1 NICHOLAS A. TRUTANICH United States Attorney 2 District of Nevada

3 ALLISON J. CHEUNG, CSBN 244651 Special Assistant United States Attorney 4 160 Spear Street, Suite 800 San Francisco, California 94105 5 Telephone: (415) 977-8942 Facsimile: (415) 744-0134 6 E-Mail: [email protected]

7 Attorneys for Defendant

8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA 10

11 WANDA OSBORNE, ) ) Case No.: 3:19-cv-00671-CLB 12 Plaintiff, ) ) STIPULATION FOR THE AWARD AND 13 v. ) PAYMENT OF ATTORNEY FEES AND ) EXPENSES PURSUANT TO THE EQUAL 14 ANDREW SAUL, ) ACCESS TO JUSTICE ACT, 28 U.S.C. Commissioner of Social Security, ) § 2412(d), AND COSTS PURSUANT TO 15 )

Defendant. ) 16 ) ) 17

18 19 20 21 22 23 24 25 26 11 IT IS HEREBY STIPULATED by and between the parties through their undersigned counsel, 22 subject to the approval of the Court, that Plaintiff Wanda Osborne be awarded attorney fees and 33 expenses in the amount of one thousand fifty-nine dollars and fourteen cents ($1,059.14) under the 44 Equal Access to Justice Act (EAJA),

(d), and costs in the amount of two hundred and 55 seventy-five dollars ($275.00) under

. This amount represents compensation for all 66 legal services rendered on behalf of Plaintiff by counsel in connection with this civil action, in 77 accordance with

, 2412(d). 88 After the Court issues an order for EAJA fees to Plaintiff, the government will consider the 99 matter of Plaintiff’s assignment of EAJA fees to Jared T. Walker. Pursuant to Astrue v. Ratliff, 560

, 598,

,

(2010), the ability to honor the assignment will depend 1111 on whether the fees are subject to any offset allowed under the United States Department of the 1122 Treasury’s Offset Program. After the order for EAJA fees is entered, the government will determine 1133 whether they are subject to any offset. 1144 Fees shall be made payable to Plaintiff, but if the Department of the Treasury determines that 1155 Plaintiff does not owe a federal debt, then the government shall cause the payment of fees, expenses 1166 and costs to be made directly to Jared T. Walker, pursuant to the assignment executed by Plaintiff. 1177 Any payments made shall be delivered to counsel, Jared T. Walker. 1188 This stipulation constitutes a compromise settlement of Plaintiff’s request for EAJA attorney 1199 fees, and does not constitute an admission of liability on the part of Defendant under the EAJA or 2200 otherwise. Payment of the agreed amount shall constitute a complete release from, and bar to, any and 2211 all claims that Plaintiff Wanda Osborne, Jared T. Walker (including Law Office of Jared T. Walker) 2222 and/or Hal Taylor, may have relating to EAJA attorney fees in connection with this action. 2233 // 2244 // 2255 // 2266 1 This award is without prejudice to the rights of Jared Walker and/or Law Office of Jared T. 2 || Walker to seek Social Security Act attorney fees under

(b), subject to the savings 3 || clause provisions of the EAJA. 4 5 || Dated: June 9, 2020 Respectfully submitted, 6 LAW OFFICE OF JARED T. WALKER 7 /s/ Jared T. Walker JARED T. WALKER 8 (*as authorized via email on June 8, 2020) Attorney for Plaintiff 9 Dated: June 9, 2020 Respectfully submitted, 10 NICHOLAS A. TRUTANICH 11 United States Attorney 12 /s/ Allison J. Cheung ALLISON J. CHEUNG 13 Special Assistant United States Attorney Attorneys for Defendant 14 15 16 17 ITIS SO D: ‘ 18 19 HON. CARLA L. BALDWIN UNITED STATES GISTRATE JUDGE 20 DATED: June 9.20200 22 23 24 25 26

11 CERTIFICATE OF SERVICE 22 I, Allison J. Cheung, certify that the following individual(s) were served with a copy of the 33 foregoing STIPULATION FOR THE AWARD AND PAYMENT OF ATTORNEY FEES AND 44 EXPENSES PURSUANT TO THE EQUAL ACCESS TO JUSTICE ACT,

(d), 55 AND COSTS PURSUANT TO

on the date, and via the method of service, 66 identified below: 77 CM/ECF: 88 Jared T. Walker 99 [email protected] Attorney for Plaintiff 1100 Hal Taylor 1111 [email protected] 1122 Attorney for Plaintiff

1133 Dated: June 9, 2020

1144 /s/ Allison J. Cheung 1155 ALLISON J. CHEUNG Special Assistant United States Attorney 1166 1177 1188 1199 2200 2211 2222 2233 2244 2255 2266