KAREN NELSON MOORE, Circuit Judge. Toby Studabaker pleaded guilty to causing the foreign travel of a minor with the intent to engage in criminal sexual activity and to possessing and attempting to possess child pornography. The district court sentenced Studabaker to 136 months of incarceration for the foreign-travel charge and 87 months of incarceration for the child-pornography charge, to run concurrently. On appeal, Studabaker argues that the district court lacked jurisdiction over the child-pornography offense because there was an insufficient factual basis to support his guilty plea, that his prosecution violated double jeopardy, that the district court erred when it sentenced him without considering his prior incarceration, and that the district court imposed an above-Guidelines sentence without a sufficient factual basis.

For the reasons explained herein, we AFFIRM Studabaker’s convictions and sentence.

JULIA SMITH GIBBONS, Circuit Judge. Petitioner Ibrahim Parlak seeks review of the Board of Immigration Appeals’ (“BIA”) decision affirming the decision of the immigration judge (“IJ”) ordering Parlak’s removal from the United States pursuant to various provisions of the Immigration and Naturalization Act (“INA”). Specifically, Parlak argues that the BIA erred by: (1) determining that Parlak was removable for fraud or willful misrepresentation pursuant to 8 U.S.C. § 1182(a)(6)(C)(i); (2) determining that Parlak was removable for engaging in terrorist activity pursuant to 8 U.S.C. § 1182(a)(3)(B)(i); (3) determining that Parlak’s removal could not be withheld because he persecuted others and thus lacked refugee status under 8 U.S.C. § 1101(a)(42)(A), rendering him ineligible for withholding of removal pursuant to 8 U.S.C. § 1231(b)(3); (4) failing to address properly the IJ’s reliance on allegedly torture- induced evidence; and (5) denying Parlak’s application for a grant of deferral of removal under the Convention Against Torture (“CAT”).

In summary, we deny Parlak’s petition for review, concluding that the BIA correctly determined that he was removable for making willful misrepresentations in his adjustment and naturalization applications, that he was ineligible for withholding of removal because he assisted in the persecution of others, and that he has not met his burden for obtaining relief under the CAT. We need not reach the issues of whether Parlak was removable on other bases.

JULIA SMITH GIBBONS, Circuit Judge. Plaintiff-appellant Jerry Rice appeals the dismissal of his suit pursuant to the Employee Retirement Income Security Act of 1974 (“ERISA”), 29 U.S.C. § 1001 et seq., against defendant-appellee Jefferson Pilot Financial Insurance Company, NKA, Lincoln Financial Group (“Jefferson Pilot”). Rice brought a claim against Jefferson Pilot in the United States District Court for the Southern District of Ohio challenging the denial of his application for long-term disability benefits. The district court granted Jefferson Pilot’s motion for judgment as a matter of law, finding that Rice’s complaint was barred by the applicable statute of limitations. On appeal, Rice challenges the district court’s determination of the date on which his claim accrued.

For the following reasons, we employ a different analysis than the district court but ultimately affirm the dismissal of Rice’s ERISA claim.

COLE, Circuit Judge. Plaintiffs-Appellants Clarence Bryant and John C. Turner (collectively, “Plaintiffs”) appeal from separate cases awarding attorney fees directly to Plaintiffs rather than to their attorneys under the Equal Access to Justice Act (the “EAJA”), 28 U.S.C. § 2412(d). This Court consolidated Plaintiffs’ appeals. Plaintiffs, who are both represented by the same counsel, argue that the district court’s decision to award fees to Plaintiffs is contrary to the past practices of the Social Security Administration, at odds with a recent decision of this Court, and deleterious to the ability of Social Security claimants to obtain legal representation. Specifically, Plaintiffs argue that awarding attorney-fee payments directly to plaintiffs subjects those payments to administrative offset under the Debt Collection Improvement Act of 1996 (the “DCIA”), 31 U.S.C. § 3716, reducing or completely eliminating Plaintiffs’ ability to pay for legal services. Plaintiffs also argue that the district court erred in refusing to increase the EAJA compensable hourly rate from $125 to $150.

We share Plaintiffs’ concern that awarding attorney fees to successful parties, rather than to their attorneys, will prevent some successful plaintiffs from paying their lawyers and, ultimately, may prevent future claimants from obtaining counsel in the first place. However, the plain language of the EAJA, as well as Supreme Court case law interpreting similar language in other statutes, convinces us that we must AFFIRM the district court’s decisions.

BOYCE F. MARTIN, JR., Circuit Judge. Professionals Direct Insurance Company petitions this Court for a writ of mandamus to vacate a discovery order issued by the district court. Professionals Direct contends that the order erroneously compels it to produce documents protected by the federal work-product doctrine and by Ohio’s attorney-client privilege. Because we find that Professionals Direct has not met the heavy burden required to justify a writ of mandamus, we DENY its petition.