Shrank v. Astrue

Filing 14

Joint Case Management Plan for Social Security Cases (ORDER) SS Plaintiffs Brief due by 7/23/2011. SS Defendants Brief due by 8/22/2011. SS Plaintiffs Reply Brief due by 9/6/2011, by Judge John L. Kane on 6/13/11. (gmssl, )

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 11-cv-00693-AP
JULIE A. SHRANK,
Plaintiff,
v.
MICHAEL J. ASTRUE, Commissioner of Social Security,
Defendant.
____________________________________________________________________________
JOINT CASE MANAGEMENT PLAN FOR SOCIAL SECURITY CASES
______________________________________________________________________________
1.

APPEARANCES OF COUNSEL AND PRO SE PARTIES

For Plaintiff:
Alan M. Agee
512 S. 8th Street
Colorado Springs, CO 80905
[phone]
[e-mail]

For Defendant:
John F. Walsh
United States Attorney
Kevin T. Traskos
Deputy Civil Chief
United States Attorney’s Office
District of Colorado
William G. Pharo
United States Attorney Office
District of Colorado
Michael Howard
Special Assistant United States Attorney
Office of the General Counsel
Social Security Administration
1001 17th St.
Denver, Colorado 80202
[phone]
[e-mail]

2.

STATEMENT OF LEGAL BASIS FOR SUBJECT MATTER JURISDICTION
The Court has jurisdiction based on section 205(g) of the Social Security Act, 42 U.S.C.
§ 405(g).

3.

DATES OF FILING OF RELEVANT PLEADINGS
A. Date Complaint was filed: March 18, 2011
B. Date Complaint was served on U.S. Attorney’s Office: March 21, 2011
C. Date Answer and Administrative Record were filed: May 23, 2011

4.

STATEMENT REGARDING THE ADEQUACY OF THE RECORD
Plaintiff's counsel states that the administrative record may be missing records that have
previously been submitted to the Appeals Council. Otherwise the administrative record is
complete.
Defendant's counsel states, to the best of his knowledge, that the administrative record is
complete.

5.

STATEMENT REGARDING ADDITIONAL EVIDENCE
Plaintiff does not intend to submit additional evidence unless records are missing that
have been previously submitted to the Appeals Council.
Defendant does not intend to submit additional evidence.

6.

STATEMENT REGARDING WHETHER THIS CASES RAISES UNUSUAL CLAIMS
OR DEFENSES
The parties, to the best of their knowledge, do not believe the case raises unusual claims
or defenses.

7.

OTHER MATTERS
The parties have no other matters to bring to the attention of the Court.

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8.

BRIEFING SCHEDULE
The parties respectfully request the following briefing schedule
A. Plaintiff’s opening brief due: July 23, 2011
B. Defendant’s response brief due: August 22, 2011
C. Plaintiff’s reply brief (if any) due: September 6, 2011

9.

STATEMENTS REGARDING ORAL ARGUMENT
A.
B.

10.

Plaintiff requests oral argument.
Defendant does not request oral argument.

CONSENT TO EXERCISE OF JURISDICTION BY MAGISTRATE JUDGE
All parties have consented to the exercise of jurisdiction of a United States Magistrate
Judge.

11.

OTHER MATTERS
THE PARTIES FILING MOTIONS FOR EXTENSION OF TIME OR
CONTINUANCES MUST COMPLY WITH D.C. COLO.L.CivR. 7.1(C) BY
SUBMITTING PROOF THAT A COPY OF THE MOTION HAS BEEN SERVED
UPON ALL ATTORNEYS OF RECORD AND ALL PRO SE PARTIES.

12.

AMENDMENTS TO JOINT CASE MANAGEMENT PLAN
The parties agree that the Joint Case Management Plan may be altered or amended only
upon a showing of good cause.
DATED this 13th day of June, 2011.
BY THE COURT:

s/John L. Kane
U.S. DISTRICT COURT JUDGE

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APPROVED:
/s/ Alan M. Agee
Alan M. Agee
512 S. 8th Street
Colorado Springs, CO 80905
[phone]
[e-mail]

John F. Walsh
United States Attorney
Kevin T. Traskos
Deputy Civil Chief
United States Attorney’s Office
District of Colorado
William G. Pharo
United States Attorney Office
District of Colorado
/s/ Michael S. Howard
Michael Howard
Special Assistant United States Attorney
Office of the General Counsel
Social Security Administration
1001 17th St.
Denver, Colorado 80202
[phone]
[e-mail]

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