1 Brian C. Shapiro Attorney at Law: 192789 2 Law Offices of Lawrence D. Rohlfing, Inc., CPC 12631 East Imperial Highway Suite C-115 3 Santa Fe Springs, CA 90670 Tel.: (562) 868-5886 4 Fax: (562) 868-8868 E-mail: [email protected] 5 Attorneys for Plaintiff 6 Tanesha Hale

7

8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 TANESHA HALE, ) Case No.: 2:25-cv-02106-CKD ) 12 Plaintiff, ) STIPULATION AND PROPOSED ) ORDER FOR THE AWARD AND 13 vs. ) PAYMENT OF ATTORNEY FEES ) AND EXPENSES PURSUANT TO 14 FRANK BISIGNANO, ) THE EQUAL ACCESS TO JUSTICE Commissioner of Social Security, ) ACT,

(d) AND 15 ) COSTS PURSUANT TO 28 U.S.C. § Defendant. ) 1920; DECLARATION OF Brian C. 16 ) Shapiro ) 17 18 TO THE HONORABLE CAROLYN K. DELANEY, MAGISTRATE 19 JUDGE OF THE DISTRICT COURT: 20 IT IS HEREBY STIPULATED, by and between the parties through their 21 undersigned counsel, subject to the approval of the Court, that Tanesha Hale 22 (“Hale”) be awarded attorney fees and expenses in the amount of FOUR 23 THOUSAND TWO HUNDRED FIFTY dollars ($4,250.00) under the Equal 24 Access to Justice Act (EAJA),

(d), and no costs under

1920. This amount represents compensation for all legal services rendered on 26 1 behalf of Plaintiff by counsel in connection with this civil action, in accordance 2 with

; 2412(d). 3 After the Court issues an order for EAJA fees to Hale, the government will 4 consider the matter of Hale's assignment of EAJA fees to Brian C. Shapiro. The 5 retainer agreement containing the assignment is attached as exhibit 1. Pursuant to 6 Astrue v. Ratliff,

(2010), the ability to honor the assignment 7 will depend on whether the fees are subject to any offset allowed under the United 8 States Department of the Treasury's Offset Program. After the order for EAJA fees 9 is entered, the government will determine whether they are subject to any offset. 10 Fees shall be made payable to Hale, but if the Department of the Treasury 11 determines that Hale does not owe a federal debt, then the government shall cause 12 the payment of fees, expenses and costs to be made directly to Law Offices of 13 Lawrence D. Rohlfing, Inc., CPC, pursuant to the assignment executed by Hale.1 14 Any payments may be made by check or electronic fund transfer (EFT) and shall 15 be delivered to the Law offices of Lawrence D. Rohlfing, Inc. 16 This stipulation constitutes a compromise settlement of Hale's request for 17 EAJA attorney fees, and does not constitute an admission of liability on the part of

18 Defendant under the EAJA or otherwise. Payment of the agreed amount shall 19 constitute a complete release from, and bar to, any and all claims that Hale and/or 20 Brian C. Shapiro including Law Offices of Lawrence D. Rohlfing, Inc., CPC may 21 have relating to EAJA attorney fees in connection with this action. 22 This award is without prejudice to the rights of Brian C. Shapiro and/or the 23 Law Offices of Lawrence D. Rohlfing, Inc., CPC to seek Social Security Act 24

25 1 The parties do not stipulate whether counsel for the plaintiff has a cognizable lien under federal law against the recovery of EAJA fees that survives the Treasury 26 1 attorney fees under

(b), subject to the savings clause provisions of 2 the EAJA. 3 DATE: December 5, 2025 Respectfully submitted, 4 LAW OFFICES OF LAWRENCE D. ROHLFING, INC., CPC

5 /s/ Brian C. Shapiro2 BY: _________________________ 6 Brian C. Shapiro Attorney for plaintiff Tanesha Hale 7

8 DATED: December 5, 2025 MICHELE BECKWITH 9 Acting United States Attorney 10 MATHEW W. PILE Associate General Counsel 11 Social Security Administration

12 /s/ David Priddy 13

14 DAVID PRIDDY Special Assistant United States Attorney 15 Attorneys for Defendant FRANK BISIGNANO, Commissioner of Social 16 Security (Per e-mail authorization)

17

18

19 20 21 22 23 24

25 2 Counsel for the plaintiff attests that all other signatories listed, and on whose behalf the filing is submitted, concur in the filing’s content and have authorized the 26 1 ORDER 2 Accordingly, IT IS ORDERED THAT: 3 1. The parties’ stipulation (ECF No. 17) is GRANTED; and 4 2. Tanesha Hale is awarded attorney fees and expenses in the amount of FOUR 5 THOUSAND TWO HUNDRED FIFTY dollars ($4,250.00) under the Equal 6 Access to Justice Act (EAJA),

(d), and no costs under 28

pursuant to the terms of the stipulation. 8 || Dated: December 9, 2025 Yr?) ae

CAROLYN K. DELANEY 10 UNITED STATES MAGISTRATE JUDGE 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26

1 DECLARATION OF BRIAN C. SHAPIRO 2 I, Brian C. Shapiro, declare as follows: 3 1. I am an attorney at law duly admitted to practice before this Court in this 4 case. I represent Tanesha Hale in this action. I make this declaration of 5 my own knowledge and belief. 6 2. I attach as exhibit 1 a true and correct copy of the itemization of time in 7 this matter. 8 3. I attach as exhibit 2 a true and correct copy of the retainer agreement with 9 Tanesha Hale containing an assignment of the EAJA fees. 10 I declare under penalty of perjury that the foregoing is true and correct to the 11 best of my knowledge and belief. 12 Executed this December 5, 2025, at Santa Fe Springs, California. 13 14 /s/ Brian C. Shapiro 15 _________________________ Brian C. Shapiro 16 17 18 19 20 21 22 23 24 25 26 1 PROOF OF SERVICE 2 3 S TATE IO aFm CA eLmIFpOloRyNeIAd, iCnO tUhNe TcYo uOnFt LyO oSf ALNoGsE ALEnSg eles, State of California. I am over 4 the age of 18 and not a party to the within action. My business address is 12631 5 East Imperial Highway, Suite C-115, Santa Fe Springs, California 90670. 6 On this day of December 5, 2025, I served the foregoing document 7 described as STIPULATION FOR THE AWARD AND PAYMENT OF 8 ATTORNEY FEES AND EXPENSES PURSUANT TO THE EQUAL ACCESS 9 TO JUSTICE ACT,

(d) AND COSTS PURSUANT TO 28 U.S.C. 10 § 1920 on the interested parties in this action by placing a true copy thereof 11 enclosed in a sealed envelope addressed as follows: 12 Ms. Tanesha Hale 4545 10th Ave. 13 Sacramento, CA 95820

14 I caused such envelope with postage thereon fully prepaid to be placed in the 15 United States mail at Santa Fe Springs, California. 16 I declare under penalty of perjury under the laws of the State of California 17 that the above is true and correct. 18 I declare that I am employed in the office of a member of this court at whose 19 direction the service was made. 20 Brian C. Shapiro ___ /s/ Brian C. Shapiro____________ 21 TYPE OR PRINT NAME SIGNATURE 22 23 24 25 26