1 Francesco Benavides, CSBN 258924 Law Offices of Francesco Benavides 2 1990 N. California Blvd. 8th Floor Walnut Creek, CA 94596 3 Tel: (925) 222-7071 Email: francesco@benavidesdisabilitylaw.com 4 Attorney for Plaintiff 5

SARA ANN HALE

6 7 UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF CALIFORNIA

8

FRESNO DIVISION

9

10 SARA ANN HALE, Case No. 1:25-cv-00184-SKO

11 Plaintiff, STIPULATION AND UNOPPOSED MOTION

FOR THE AWARD AND PAYMENT OF

12 v. ATTORNEY FEES AND EXPENSES 13 PURSUANT TO THE EQUAL ACCESS TO

JUSTICE ACT; ORDER

14 FRANK BISIGNANO, Commissioner of Social Security, (Doc. 17) 15 Defendant. 16 17 IT IS HEREBY STIPULATED by and between the parties through their undersigned counsel, 18 subject to the approval of the Court, that Plaintiff be awarded attorney fees and expenses in the amount 19 of $8,475.00, under the Equal Access to Justice Act (EAJA), 28 U.S.C. § 2412(d), and no costs under 20 28 U.S.C. § 1920. This amount represents compensation for all legal services rendered on behalf of 21 Plaintiff by counsel in connection with this civil action, in accordance with 28 U.S.C. §§ 2412(d), 1920. 22 After the Court issues an order for EAJA fees to Plaintiff, the government will consider the 23 matter of Plaintiff’s assignment of EAJA fees to counsel. Pursuant to Astrue v. Ratliff, 560 U.S. 586, 24 598, 130 S.Ct. 2521, 177 L.Ed.2d 91 (2010), the ability to honor the assignment will depend on whether 25 the fees are subject to any offset allowed under the United States Department of the Treasury’s Offset 26 Program. After the order for EAJA fees is entered, the government will determine whether they are 27 subject to any offset. 1 Fees shall be made payable to Plaintiff, but if the Department of the Treasury determines that 2 Plaintiff does not owe a federal debt, then the government shall cause the payment of fees, expenses 3 and costs to be made directly to Plaintiff’s counsel, Francesco Benavides, pursuant to the assignment 4 executed by Plaintiff. 5 Payments may be made by electronic funds transfer (EFT) or by check. 6 This stipulation constitutes a compromise settlement of Plaintiff’s request for EAJA attorney 7 fees and does not constitute an admission of liability on the part of Defendant under the EAJA or 8 otherwise. Payment of the agreed amount shall constitute a complete release from, and bar to, any 9 and all claims that Plaintiff and/or Francesco Benavides, including the Law Offices of Francesco 10 Benavides, may have relating to EAJA attorney fees in connection with this action. 11 This award is without prejudice to the rights of Francesco Benavides to seek Social Security 12 Act attorney fees under 42 U.S.C. § 406(b), subject to the savings clause provisions of the EAJA. 13 14 Respectfully submitted,

15

16 Dated: September 17, 2025 Law Offices of Francesco Benavides

17 By: /s/ Francesco Benavides

FRANCESCO P. BENAVIDES

18 Attorney for Plaintiff 19

20

21 Dated: September 17, 2025 ERIC GRANT 22 United States Attorney 23 MATHEW W. PILE Associate General Counsel 24 Social Security Administration

25 By: Marla Letellier*

MARLA LETELLIER

26 Special Assistant U.S. Attorney 27 Attorneys for Defendant 1 (*Permission to use electronic signature obtained via email on September 17, 2025). 2 3

ORDER

4 Based upon the parties’ Stipulation and Unopposed Motion for the Award and Payment of Equal 5 Access to Justice Act Fees and Expenses, (Doc. 17), 6 IT IS ORDERED that fees and expenses in the amount of EIGHT THOUSAND FOUR 7 HUNDRED AND SEVENTY-FIVE DOLLARS ($8,475.00) as authorized by the Equal Access to 8 Justice Act (EAJA), 28 U.S.C. § 2412(d), be awarded subject to the terms of the Stipulation. 9

10

IT IS SO ORDERED.

11 Dated: September 17, 2025 /s/ Sheila K. Oberto . 12

UNITED STATES MAGISTRATE JUDGE

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