Russ v. Colvin

Filing 18

JOINT CASE MANAGEMENT PLAN FOR SOCIAL SECURITY CASES (ORDER). SS Plaintiffs Brief due by 9/30/2013. SS Defendants Brief due by 10/30/2013. SS Plaintiffs Reply Brief due by 11/14/2013. By Judge John L. Kane on 8/20/13. (mnfsl, )

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 13-cv-1319-AP
MELISSA RUSS,
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:
Joseph A. Whitcomb
Rocky Mountain Disability Law Group
1391 Speer Blvd., Suite 705
Denver, CO 80204
Phone: [phone]
Email: [e-mail]

For Defendant:
John F. Walsh
United States Attorney
James L. Burgess
Special Assistant United States Attorney
Office of the General Counsel
Social Security Administration-Region VIII
1969 Stout Street, Suite 4169
Denver, CO 80294-4003
Phone: [phone]
Email: [e-mail]
J. Benedict García
Assistant United States Attorney
1225 Seventeenth Street, Suite 700
Denver, CO 80202
Phone: [phone]
Email: [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.
B.

Date Complaint Was Served on U.S. Attorney's Office: May 29, 2013

C.
4.

Date Complaint Was Filed: May 20, 2013

Date Answer and Administrative Record Were Filed: July 29, 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

The parties do 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. Plaintiff’s current claim does not involve any prior
judicial proceedings.
8.

BRIEFING SCHEDULE

Attorneys for both parties agree to the following proposed briefing schedule:
A.

Plaintiff’s Opening Brief Due: September 30, 2013

B.

Defendant’s Response Brief Due: October 30, 2013

C.

Plaintiff’s Reply Brief (If Any) Due: November 14, 2013

9.

STATEMENTS REGARDING ORAL ARGUMENT
A.
B.

10.

Plaintiff's Statement: Plaintiff does not request 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.

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 20th day of August, 2013.
BY THE COURT:
s/John L. Kane
U.S. DISTRICT COURT JUDGE
APPROVED:

JOHN F. WALSH
UNITED STATES ATTORNEY
J. Benedict García
Assistant United States Attorney

s/ Joseph A. Whitcomb
Joseph A. Whitcomb
Rocky Mountain Disability Law Group
1391 Speer Blvd., Suite 705
Phone: [phone]
Email: [e-mail]
Counsel for Plaintiff

s/ James L. Burgess
Special Assistant United States Attorney
Office of the General Counsel
Social Security Administration-Region VIII
Denver, CO 80204
1969 Stout Street, Suite 4169
Denver, CO 80294-4003
Phone: [phone]
Email: [e-mail]
Counsel for Defendant