Bertram v. Colvin

Filing 12

ORDER: Joint case management plan. SS Plaintiffs Brief due by 5/20/2014. SS Defendants Brief due by 6/19/2014. SS Plaintiffs Reply Brief due by 7/7/2014. by Judge John L. Kane on 4/10/2014. (trlee, )

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLORADO
Civil Action No. 14-cv-00031-AP
JAMIE L. BERTRAM,
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:

For Defendant:

Patrick C.H. Spencer, II
830 Tenderfoot Hill Road, Suite 320
Colorado Springs, CO 80906
[phone]
[phone] (fax)
[e-mail]

Jessica Milano
Special Assistant United States Attorney
Assistant Regional Counsel
Office of the General Counsel
Social Security Administration
1961 Stout St., Suite 4169
Denver, CO 80294-4003
[phone]
[phone] (fax)
[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).

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3.

DATES OF FILING OF RELEVANT PLEADINGS
A.

B.

Date Complaint Was Served on U.S. Attorney's Office: January 23, 2014

C.

4.

Date Complaint Was Filed: January 5, 2014

Date Answer and Administrative Record Were Filed: March 21, 2014

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 this case raises any unusual claims or
defenses.

7.

OTHER MATTERS

The parties have no other matters to bring to the attention of the Court. This case is not on
appeal from a decision issued on remand from this Court.

8.

BRIEFING SCHEDULE

Counsel for both parties conferred and agreed upon the following proposed briefing schedule:
A.

Plaintiff's Opening Brief Due: May 20, 2014

B.

Defendant’s Response Brief Due: June 19, 2014

C.

Plaintiff’s Reply Brief (If Any) Due: July 7, 2014

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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
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 10thday of April, 2014.
BY THE COURT:
s/John L. Kane

U.S. DISTRICT COURT JUDGE

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APPROVED:
s/ Patrick C.H. Spencer, II1
Patrick C.H. Spencer, II
830 Tenderfoot Hill Road, Suite 320
Colorado Springs, CO 80906
[phone]
[phone] (fax)
[e-mail]
Attorney for Plaintiff

JOHN F. WALSH
United States Attorney
J. BENEDICT GARCÍA
Assistant United States Attorney
United States Attorney's Office
District of Colorado

s/ Jessica Milano
Jessica Milano
Special Assistant United States Attorney
1961 Stout St., Suite 4169
Denver, CO 80294-4003
[phone]
[phone] (fax)
[e-mail]
Attorneys for Defendant

1

Signed by Jessica Milano with consent of Plaintiff’s counsel.

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