1 Marc V. Kalagian Attorney at Law: 4460 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 Leonard Stone 6 Attorney at Law: 5791 Shook & Stone 7 710 South 4th Street Las Vegas, NV 89101 8 Tel.: (702) 385-2220 Fax: (702) 384-0394 9 E-mail: [email protected] 10 Attorneys for Plaintiff Ashley Renee Pinon 11 12 UNITED STATES DISTRICT COURT 13 DISTRICT OF NEVADA 14 15 ASHLEY RENEE PINON, ) Case No.: 3:22-cv-00139-CSD ) 16 Plaintiff, ) STIPULATION AND ORDER FOR ) THE AWARD AND PAYMENT OF 17 vs. ) ATTORNEY FEES AND ) EXPENSES PURSUANT TO THE 18 KILOLO KIJAKAZI, ) EQUAL ACCESS TO JUSTICE Acting Commissioner of Social ) ACT,

(d) AND 19 Security, ) COSTS PURSUANT TO 28 U.S.C. § ) 1920 20 Defendant. ) ) 21 22 TO THE HONORABLE CRAIG STEPHEN DENNEY, MAGISTRATE 23 JUDGE OF THE DISTRICT COURT: 24 IT IS HEREBY STIPULATED, by and between the parties through their 25 undersigned counsel, subject to the approval of the Court, that Ashley Renee Pinon 26 be awarded attorney fees in the amount of FOUR THOUSAND EIGHT 1 HUNDRED dollars ($4,800.00) under the Equal Access to Justice Act (EAJA), 28

(d), and no costs under

. This amount represents 3 compensation for all legal services rendered on behalf of Plaintiff by counsel in 4 connection with this civil action, in accordance with

; 2412(d). 5 After the Court issues an order for EAJA fees to Ashley Renee Pinon, the 6 government will consider the matter of Ashley Renee Pinon's assignment of EAJA 7 fees to Marc Kalagian. The retainer agreement containing the assignment is 8 attached as exhibit 1. Pursuant to Astrue v. Ratliff,

(2010), 9 the ability to honor the assignment will depend on whether the fees are subject to 10 any offset allowed under the United States Department of the Treasury's Offset 11 Program. After the order for EAJA fees is entered, the government will determine 12 whether they are subject to any offset. 13 Fees shall be made payable to Ashley Renee Pinon, but if the Department of 14 the Treasury determines that Ashley Renee Pinon does not owe a federal debt, then 15 the government shall cause the payment of fees, expenses and costs to be made 16 directly to Law Offices of Lawrence D. Rohlfing, Inc., CPC, pursuant to the 17 assignment executed by Ashley Renee Pinon.1 Any payments made shall be 18 delivered to Law Offices of Lawrence D. Rohlfing, Inc., CPC.

19 This stipulation constitutes a compromise settlement of Ashley Renee 20 Pinon's request for EAJA attorney fees, and does not constitute an admission of 21 liability on the part of Defendant under the EAJA or otherwise. Payment of the 22 agreed amount shall constitute a complete release from, and bar to, any and all 23 claims that Ashley Renee Pinon and/or Marc Kalagian including Law Offices of 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 || Lawrence D. Rohlfing, Inc., CPC, may have relating to EAJA attorney fees in 2 connection with this action. 3 This award is without prejudice to the rights of Marc Kalagian and/or the 4 || Law Offices of Lawrence D. Rohlfing, Inc., CPC, to seek Social Security Act 5 || attorney fees under

(b), subject to the savings clause provisions of 6 || the EAJA. 7 ||DATE: August 31, 2023 Respectfully submitted, 8 LAW OFFICES OF LAWRENCE D. ROHLFING, INC., CPC 9 /S| WareV. Kalagian I BY: 0 Marc V. Kalagian Attorney for plaintiff 1 ASHLEY RENEE PINON 12 DATED: August 31, 2023 JASON M. FRIERSON United States Attorney 14 15 |s| WUangaret 7. Branich- tbilla 16 MARGARET I. BRANICK-ABILLA Special Assistant United States Attorney 17 Attorneys for Defendant KILOLO KIJAKAZI, Acting Commissioner of 18 Social Security (Per e-mail authorization) 19 20 ORDER 21 Approved and so ordered: 22 DATED: September 6, 2023 23 CS 24 THE HONORABLE CRAIG S HEN DENNEY UNITED STATES MAGISTRATE JUDGE 25 26