The opinion
SUE FAHAMI
1 Acting United States Attorney
Nevada Bar No. 5634
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JEFFREY E. STAPLES, Washington Bar No. 45035
Special Assistant United States Attorney
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Office of the General Counsel
Social Security Administration
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6401 Security Boulevard
Baltimore, MD 21235
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E-Mail: jeff.staples@ssa.gov
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7 Attorneys for Defendant
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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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11 ZENIA BROWN, )
) Case No. 2:25-cv-00383-JCM-NJK
12 Plaintiff, )
) STIPULATION TO VOLUNTARY
13 v. ) REMAND PURSUANT TO SENTENCE
) FOUR OF 42 U.S.C. § 405(g) AND TO
14 FRANK BISIGNANO, ) ENTRY OF JUDGMENT FOR
Commissioner of Social Security, ) PLAINTIFF
15 )
Defendant. )
16 )
)
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The parties, through their respective counsel, stipulate to the following matters. The
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20 Commissioner’s final decision should be reversed and remanded for further administrative
21 proceedings before an Administrative Law Judge (ALJ). The ALJ should further develop the record,
22 offer Plaintiff a new hearing, and issue a new decision. The ALJ should reevaluate the evidence and
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the step-five finding, as necessary.
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Remand should be made under sentence four of 42 U.S.C. § 405(g). See Melkonyan v. Sullivan,
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501 U.S. 89 (1991). Plaintiff should be entitled to reasonable attorney fees and expenses pursuant to
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28 U.S.C. § 2412(d), upon proper request to this Court. Plaintiff should be entitled to costs as
4 enumerated in 28 U.S.C. § 1920, under 28 U.S.C. § 2412(a).
3 The parties further request that the Clerk of the Court be directed to enter a final judgment in
4 || favor of Plaintiff and against Defendant, reversing the Commissioner’s final decision.
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Dated: July 2, 2025 Respectfully submitted,
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/s/ John Metsker
8 JOHN METSKER
(*as authorized via email)
9 Attorney for Plaintiff
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11 || Dated: July 2, 2025 Respectfully submitted,
12 SUE FAHAMI
B Acting United States Attorney
14 /s/ Jeffrey E. Staples
JEFFREY E. STAPLES
15 Special Assistant United States Attorney
Attorneys for Defendant
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17 IT IS SO ORDERED:
18 : a (tid ©. Ato law
HON. JAMES C. MAHAN
? UNITED STATES DISTRICT JUDGE
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July 3, 2025
DATED: □□
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11 CERTIFICATE OF SERVICE
22 I, the undersigned, am a citizen of the United States and am at least eighteen years of age. My
33 business address is 6401 Security Boulevard, Baltimore, MD 21235. I am not a party to the above-
entitled action. On the date set forth below, I caused a copy of the above STIPULATION TO
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VOLUNTARY REMAND PURSUANT TO SENTENCE FOUR OF 42 U.S.C. § 405(g) AND TO
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ENTRY OF JUDGMENT FOR PLAINTIFF to be served upon the following by:
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77 CM/ECF:
John Metsker
88 jmetsker@metskerlaw.com
99 I declare under penalty of perjury that the foregoing is true and correct.
1100 Dated: July 2, 2025
1111
/s/ Jeffrey E. Staples
1122 JEFFREY E. STAPLES
Special Assistant United States Attorney
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