IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLORADO

Civil Action No. 11-cv-02425-AP

GLORIANNE MERCADO,

Plaintiff,

v.

MICHAEL J. ASTRUE, Commissioner of Social Security,

Plaintiff.

______________________________________________________________________________

JOINT CASE MANAGEMENT PLAN FOR SOCIAL SECURITY CASES

______________________________________________________________________________

1. APPEARANCES OF COUNSEL

For Plaintiff: 

 Gordon W. Williams

143 Union Blvd., Suite 270

Lakewood, Colorado 80228

Telephone: 303-988-2841

Fax No. 303-988-0445

Email: gwilliamsefile@jeffcolaw.net

For Defendant:

JOHN F. WALSH

United States Attorney

WILLIAM G. PHARO

Assistant United States Attorney

United States Attorney's Office

District of Colorado

Debra J. Meachum

Special Assistant United States Attorney

10001 17th Street, Sixth Floor

Denver, Colorado 80202

Telephone: (303) 844-1570

debra.meachum@ssa.gov

Attorneys for Defendant

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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: 9/14/11.

B. Date Complaint Was Served on U.S. Attorney's Office: 9/19/11.

C. Date Answer and Administrative Record Were Filed: 11/17/11.

4. STATEMENT REGARDING THE ADEQUACY OF THE RECORD

To the best of their knowledge, the parties 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

To the best of their knowledge, the parties do not believe the case raises unusual claims

or defenses.

7. OTHER MATTERS

The parties have no other matters to bring to the attention of the court.

8. BRIEFING SCHEDULE

Counsel for the parties respectfully request that briefing commence more than 40 days

after filing this plan. Plaintiff's attorney has a significant number of Social Security hearings in

December and January, his office will be closed for remodeling for one week, and he has holiday

travel plans. In January and February, Defendant's attorney currently has eight briefs due, one

oral argument set in Colorado, a deposition set in California, and other pleadings and business

matters that arise in the regular course of business. She will also be out of the country on family

travel from February 13-23, 2012. 

A. Plaintiff's Opening Brief Due: 2/8/12

B. Defendant's Response Brief Due: 3/12/12

C. Plaintiff's Reply Brief (If Any) Due: 3/27/12

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.

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10. CONSENT TO EXERCISE OF JURISDICTION BY MAGISTRATE JUDGE

A. ( ) All parties have consented to the exercise of jurisdiction of a United States

Magistrate Judge.

B. (X) 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.

DATED this 8th day of December, 2011.

BY THE COURT:

s/John L. Kane _______ 

U.S. DISTRICT COURT JUDGE

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APPROVED:

For Plaintiff: 

s/Gordon W. Williams

Gordon W. Williams

143 Union Blvd., Suite 270

Lakewood, Colorado 80228

Telephone: 303-988-2841

Fax No. 303-988-0445

Email: gwilliamsefile@jeffcolaw.net

For Defendant:

JOHN F. WALSH

United States Attorney

WILLIAM G. PHARO

Assistant United States Attorney

United States Attorney's Office

District of Colorado

s/Debra J. Meachum

By: Debra J. Meachum

Special Assistant United States Attorney

Office of the General Counsel

Social Security Administration

1001 17th Street

Denver, Colorado 80202

(303) 844-1570

debra.meachum@ssa.gov

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