1 Cyrus Safa Nevada Bar No: 13241 2 Law Offices of Lawrence D. Rohlfing 12631 East Imperial Highway, Suite C-115 3 Santa Fe Springs, CA 90670 Tel.: (562) 868-5886 4 Fax: (562) 868-5491 E-mail [email protected] 5 Attorneys for Plaintiff 6 Raymond A. Chatmon 7 UNITED STATES DISTRICT COURT 8 DISTRICT OF NEVADA 9 10 RAYMOND A. CHATMON, ) Case No.: 2:19-cv-01201-EJY ) 11 Plaintiff, ) STIPULATION AND {PROPOSED} ) ORDER FOR THE AWARD AND 12 vs. ) PAYMENT OF ATTORNEY FEES ) AND EXPENSES PURSUANT TO 13 ANDREW SAUL, ) THE EQUAL ACCESS TO JUSTICE Commissioner of Social Security, ) ACT,

(d) AND 14 ) COSTS PURSUANT TO 28 U.S.C. § Defendant. ) 1920 15 ) ) 16 17 TO THE HONORABLE ELAYNA J. YOUCHAH, MAGISTRATE JUDGE 18 OF THE DISTRICT COURT: 19 IT IS HEREBY STIPULATED by and between the parties through their 20 undersigned counsel, subject to the approval of the Court, that Raymond A. 21 Chatmon be awarded attorney fees and expenses in the amount of two thousand 22 two hundred eighty-one dollars and three cents dollars ($2,281.03) under the Equal 23 Access to Justice Act (EAJA),

(d), and no costs under

1920. This amount represents compensation for all legal services rendered on 25 behalf of Plaintiff by counsel in connection with this civil action, in accordance 26 with

; 2412(d). 1 After the Court issues an order for EAJA fees to Raymond A. Chatmon, the 2 government will consider the matter of Raymond A. Chatmon's assignment of 3 EAJA fees to Cyrus Safa. The retainer agreement containing the assignment is 4 attached as exhibit 1. Pursuant to Astrue v. Ratliff,

(2010), 5 the ability to honor the assignment will depend on whether the fees are subject to 6 any offset allowed under the United States Department of the Treasury's Offset 7 Program. After the order for EAJA fees is entered, the government will determine 8 whether they are subject to any offset. 9 Fees shall be made payable to Raymond A. Chatmon, but if the Department 10 of the Treasury determines that Raymond A. Chatmon does not owe a federal debt, 11 then the government shall cause the payment of fees, expenses and costs to be 12 made directly to Law Offices of Lawrence D. Rohlfing, pursuant to the assignment 13 executed by Raymond A. Chatmon.1 Any payments made shall be delivered to 14 Cyrus Safa. 15 This stipulation constitutes a compromise settlement of Raymond A. 16 Chatmon's request for EAJA attorney fees, and does not constitute an admission of 17 liability on the part of Defendant under the EAJA or otherwise. Payment of the 18 agreed amount shall constitute a complete release from, and bar to, any and all

19 claims that Raymond A. Chatmon and/or Cyrus Safa including Law Offices of 20 Lawrence D. Rohlfing may have relating to EAJA attorney fees in connection with 21 this action. 22 23 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 This award is without prejudice to the rights of Cyrus Safa and/or the Law 2 Offices of Lawrence D. Rohlfing to seek Social Security Act attorney fees under 3

(b), subject to the savings clause provisions of the EAJA. 4 DATE: March 19, 2020 Respectfully submitted, 5 LAW OFFICES OF LAWRENCE D. ROHLFING 6 /s/ Cyrus Safa BY: __________________ 7 Cyrus Safa Attorney for plaintiff Raymond A. Chatmon 8 9 DATED: March 19, 2020 NICHOLAS A. TRUTANICH 10 United States Attorney 11 12 /s/ Allison J. Cheung 13 14 ALLISON J. CHEUNG Special Assistant United States Attorney 15 Attorneys for Defendant ANDREW SAUL, Commissioner of Social Security 16 (Per e-mail authorization) 17 IT IS SO ORDERED 18 19 DATE: March 20, 2020 20 21 ___________________________________ THE HONORABLE ELAYNA J. YOUCHAH 22 UNITED STATES MAGISTRATE JUDGE 23 24 25 26