1 Cyrus Safa Attorney at Law: 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) 868-8868 E-mail: [email protected] 5 Attorneys for Plaintiff 6 Tinisha Price 7 UNITED STATES DISTRICT COURT 8 DISTRICT OF NEVADA 9 10 TINISHA PRICE, ) Case No.: 2:19-cv-01319-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 Tinisha Price be 21 awarded attorney fees and expenses in the amount of three thousand two hundred 22 fifty dollars ($3,250.00) under the Equal Access to Justice Act (EAJA), 28 U.S.C. 23 § 2412(d). This amount represents compensation for all legal services rendered on 24 behalf of Plaintiff by counsel in connection with this civil action, in accordance 25 with

; 2412(d). 26 1 After the Court issues an order for EAJA fees to Tinisha Price, the 2 government will consider the matter of Tinisha Price's assignment of EAJA fees to 3 Cyrus Safa. The retainer agreement containing the assignment is attached as 4 exhibit 1. Pursuant to Astrue v. Ratliff,

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

19 relating to EAJA attorney fees in connection with this action. 20 /// 21 /// 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: May 8, 2020 Respectfully submitted, 5 LAW OFFICES OF LAWRENCE D. ROHLFING 6 /s/ Cyrus Safa BY: __________________ 7 Cyrus Safa Attorney for plaintiff Tinisha Price 8 9 DATE: May 11, 2020 10 NICHOLAS A. TRUTANICH United States Attorney 11 12 13 /s/ Allison J. Cheung 14 ALLISON J. CHEUNG 15 Special Assistant United States Attorney Attorneys for Defendant ANDREW SAUL, 16 Commissioner of Social Security (Per e-mail authorization) 17 18 19 DATED: May 12, 2020 IT IS SO ORDERED: 20 UNITED STATES MAGISTRATE JUDGE 21 ELAYNA J. YOUCHAH 22 23 24 25 26