Gilbert v. Social Security

Stip. to Extend Time & Prop. Order 	1 	Case No. 3:25-cv-07397-TSH
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CRAIG H. MISSAKIAN (CABN 125202)
United States Attorney
MATHEW W. PILE (WSBA 32245)
Head of Program Litigation 1
ERIN HIGHLAND (GA 153550)
Special Assistant United States Attorney
Program Litigation 1
Law and Policy
Social Security Administration
6401 Security Boulevard
Baltimore, MD 21235
(206) 615-2495
erin.highland@ssa.gov
Attorneys for Defendant
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION
CHRISTOPHER W. GILBERT,
Plaintiff,
vs.
COMMISSIONER OF SOCIAL SECURITY,
Defendant.
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Case No. 3:25-cv-07397-TSH
STIPULATION AND [PROPOSED]
ORDER FOR AN EXTENSION OF TIME
IT IS HEREBY STIPULATED, by and between the parties through their respective
counsel of record, with the Court’s approval, that Defendant shall have a 30-day extension of
time, from February 10, 2026, to March 12, 2026, to respond to Plaintiff’s opening brief.
This is Defendant’s first request for an extension of time and good cause exists for this
extension. Upon review of Plaintiff’s brief and the transcript, I require more time to consult with
my client and possibly Plaintiff regarding settlement options in this case and to file a responsive
brief absent settlement. I also have 10 district court briefs due between February 2, 2026 and
Case 3:25-cv-07397-TSH Document 22 Filed 02/04/26 Page 1 of 3

Stip. to Extend Time & Prop. Order 	2 	Case No. 3:25-cv-07397-TSH
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February 19, 2026. In addition, I have planned leave for February 5, 2026 and February 9, 2026.
Defendant’s counsel is also a part-time attorney and does not work a 40-hour week. Thus,
counsel needs additional time to consult with the client.
Defendant’s counsel will endeavor to complete these tasks as soon as possible. This
request is made in good faith and with no intention to unduly delay the proceedings, and counsel
apologizes for any inconvenience.
Respectfully submitted,
Dated: February 4, 2026 	/s/ David J. Linden
DAVID J. LINDEN
(*as authorized via email)
Attorney for Plaintiff
Dated: February 4, 2026 	CRAIG H. MISSAKIAN
United States Attorney
MATHEW W. PILE
Head of Program Litigation 1
By: s/ Erin Highland
Erin Highland
Special Assistant United States Attorney
Program Litigation 1 | Law and Policy
Attorneys for Defendant
In accordance with Civil Local Rule 5-1(i)(3), I, Erin Highland, attest that I have
obtained concurrence in the filing of this document from all other signatories listed here.
ORDER
Pursuant to stipulation, IT IS SO ORDERED.
Dated: February 4, 2026 __________________________________
THE HONORABLE THOMAS S. HIXSON
Case 3:25-cv-07397-TSH Document 22 Filed 02/04/26 Page 2 of 3

Stip. to Extend Time & Prop. Order 	3 	Case No. 3:25-cv-07397-TSH
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United States Magistrate Judge
Case 3:25-cv-07397-TSH Document 22 Filed 02/04/26 Page 3 of 3