Cairns v. Social Security Administration, Commissioner of

Filing 20

JOINT CASE MANAGEMENT PLAN FOR SOCIAL SECURITY CASES (ORDER). SS Plaintiffs Brief due by 9/2/2013. SS Defendants Brief due by 10/2/2013. SS Plaintiffs Reply Brief due by 10/17/2013. By Judge John L. Kane on 7/10/13. (mnfsl, )

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 13-cv-00901-AP
Lori Michelle Cairns,
Plaintiff,
v.
Carolyn W. Colvin, Acting Commissioner of Social Security,
Defendant.

JOINT CASE MANAGEMENT PLAN FOR SOCIAL SECURITY CASES

1.

APPEARANCES OF COUNSEL AND PRO SE PARTIES
For Plaintiff:
Chris W. Gordon, Esq.
Irwin & Boesen, P.C.
4100 E. Mississippi Ave., 19th Fl.
Denver, CO 80246
[phone]
[e-mail]
For Defendant:

John F. Walsh
United States Attorney

Michael A. Thomas
Special Assistant United States Attorney
Social Security Administration
Office of the General Counsel, Region VIII
1961 Stout St., Ste. 04-169
Denver, CO 80294
[phone]
[e-mail]

J. Benedict García
Assistant United States Attorney

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).

-1-

3.

DATES OF FILING OF RELEVANT PLEADINGS
A.
B.

Date Complaint Was Served on U.S. Attorney's Office: April 23, 2013

C.
4.

Date Complaint Was Filed: April 8, 2013

Date Answer and Administrative Record Were Filed: June 20, 2013

STATEMENT REGARDING THE ADEQUACY OF THE RECORD

The parties, to the best of their knowledge, state that the administrative record is complete and
accurate.
5.

STATEMENT REGARDING ADDITIONAL EVIDENCE

Neither party intends to submit additional evidence.
6.

STATEMENT REGARDING WHETHER THIS CASE 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.
8.

BRIEFING SCHEDULE

Due to Defendant’s counsel’s caseload and schedule, as well as Plaintiff’s counsel’s schedule, the
parties request a briefing schedule outside the standard time frame.
A.
B.

Defendant’s Response Brief Due: October 2, 2013

C.

9.

Plaintiff's Opening Brief Due: September 2, 2013

Plaintiff’s Reply Brief (If Any) Due: October 17, 2013

STATEMENTS REGARDING ORAL ARGUMENT
A.

Plaintiff's Statement: Plaintiff does not request oral argument.

B.

Defendant's Statement: Defendant does not request oral argument.

-2-

10.

CONSENT TO EXERCISE OF JURISDICTION BY MAGISTRATE JUDGE
Indicate below the parties' consent choice.
A.

B.

11.

(

)

(x)

All parties have consented to the exercise of jurisdiction of a
United States Magistrate Judge.
All parties have not consented to the exercise of jurisdiction of a
United States Magistrate Judge.

AMENDMENTS TO JOINT CASE MANAGEMENT PLAN

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.
The parties agree that the Joint Case Management Plan may be altered or amended only
upon a showing of good cause.
DATED this 10th day of July, 20 13.
BY THE COURT:
s/John L. Kane

U.S. DISTRICT COURT JUDGE

APPROVED:

UNITED STATES ATTORNEY

/s/J.J. Fraser, III

/s/Michael A. Thomas

J. J. Fraser, III, Esq.
Irwin & Boesen, P.C.
4100 E. Mississippi Ave., 19th Fl.
Denver, CO 80246
[phone]
[e-mail]

By: Michael A. Thomas
Special Assistant United States Attorney
Social Security Administration
Office of the General Counsel, Region VIII
1961 Stout St., Ste. 04-169
Denver, CO 80294
[phone]
[e-mail]

Attorney for Plaintiff

Attorneys for Defendant

-3-