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 Rosanna Nalbandian 11 12 UNITED STATES DISTRICT COURT 13 DISTRICT OF NEVADA 14 15 ROSANNA NALBANDIAN, ) Case No.: 2:24-cv-01946-BNW ) 16 Plaintiff, ) STIPULATION AND ORDER FOR ) THE AWARD AND PAYMENT OF 17 vs. ) ATTORNEY FEES AND ) EXPENSES PURSUANT TO THE 18 LELAND DUDEK, ) 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 BRENDA WEKSLER, MAGISTRATE JUDGE 23 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 Rosanna Nalbandian 26 (“Nalbandian”) be awarded attorney fees in the amount of THIRTY FOUR 1 HUNDRED dollars ($3,400.00) 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 Nalbandian, the 6 government will consider the matter of Nalbandian's assignment of EAJA fees to 7 Marc Kalagian. The retainer agreement containing the assignment is attached as 8 exhibit 1. Pursuant to Astrue v. Ratliff,

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

19 of costs may be made either by electronic fund transfer (ETF) or by check. 20 This stipulation constitutes a compromise settlement of Nalbandian's 21 request for EAJA attorney fees, and does not constitute an admission of liability on 22 the part of Defendant under the EAJA or otherwise. Payment of the agreed amount 23 shall constitute a complete release from, and bar to, any and all claims that 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 || Nalbandian and/or Marc Kalagian including Law Offices of Lawrence D. 2 || Rohlfing, Inc., CPC, may have relating to EAJA attorney fees in connection with 3 || this action. 4 This award is without prejudice to the rights of Marc Kalagian and/or the 5 || Law Offices of Lawrence D. Rohlfing, Inc., CPC, to seek Social Security Act 6 || attorney fees under

(b), subject to the savings clause provisions of 7 EAJA. 8 || DATE: April 30, 2025 Respectfully submitted, 9 LAW OFFICES OF LAWRENCE D. ROHLFING, INC., CPC 10 /s/ Ware. Katagyian BY: 1] Marc V. Kalagian Attorney for plaintiff 12 ROSANNA NALBANDIAN 13 14 DATE: April 30, 2025 SIGAL CHATTAH United States Attorney 15

17 DAVID PRIDDY Special Assistant United States Attorney 18 Attorneys for Defendant LELAND DUDEK, Acting Commissioner of 19 Social Security (Per e-mail authorization) 20 21 ORDER 92 Approved and so ordered: 93 || DATE: May 2, 2025 24 Zi Som le Are THE HONORABLE BRENDA WEKSLER 25 UNITED STATES MAGISTRATE JUDGE 26

1 DECLARATION OF MARC V. KALAGIAN 2 I, Marc V. Kalagian, declare as follows: 3 1. I am an attorney at law duly admitted to practice before this Court in this 4 case. I represent Rosanna Nalbandian in this action. I make this 5 declaration of my own knowledge and belief. 6 2. I attach as exhibit 1 a true and correct copy of the retainer agreement with 7 Rosanna Nalbandian containing an assignment of the EAJA fees. 8 3. I attach as exhibit 2 a true and correct copy of the itemization of time in 9 this matter. 10 I declare under penalty of perjury that the foregoing is true and correct to the 11 best of my knowledge and belief. 12 Executed this April 30, 2025, at Santa Fe Springs, California. 13 14 /s/ Marc V. Kalagian 15 _________________________ Marc V. Kalagian 16 17 18 19 20 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 May 1, 2025, 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. Rosanna Nalbandian 8425 Dunphy Ct 13 Las Vegas, NV 89145

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 Marc V. Kalagian ___ /s/ Marc V. Kalagian___________ 21 TYPE OR PRINT NAME SIGNATURE 22 23 24 25 26 1 CERTIFICATE OF SERVICE FOR CASE NUMBER 2:24-CV-01946-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 May 1, 2025. 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/ Marc V. Kalagian _______________________________ 10 Marc V. Kalagian 11 Attorneys for Plaintiff

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