1 

 IN THE UNITED STATES DISTRICT COURT 

 FOR THE DISTRICT OF COLORADO 

Civil Action No. 11-cv-02240-JLK 

DOLORES E. TAFOYA, 

Plaintiff, 

v. 

MICHAEL J. ASTRUE, 

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: 

Alan M. Agee John F. Walsh 

512 S. 8th Street United States Attorney 

Colorado Springs, CO 80905 

(719) 473-1515 Kevin T. Traskos 

ageealanmpc@qwestoffice.net Deputy Civil Chief 

United States Attorney’s Office 

District of Colorado 

William G. Pharo 

United States Attorney Office 

District of Colorado 

Michael Howard 

Special Assistant United States Attorney 

David Blower 

Special Assistant United States Attorney 

Office of the General Counsel 

Social Security Administration 

1001 Seventeenth Street 

Denver, CO 80202 

Telephone:(303) 844-1571 

David.blower@ssa.gov

Case 1:11-cv-02240-JLK Document 9 Filed 12/06/11 USDC Colorado Page 1 of 4
2 

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. Date Complaint Was Filed: August 25, 2011 

B. Date Complaint Was Served on U.S. Attorney=s Office: August 31, 2011 

C. Date Answer and Administrative Record Were Filed: November 15, 2011 

4. STATEMENT REGARDING THE ADEQUACY OF THE RECORD

Plaintiff's counsel states that the administrative record may be missing records that have 

previously been submitted to the Appeals Council. Plaintiff intends to file a motion to 

supplement the record for any missing medical records. Otherwise the administrative record is 

complete. 

Defendant's counsel states, to the best of his knowledge, that the administrative record is 

complete. 

5. STATEMENT REGARDING ADDITIONAL EVIDENCE

Plaintiff's counsel states that the administrative record may be missing records that have 

previously been submitted to the Appeals Council. Plaintiff intends to file a motion to 

supplement the record for any missing medical records. Otherwise the administrative record is 

complete. 

Defendant does not intend 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 unusual claims or 

defenses. 

Case 1:11-cv-02240-JLK Document 9 Filed 12/06/11 USDC Colorado Page 2 of 4
3 

7. OTHER MATTERS

There are no other matters anticipated. 

8. PROPOSED BRIEFING SCHEDULE

Parties agree to the following proposed briefing schedule: 

A. Plaintiffs Opening Brief Due: January 17, 2012

B. Defendant=s Response Brief Due: February 16, 2012 

C. Plaintiffs Reply Brief (If Any) Due: March 2, 2012 

9. STATEMENTS REGARDING ORAL ARGUMENT 

A. Plaintiffs Statement: Plaintiff requests oral argument. 

B. Defendant=s Statement: Defendant does not request oral argument 

10. 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. OTHER MATTERS

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. 

12. AMENDMENTS TO JOINT CASE MANAGEMENT PLAN

The parties agree that the Joint Case Management Plan may be altered or amended only upon a 

showing of good cause. 

Case 1:11-cv-02240-JLK Document 9 Filed 12/06/11 USDC Colorado Page 3 of 4
4 

 

DATED this 6th day of December, 2011. 

BY THE COURT: 

s/John L. Kane ______________ 

SENIOR U.S. DISTRICT JUDGE 

APPROVED: 

/s/ Alan M. Agee 

Alan M. Agee 

512 S. 8th Street 

Colorado Springs, CO 80905 

(719) 473-1515 

ageealanmpc@qwestoffice.net

Attorney for Plaintiff 

JOHN F. WALSH 

United States Attorney 

KEVIN T. TRASKOS 

Civil Chief 

WILLIAM G. PHARO 

Assistant United States Attorney 

United States Attorney=s Office 

District of Colorado 

William.Pharo@usdoj.gov

Michael Howard 

Special Assistant United States Attorney 

/s/ David I. Blower 

David Blower 

Special Assistant United States Attorney 

1001 Seventeenth Street 

Denver, Colorado 80202 

Telephone: (303) 844-1571 

David.blower@ssa.gov 

Attorneys for Defendant. 

Case 1:11-cv-02240-JLK Document 9 Filed 12/06/11 USDC Colorado Page 4 of 4