Ghini v. Colvin

Filing 17

Joint Case Management Plan for Social Security Cases. SS Plaintiffs Brief due by 3/24/2014. SS Defendants Brief due by 4/23/2014. SS Plaintiffs Reply Brief due by 5/8/2014 by Judge John L. Kane on 02/05/14. (jhawk, )

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 1:13-cv-02790-AP JOSEPH A. GHINI, 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: Teresa H. Abbott 3515 S. Tamarac, Suite 200 Denver, CO 80237 303-757-5000 303-689-9627 (facsimile) Abbott.teresa@gmail.com For Defendant: John F. Walsh United States Attorney J. Benedict García Assistant United States Attorney United States Attorney’s Office District of Colorado J.B.Garcia@usdoj.gov Alexess D. Rea Special Assistant United States Attorney 1961 Stout St., Ste. 4169 Denver, Colorado 80294 303-844-7101 303-844-0770 (facsimile) Alexess.rea@ssa.gov -1- 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: 10/28/2013 C. 4. Date Complaint Was Filed: 10/11/2013 Date Answer and Administrative Record Were Filed: 01/21/2014 STATEMENT REGARDING THE ADEQUACY OF THE RECORD To the best of his knowledge, Plaintiff states that the record is complete and accurate. To the best of his knowledge, Defendant states that the 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 state that this case does not raise unusual claims or defenses. 7. OTHER MATTERS The parties state that there are no other matters. 8. BRIEFING SCHEDULE A. Plaintiff's Opening Brief Due: 03/24/2014 B. Defendant’s Response Brief Due: 04/23/2014 C. Plaintiff’s Reply Brief (If Any) Due: 05/08/2014 -2- 9. STATEMENTS REGARDING ORAL ARGUMENT A. Plaintiff's Statement: Plaintiff does not request oral argument. B. Defendant's Statement: Defendant does not request oral argument. 10. CONSENT TO EXERCISE OF JURISDICTION BY MAGISTRATE JUDGE Indicate below the parties' consent choice. A. ( ) All parties have consented to the exercise of jurisdiction of a United States Magistrate Judge. B. ( X ) 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 5th day of February, 2014. BY THE COURT: s/John L. Kane U.S. DISTRICT COURT JUDGE -3- APPROVED: John F. Walsh United States Attorney s/ Teresa Abbott Teresa H. Abbott #27192 Law Office of Teresa Abbott, P.C. 3515 S. Tamarac, Suite 200 Denver, CO 80237 303-757-5000 303-689-9627 (facsimile) Abbott.teresa@gmail.com By: s/ Alexess Rea Special Assistant U.S. Attorney 1961 Stout Street, Suite 4169 Denver, CO 80214 303-844-7101 303-844-0770 (facsimile) Alexess.rea@ssa.gov Attorney for Plaintiff Attorneys for Defendant -4-

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