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 IN THE UNITED STATES DISTRICT COURT 

 FOR THE DISTRICT OF COLORADO 

Civil Action No. 11-cv-01933-AP 

Lisa Patel 

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: 

Kristina J. Vasold, Esq. JOHN F. WALSH 

The Sawaya Law Firm, P.C. United States Attorney 

1600 Odgen Street 

Denver, CO 80218 WILLIAM G. PHARO 

Telephone (303) 551-7701 Assistant United States Attorney 

E-mail: kvasold@sawayalaw.com United States Attorney’s Office 

District of Colorado 

William.Pharo@usdoj.gov 

ALEXESS REA 

Special Assistant United States Attorney 

Office of the General Counsel 

Social Security Administration 

1001 Seventeenth Street 

Denver, CO 80202 

Telephone:(303) 844-7101 

Alexess.rea@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. Date Complaint Was Filed: July 25, 2011 

B. Date Complaint Was Served on U.S. Attorney’s Office: August 8, 2011 

C. Date Answer and Administrative Record Were Filed: October 4, 2011 

4. STATEMENT REGARDING THE ADEQUACY OF THE RECORD

The parties, to the best of their knowledge, state that the administrative record is complete and 

accurate. However, the Plaintiff reserves the right to supplement the record if necessary at the time 

of the Opening Brief. 

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, to the best of their knowledge, do not believe this case raises unusual claims or 

defenses. 

7. OTHER MATTERS

There are no other matters anticipated. 

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8. BRIEFING SCHEDULE

Counsel for both parties agree to the following proposed briefing schedule: 

A. Plaintiff’s Opening Brief Due: November 30, 2011

B. Defendant’s Response Brief Due: December 30, 2011 

C. Plaintiff’s Reply Brief (If Any) Due: January 13, 2012 

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

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. 

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DATED this 27th day of October, 2011. 

BY THE COURT: 

s/John L. Kane _____ 

U.S. DISTRICT COURT JUDGE 

APPROVED: 

s/Kristina J. Vasold 

The Sawaya Law Firm, P.C. 

1600 Odgen Street 

Denver, CO 80218 

Telephone (303) 551-7701 

E-mail: kvasold@sawayalaw.com 

Attorney for Plaintiff 

JOHN F. WALSH 

 United States Attorney 

 WILLIAM G. PHARO 

 Assistant United States Attorney 

 United States Attorney=s Office 

 District of Colorado 

 William.Pharo@usdoj.gov

By: s/Alexess Rea 

 Alexess Rea 

 Special Assistant United States Attorney 

 1001 Seventeenth Street 

 Denver, Colorado 80202 

 Telephone: (303) 844-7101 

 Alexess.rea@ssa.gov 

 Attorneys for Defendant. 

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