OF ATTORNEY FEES AND EXPENSES PURSUANT TO THE EQUAL ACCESS TO JUSTICE ACT; ORDER - 1 28 1 Retainer Agreement. If Plaintiff has a debt, then any remaining funds after offset shall be made 2 payable to Plaintiff and mailed to counsel’s address. 3 This stipulation constitutes a compromise settlement of Plaintiff’s request for EAJA 4 attorney fees and expenses and does not constitute an admission of liability on the part of 5 6 Defendant under the EAJA. Payment of the agreed amount shall constitute a complete release 7 from, and bar to, any and all claims that Plaintiff and/or Plaintiff’s counsel may have relating to 8 EAJA attorney fees and expenses in connection with this action. 9 This award is without prejudice to the rights of Plaintiff’s counsel to seek Social Security 10 Act attorney fees under

, subject to the offset provisions of the EAJA. 11 12 13 DATE: November 3, 2025 Respectfully submitted, 14 15 Lehrkind Law Office, P.C.

16 By: /s/ Margaret Lehrkind 17 MARGARET LEHRKIND Attorney for Plaintiff 18 DATE: November 3, 2025 By: /s/ Katherine Bennett Watson * 19 KATHERINE BENNETT WATSON 20 *As authorized via email on 10/31/25 Special Assistant United States Attorney 21 Attorney for Defendant

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26 27 STIPULATION FOR THE AWARD AND PAYMENT OF ATTORNEY FEES AND EXPENSES PURSUANT TO THE EQUAL ACCESS TO JUSTICE ACT; ORDER - 2 28 1 5 [PROPOSED] ORDER 3 Based upon the parties’ Stipulation for the Award and Payment of Equal Access to 4 || Justice Act Fees and Expenses (the “Stipulation”), > IT IS ORDERED that fees and expenses in the amount of NINE THOUSAND NINE HUNDRED ($9,900) as authorized by the Equal Access to Justice Act (EAJA),

2412(d), and ZERO dollars ($0.00), pursuant to

be awarded subject to the g of the Stipulation. 10 IT IS SO ORDERED. 12 || DATE: November 17, 2025

14 SEAN C. RIORDAN UNITED STATES MAGISTRATE JUDGE

16 17 18 19 20 21 22 23 24 25 26 27 || STIPULATION FOR THE AWARD AND PAYMENT OF ATTORNEY FEES AND 3g EXPENSES PURSUANT TO THE EQUAL ACCESS TO JUSTICE ACT; ORDER - 3