1 Paul Sachelari, CSBN 230083 Law Offices of Francesco Benavides 2 1990 N. California Blvd. 8th Floor Walnut Creek, CA 94596 3 Tel: (925) 222-7071 Email: paul@sachelarilaw.com 4 Attorney for Plaintiff 5

6 UNITED STATES DISTRICT COURT 7 EASTERN DISTRICT OF CALIFORNIA 8

9 BRAD CHRISTOPHER OLIVER, Case No. 2:25-cv-01866-AC

10 Plaintiff, STIPULATION FOR THE AWARD AND

PAYMENT OF ATTORNEY FEES AND

11 v. EXPENSES PURSUANT TO THE EQUAL 12 ACCESS TO JUSTICE ACT; [PROPOSED]

COMMISSIONER OF SOCIAL SECURITY, ORDER

13 Defendant. 14

15 IT IS HEREBY STIPULATED by and between the parties through their undersigned counsel, 16 subject to the approval of the Court, that Plaintiff be awarded attorney fees and expenses in the amount 17 of $10,000.00, under the Equal Access to Justice Act (EAJA), 28 U.S.C. § 2412(d), and no costs under 18 19 28 U.S.C. § 1920. This amount represents compensation for all legal services rendered on behalf of 20 Plaintiff by counsel in connection with this civil action, in accordance with 28 U.S.C. §§ 2412(d), 21 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 25 whether the fees are subject to any offset allowed under the United States Department of the 26 Treasury’s Offset Program. After the order for EAJA fees is entered, the government will determine 27 whether they are 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 Respectfully submitted,

14 Dated: December 22, 2025 Law Offices of Francesco Benavides 15 By: /s/ Paul Sachelari 16 PAUL SACHELARI Attorney for Plaintiff 17

18 Dated: December 22, 2025 ERIC GRANT 19 United States Attorney

MATHEW W. PILE

20 Associate General Counsel Social Security Administration 21

22 By: Marcelo Illarmo*

MARCELO ILLARMO

23 Special Assistant U.S. Attorney Attorneys for Defendant 24 (*Permission to use electronic signature obtained via email on December 22, 2025). 25

26 27 1 [PROPOSED] ORDER 2 Based upon the parties’ Stipulation for the Award and Payment of Equal Access to Justice Act 3 || Fees and Expenses, IT IS ORDERED that fees and expenses in the amount of $10,000.00 as 4 || authorized by 28 U.S.C. § 2412, and no costs under 28 U.S.C. § 1920, be awarded subject to the terms 5 of the Stipulation. 6 7 8 || DATE: December 23, 2025 ~

10 ALLISON CLAIRE

UNITED STATES MAGISTRATE JUDGE

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