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 Gerald M. Welt 6 Attorney at Law: 1575 732 S. Sixth Street, Suite 200-D 7 Las Vegas, NV 89101 Tel.: (702) 382-2030 8 Fax: (702) 684-5157 E-mail: [email protected]; [email protected] 9 Attorneys for Plaintiff 10 Linda Patterson

11 UNITED STATES DISTRICT COURT 12 DISTRICT OF NEVADA 13 14 LINDA PATTERSON, ) Case No.: 2:18-cv-01951-BNW ) 15 Plaintiff, ) STIPULATION AND {PROPOSED} ) ORDER FOR THE AWARD AND 16 vs. ) PAYMENT OF ATTORNEY FEES ) AND EXPENSES PURSUANT TO 17 ANDREW SAUL, ) THE EQUAL ACCESS TO JUSTICE Commissioner of Social Security, ) ACT,

(d) AND 18 ) COSTS PURSUANT TO 28 U.S.C. § Defendant. ) 1920 19 ) ) 20 21 TO THE HONORABLE BRENDA WEKSLER, MAGISTRATE JUDGE 22 OF THE DISTRICT COURT: 23 IT IS HEREBY STIPULATED by and between the parties through their 24 undersigned counsel, subject to the approval of the Court, that Linda Patterson be 25 awarded attorney fees and expenses in the amount of two thousand four hundred 26 dollars ($2,400.00) under the Equal Access to Justice Act (EAJA),

2412(d), and no costs under

. This amount represents 2 compensation for all legal services rendered on behalf of Plaintiff by counsel in 3 connection with this civil action, in accordance with

; 2412(d). 4 After the Court issues an order for EAJA fees to Linda Patterson, the 5 government will consider the matter of Linda Patterson's assignment of EAJA fees 6 to Cyrus Safa. The retainer agreement containing the assignment is attached as 7 exhibit 1. Pursuant to Astrue v. Ratliff,

(2010), the ability to 8 honor the assignment will depend on whether the fees are subject to any offset 9 allowed under the United States Department of the Treasury's Offset Program. 10 After the order for EAJA fees is entered, the government will determine whether 11 they are subject to any offset. 12 Fees shall be made payable to Linda Patterson, but if the Department of the 13 Treasury determines that Linda Patterson does not owe a federal debt, then the 14 government shall cause the payment of fees, expenses and costs to be made 15 directly to Law Offices of Lawrence D. Rohlfing, pursuant to the assignment 16 executed by Linda Patterson.1 Any payments made shall be delivered to Cyrus 17 Safa.

18 This stipulation constitutes a compromise settlement of Linda Patterson's 19 request for EAJA attorney fees, and does not constitute an admission of liability on 20 the part of Defendant under the EAJA or otherwise. Payment of the agreed amount 21 shall constitute a complete release from, and bar to, any and all claims that Linda 22 Patterson and/or Cyrus Safa including Law Offices of Lawrence D. Rohlfing may 23 have relating to EAJA attorney fees in connection with this action. 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: June 8, 2020 Respectfully submitted, 5 LAW OFFICES OF LAWRENCE D. ROHLFING 6 /s/ Cyrus Saba BY: 7 Cyrus Sata g Attorney for plaintiff Linda Patterson

? DATE: June 8, 2020 NICHOLAS A. TRUTANICH 10 United States Attorney 11 2 /S/ “Faa Matcher 13 TINA NAICKER Special Assistant United States Attorney 14 Attorneys for Defendant ANDREW SAUL, Commissioner of Social Security 15 (Per e-mail authorization) 16 IT IS SO ORDERED: 17 18 DATE: 6/10/2020 19 les sre ben 20 E HONORABLE BRENDA WEKSLER UNITED STATES MAGISTRATE JUDGE 21 22 23 24 25 26

1 PROOF OF SERVICE 2 STATE OF CALIFORNIA, COUNTY OF LOS ANGELES 3 I am employed in the county of Los Angeles, 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 June 9, 2020, I served the foregoing document described as 7 STIPULATION FOR THE AWARD AND PAYMENT OF ATTORNEY FEES 8 AND EXPENSES PURSUANT TO THE EQUAL ACCESS TO JUSTICE ACT, 9

(d) AND COSTS PURSUANT TO

on the 10 interested parties in this action by placing a true copy thereof enclosed in a sealed 11 envelope addressed as follows: 12 Ms. Linda Patterson 2109 Sunrise Avenue, Apt. 4 13 Las Vegas, NV 89101

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 Cyrus Safa ___ /s/ Cyrus Safa____________ 21 TYPE OR PRINT NAME SIGNATURE 22 23 24 25 26 1 CERTIFICATE OF SERVICE FOR CASE NUMBER 2:18-CV-01951-BNW 2 I hereby certify that I electronically filed the foregoing with the Clerk of the 3 4 Court for this court by using the CM/ECF system on June 9, 2020. 5 I certify that all participants in the case are registered CM/ECF users and 6 that service will be accomplished by the CM/ECF system, except the plaintiff 7 served herewith by mail. 8 9 /s/ Cyrus Safa _______________________________ 10 Cyrus Safa 11 Attorneys for Plaintiff

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