IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF COLORADO 

Civil Action No. 11-cv-02300-AP 

MICHAEL A. ZELLER, 

Plaintiff, 

v. 

MICHAEL J. ASTRUE, 

Commissioner of Social Security, 

Defendant. 

______________________________________________________________________________ 

JOINT CASE MANAGEMENT PLAN 

1. APPEARANCES OF COUNSEL 

For Plaintiff: 

KENNETH J. SHAKESHAFT 

Shakeshaft Law Firm 

1530 S. Tejon St. 

Colorado Springs, CO 80905 

Telephone: 719-635-5886 

office@shakeshaftlawfirm.com 

For Defendant: 

JOHN F. WALSH 

United States Attorney 

WILLIAM G. PHARO 

Assistant United States Attorney 

United States Attorney's Office 

District of Colorado 

ALEXESS REA 

Special Assistant United States Attorney 

Office of General Counsel 

Social Security Administration 

1001 Seventeenth Street 

Denver, CO 80202 

Telephone: 303-844-7101 

Alexess.rea@ssa.gov

Case 1:11-cv-02300-CMA Document 8 Filed 12/13/11 USDC Colorado Page 1 of 3
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: 09/01/11

B. Date Complaint Was Served on U.S. Attorney's Office: 09/19/11

C. Date Answer and Administrative Record Were Filed: 11/15/11

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. 

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 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 

A. Plaintiff's Opening Brief Due: 01/13/12 

B. Defendant's Response Brief Due: 02/13/12 

C. Plaintiff's Reply Brief (If Any) Due: 02/28/12 

 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. 

Case 1:11-cv-02300-CMA Document 8 Filed 12/13/11 USDC Colorado Page 2 of 3
 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 13th day of December, 2011. 

BY THE COURT: 

s/John L. Kane 

 U.S. DISTRICT COURT JUDGE 

APPROVED: UNITED STATES ATTORNEY 

s/ Kenneth J. Shakeshaft s/ Alexess Rea 

KENNETH J. SHAKESHAFT BY: ALEXESS REA 

Shakeshaft Law Firm Special Assistant United States Attorney 

1530 S. Tejon St. 1001 17th Street, Sixth Floor 

Colorado Springs, CO 80905 Denver, Colorado 80202 

Telephone: 719-635-5886 Telephone: (303) 844-7101 

office@shakeshaftlawfirm.com alexess.rea@ssa.gov 

Attorney for Plaintiff Attorney for Defendant 

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