1 John Metsker, Esq., CA SBN 268977 THE METSKER LAW FIRM 2 P.O. Box 590881 3 San Francisco, CA 94159 Phone: 866-342-6180 4 [email protected] 5 Attorney for Plaintiff, Admitted Pro Hac Vice

6 Tiffany Gayle Doctors, Esq., NV SBN 14363 7 8390 W. Windmill Lane, Building B Las Vegas, NV 89113 8 Phone: 702-842-0901 9 [email protected] 10 Designated Resident Counsel for Plaintiff

11 UNITED STATES DISTRICT COURT 12 DISTRICT OF NEVADA 13

14 ZENIA BROWN, Case No. 2:25-cv-00383-JCM-NJK 15 Plaintiff, 16 STIPULATION AND [PROPOSED] v. ORDER FOR THE AWARD OF 17 ATTORNEY FEES PURSUANT TO FRANK BISIGNANO, THE EQUAL ACCESS TO JUSTICE 18 Commissioner of Social Security, ACT,

(d) 19 Defendant. 20 21 22 IT IS HEREBY STIPULATED by and between the parties through their 23 undersigned counsel, subject to the approval of the Court, that Plaintiff be awarded 24 attorney fees under the Equal Access to Justice Act (EAJA),

(d), 25 in the amount of FIVE THOUSAND SEVEN HUNDRED SIXTY-SEVEN 26 DOLLARS AND FOURTEEN CENTS ($5,767.14) and no costs or expenses under 27

. These amounts represent compensation for all legal services 28 rendered and costs incurred on behalf of Plaintiff, to date, by counsel in connection 1 with this civil action, in accordance with

(d) and 1920. 2 After the Court issues an order for EAJA fees to Plaintiff, the government 3 will consider the matter of Plaintiff’s assignment of EAJA fees and expenses to 4 Plaintiff's attorney. Pursuant to Astrue v. Ratliff,

(2010), the ability to 5 honor the assignment will depend on whether the fees, expenses are subject to any 6 offset allowed under the United States Department of the Treasury’s Offset 7 Program. After the order for EAJA fees and expenses is entered, the government 8 will determine whether they are subject to any offset. 9 Fees and expenses shall be made payable to Plaintiff, but if the Department 10 of the Treasury determines that Plaintiff does not owe a federal debt, then the 11 government shall cause the payment of fees to be made directly to John D. Metsker, 12 pursuant to the assignment executed by Plaintiff. Any payments made shall be 13 delivered to Plaintiff’s counsel. 14 This stipulation constitutes a compromise settlement of Plaintiff's request for 15 EAJA attorney fees and expenses, and does not constitute an admission of liability 16 on the part of Defendant under the EAJA. Payment of the agreed amount shall 17 constitute a complete release from, and bar to, any and all claims that Plaintiff 18 and/or Plaintiff's counsel may have relating to EAJA attorney fees, costs and 19 expenses in connection with this action. 20 This award is without prejudice to the rights of Plaintiff's counsel to seek 21 Social Security Act attorney fees under

, subject to the offset 22 provisions of the EAJA. 23 ///// 24 ///// 25 ///// 26 ///// 27 ///// 28 ////// 1 | Respectfully submitted, 2 3 Dated: September 26, 2025 /s/ John David Metsker JOHN DAVID METSKER 4 Attorney for Plaintiff 5 6 7 | Dated: September 26, 2025 /s/ Jeffrey E. Staples* JEFFREY E. STAPLES 8 *As authorized via email on September 26, 9 2025 Special Assistant United States Attorney 10 Attorney for Defendant 11 12 13 ORDER 14 Pursuant to the parties’ stipulation, IT IS SO ORDERED. 15 16 | DATE: September 30, 2025. ; (4id ©. Atoll 7 ‘HOM. JAMES C. MAHAN UNITED STATES DISTRICT JUDGE 18 19 20 21 22 23 24 25 26 27 28