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 Shajuanda Michelle Martin 11

12 UNITED STATES DISTRICT COURT 13 DISTRICT OF NEVADA 14 15 SHAJUANDA MICHELLE MARTIN, ) Case No.: 2:25-cv-01234-BNW ) 16 Plaintiff, ) STIPULATION AND PROPOSED ) ORDER FOR THE AWARD AND 17 vs. ) PAYMENT OF ATTORNEY FEES ) AND EXPENSES PURSUANT TO 18 FRANK BISIGNANO, ) THE EQUAL ACCESS TO JUSTICE Commissioner of Social Security, ) ACT,

(d) AND 19 ) COSTS PURSUANT TO 28 U.S.C. § Defendant. ) 1920 20 ) ) 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 Shajuanda Michelle 26 Martin (“Martin”) be awarded attorney fees in the amount of THIRTEEN 1 HUNDRED dollars ($1,300.00) 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 Martin, the government 6 will consider the matter of Martin's assignment of EAJA fees to Marc Kalagian. 7 The retainer agreement containing the assignment is attached as exhibit 1. 8 Pursuant to Astrue v. Ratliff,

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

19 by electronic fund transfer (ETF) or by check. 20 This stipulation constitutes a compromise settlement of Martin's request for 21 EAJA attorney fees, and does not constitute an admission of liability on the part of 22 Defendant under the EAJA or otherwise. Payment of the agreed amount shall 23 constitute a complete release from, and bar to, any and all claims that Martin 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 || and/or Marc Kalagian including Law Offices of Lawrence D. Rohlfing, Inc., CPC, 2 ||may have relating to EAJA attorney fees in connection with this action. 3 This award is without prejudice to the rights of Mare 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: November 13,2025 — Respectfully submitted, 8 LAW OFFICES OF LAWRENCE D. ROHLFING, INC., CPC 9 /s/ WMareV, Kalagian* BY: 10 Marc V. Kalagian Attorney for plaintiff SHAJUANDA MICHELLE MARTIN 12 1 DATE:November 13, 2025 SIGAL CHATTAH 3 United States Attorney 14 15 /s/ pbagela Thoratou-Mklard 16 ANGELA THORNTON-MILLARD Special Assistant United States Attorney 17 Attorneys for Defendant FRANK BISIGNANO, Commissioner of Social 18 Security (Per e-mail authorization) 19 ORDER 20 Approved and so ordered: 21 DATE: November 17, 2025

23 THEHO BLE BRENDA WEKSLER UNITED STATES MAGISTRATE JUDGE 24 25 ||? Counsel for the plaintiff attests that all other signatories listed, and on whose 6 || behalf the filing is submitted, concur in the filing’s content and have authorized the filing.

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 Shajuanda Michelle Martin 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 Shajuanda Michelle Martin 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 November 13, 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 November 14, 2025, I served the foregoing document 7 described as STIPULATION FOR THE AWARD AND PAYMENT OF 8 ATTORNEY FEES AND EXPENSES PURSUANT TO THE EQUAL ACCESS 9 TO JUSTICE ACT,

(d) AND COSTS PURSUANT TO 28 U.S.C. 10 § 1920 on the interested parties in this action by placing a true copy thereof 11 enclosed in a sealed envelope addressed as follows: 12 Ms. Shajuanda Michelle Martin P O Box 34672 13 Las Vegas, NV 89133

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