Opinion
Civil Action No. 12-cv-02932-AP
03-01-2013
For Plaintiff: Joseph A. Whitcomb Rocky Mountain Disability Law Group For Defendant: Meghan Frei Berglind Special Assistant U.S. Attorney Office of the General Counsel Social Security Administration
JOINT CASE MANAGEMENT PLAN
1. APPEARANCES OF COUNSEL:
For Plaintiff:
Joseph A. Whitcomb
Rocky Mountain Disability Law Group
For Defendant:
Meghan Frei Berglind
Special Assistant U.S. Attorney
Office of the General Counsel
Social Security Administration
2. STATEMENT OF LEGAL BASIS FOR SUBJECT MATTER JURISDICTION
This Court has jurisdiction based on Social Security Act § 205(g), 42 U.S.C. § 405(g)(2006).
3. DATES OF FILING RELEVANT PLEADINGS
A. Date Complaint Was Filed: November 7, 2012
B. Date Complaint Was Served on the U.S. Attorney's Office: December 17, 2012
C. Date Answer Was Filed: February 11, 2013
D. Date Administrative Record Was Filed: February 11, 2013
4. STATEMENT REGARDING THE ADEQUACY OF THE RECORD
To the best of their knowledge, the parties believe the administrative record is complete and accurate.
5. STATEMENT REGARDING ADDITIONAL EVIDENCE
The parties do not intend to submit additional evidence.
6. STATEMENT REGARDING WHETHER THIS CASE RAISES UNUSUAL CLAIMS OR DEFENSES
The parties do not believe this case raises any unusual claims or defenses.
7. OTHER MATTERS
This case is not an appeal from a decision issued on remand. The parties have no other matters to bring to the attention of the Court.
8. BRIEFING SCHEDULE
A. Plaintiff's Opening Brief Due: April 8, 2013
B. Defendant's Response Brief Due: May 8, 2013
C. Plaintiff's Reply Brief (If Any) Due: May 23, 2013
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
The parties do not consent to the exercise of jurisdiction by a magistrate judge.
11. AMENDMENTS TO JOINT CASE MANAGEMENT PLAN
Parties filing motions for extensions of time or continuances must comply with D.C.COLO.LCivR 6.1(E) 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 joint case management plan may be altered or amended only upon a showing of good cause.
BY THE COURT:
John L. Kane
U.S. District Court Judge
APPROVED: Meghan Frei Berglind on behalf of
JOSEPH A. WHITCOMB
Rocky Mountain Disability Law Group
1391 Speer Blvd., Suite 705
Denver, CO 80204
Telephone: (303) 534-1954
joe@RMDLG.com
Attorney for Plaintiff
JOHN F. WALSH
United States Attorney
J. BENEDICT GARCÍA
Assistant United States Attorney
United States Attorney's Office
District of Colorado
________________________
MEGHAN FREI BERGLIND
Special Assistant United States Attorney
Office of the General Counsel
Social Security Administration
1001 17th Street
Denver, CO 80202
Telephone: (303) 844-2544 meghan.berglind@ssa.gov
Attorneys for Defendant