Thomas v. Astrue

Filing 11

Joint Case Management Plan for Social Security Cases. SS Plaintiff's Brief due by 6/19/2012. SS Defendant's Brief due by 7/19/2012. SS Plaintiff's Reply Brief due by 8/3/2012, by Judge John L. Kane on 5/9/12. (lygsl, )

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 1:12-cv-00416-AP
RANDALL THOMAS,
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:
Chris R. Noel
3000 Pearl Street, Suite 212
Boulder, CO 80301-2431
Telephone: [phone]
email: [e-mail]

For Defendant:
JOHN F. WALSH
United States Attorney
WILLIAM G. PHARO
Assistant United States Attorney
United States Attorney=s Office
District of Colorado
[e-mail]
DAVID BLOWER
Special Assistant United States Attorney
Office of the General Counsel
Social Security Administration
1001 Seventeenth Street
Denver, CO 80202
Telephone:[phone]
[e-mail]

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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.
B.

Date Complaint Was Served on U.S. Attorney=s Office: February 21, 2012

C.

4.

Date Complaint Was Filed: February 16, 2012

Date Answer and Administrative Record Were Filed: April 20, 2012

STATEMENT REGARDING THE ADEQUACY OF THE RECORD

The parties, to the best of their knowledge, state that the administrative record is complete and
accurate. However, the Plaintiff reserves the right to supplement the record if necessary at the
time of the Opening Brief.

5.

STATEMENT REGARDING ADDITIONAL EVIDENCE

Plaintiff will review the administrative record to insure it is complete and accurate. Plaintiff will
seek to submit additional evidence as required after review of the record. Defendant does not
anticipate submitting additional evidence.

6.

STATEMENT REGARDING WHETHER THIS CASE RAISES UNUSUAL
CLAIMS OR DEFENSES

The parties, to the best of their knowledge, do not believe this case raises unusual claims or
defenses.

7.

OTHER MATTERS
There are no other matters anticipated.

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8.

BRIEFING SCHEDULE
Counsel for both parties agree to the following proposed briefing schedule:
A.
B.

Defendant=s Response Brief Due: July 19, 2012

C.

9.

Plaintiffs Opening Brief Due: June 19, 2012

Plaintiffs Reply Brief (If Any) Due: August 3, 2012

STATEMENTS REGARDING ORAL ARGUMENT
A.
B.

10.

Plaintiffs Statement: Plaintiff requests oral argument.
Defendant=s Statement: Defendant does not request oral argument

CONSENT TO EXERCISE OF JURISDICTION BY MAGISTRATE JUDGE

All parties have not 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.LCivR 7.1(C) BY SUBMITTING PROOF THAT A
COPY OF THE MOTION HAS BEEN SERVED UPON THE MOVING ATTORNEY=S
CLIENT, 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.

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DATED this 9th day of May, 2012.
BY THE COURT:

s/John L. Kane
_________
U.S. DISTRICT COURT JUDGE
APPROVED:
/s/Chris R. Noel
Chris R. Noel
3000 Pearl Street, Suite 212
Boulder, CO 80301-2431
Telephone: [phone]
email: [e-mail]
Attorney for Plaintiff

JOHN F. WALSH
United States Attorney
WILLIAM G. PHARO
Assistant United States Attorney
United States Attorney=s Office
District of Colorado
[e-mail]
By: /s/David Blower
David Blower
Special Assistant United States Attorney
1001 Seventeenth Street
Denver, Colorado 80202
Telephone: [phone]
[e-mail]
Attorneys for Defendant.

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