Lovato v. Colvin
Filing
12
Joint Case Management Plan for Social Security Cases. SS Plaintiffs Brief due by 6/23/2014. SS Defendants Brief due by 7/21/2014. SS Plaintiffs Reply Brief due by 8/5/2014 by Judge John L. Kane on 04/22/14. (jhawk, )
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. No. 1:13-cv-2839-AP
MANUEL LOVATO,
Plaintiff,
v.
CAROLYN 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
Telephone: (303) 534-1958
Facsimile: (303) 534-1949
Email: joe@RMDLG.com
For Defendant:
John F. Walsh
United States Attorney
J. Benedict García
Assistant United States Attorney
United States Attorney’s Office
Email: J.B.Garcia@usdoj.gov
James L. Burgess
Special Assistant United States Attorney
Social Security Administration, Region VIII
Office of the General Counsel
1961 Stout Street, Suite 4169
Denver, Colorado 80294-4003
Phone: (303) 844-1856
Facsimile: (303) 844-0770
Email: james.burgess@ssa.gov
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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 14, 2014
C.
4.
Date Complaint Was Filed:
October 17, 2013
Date Answer and Administrative Record Were Filed: April 14, 2014
STATEMENT REGARDING THE ADEQUACY OF THE RECORD
To the best of her knowledge, Plaintiff states that the record is complete and accurate.
To the best of her 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
The parties agreed to the following schedule:
A.
Plaintiff's Opening Brief Due:
June 23, 2014
B.
Defendant’s Response Brief Due:
July 21, 2014
C.
Plaintiff’s Reply Brief (If Any) Due:
August 5, 2014
1 The proposed briefing schedule departs from the ordinary briefing schedule by three weeks due to
Plaintiff’s counsel having several briefs due in June.
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9.
STATEMENTS REGARDING ORAL ARGUMENT
A.
Plaintiff does not request oral argument.
B.
10.
Plaintiff’s Statement:
Defendant’s Statement:
Defendant does not request oral argument.
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 22nd day of April, 2014.
BY THE COURT:
s/John L. Kane
U.S. DISTRICT COURT JUDGE
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APPROVED:
John F. Walsh
United States Attorney
By: s/ Joseph A. Whitcomb
Rocky Mountain Disability Law Group
1391 Speer Blvd., Suite 705
Denver, CO 80204
Telephone: (303) 534-1958
Facsimile: (303) 534-1949
Email: joe@RMDLG.com
By: s/ James Burgess
Special Assistant U.S. Attorney
1961 Stout St., Suite 4169
Denver, CO 80294-4003
Telephone: (303) 844-1856
Facsimile: 303-844-0770
Email: james.burgess@ssa.gov
Attorneys for Plaintiff
Attorneys for Defendant
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