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JOINT STIPULATION AND ORDER TO CONTINUE DATES 

(CASE NO. CV 2:04-01750 FCD KJM) 1239519.1

HANSON BRIDGETT MARCUS VLAHOS & RUDY, LLP 

JERROLD C. SCHAEFER - 39374 

KURT A. FRANKLIN - 172715 

PAUL B. MELLO – 179755 

DOROTHY S. LIU - 196369 

425 Market Street, 26th Floor 

San Francisco, CA 94105 

Telephone: (415) 777-3200 

Facsimile: (415) 541-9366 

jschaefer@hansonbridgett.com

BILL LOCKYER 

Attorney General of the State of California 

JAMES M. HUMES 

Chief Assistant Attorney General 

FRANCES T. GRUNDER 

Senior Assistant Attorney General 

ROCHELLE C. EAST 

Supervising Deputy Attorney General 

JAY C. RUSSELL, State Bar No. 122626 

Deputy Attorney General 

455 Golden Gate Avenue, Suite 11000 

San Francisco, CA 94102-7004 

Telephone: (415) 703-5717 

Facsimile: (415) 703-5843 

jay.russell@doj.ca.gov

Attorneys for Defendants California Department of Corrections 

and Rehabilitation, Roderick Q. Hickman, Jeanne S. Woodford, 

Thomas Felker, Mark Shepherd, and Thomas L. Carey 

UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF CALIFORNIA 

MITCHELL J. KLEMASKE, 

Plaintiff, on behalf of himself 

and others similarly situated, 

v. 

CALIFORNIA DEPARTMENT OF 

CORRECTIONS AND 

REHABILITATION, et al., 

Defendants. 

No. 2:04-cv-01750-FCD-KJM 

 CLASS ACTION 

JOINT STIPULATION and ORDER TO 

CONTINUE DATES FOR (1) FILING 

JOINT STATUS REPORT, AND (2) 

EXCHANGING RULE 26 INITIAL 

DISCLOSURES 

Case 2:04-cv-01750-LKK-JFM Document 43 Filed 03/02/06 Page 1 of 3
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- 2 - 

JOINT STIPULATION AND ORDER TO CONTINUE DATES 

(CASE NO. CV 2:04-01750 FCD KJM) 1239519.1

Defendants California Department of Corrections and Rehabilitation (CDCR), Roderick 

Q. Hickman, Jeanne S. Woodford (improperly named in Plaintiff’s First Amended Complaint as 

Jeanne S. Woodward), Thomas Felker, Mark Shepherd and Thomas L. Carey (collectively the 

"Defendants"), and Plaintiff Mitchell J. Klemaske ("Plaintiff"), by and through their respective 

attorneys, hereby stipulate as follows: 

WHEREAS no Case Management Conference or Joint Status Conference date has been 

set in this matter; 

WHEREAS a Joint Status Report is currently due to be filed with the Court on Monday, 

March 6, 2006; 

WHEREAS this matter is filed as a putative class action, and the issues and factual 

allegations are potentially complex; 

WHEREAS counsel for defendant, Hanson Bridgett Marcus Vlahos & Rudy, has newly 

substituted into this matter; 

WHEREAS Defendants just recently filed an answer to the complaint, on February 17, 

2006; 

WHEREAS the parties require an extension of time to allow sufficient time to evaluate 

both Plaintiff's claims and Defendants' defenses, and to meaningfully discuss (1) Rule 26 initial 

disclosures, (2) anticipated discovery and scheduling, (3) anticipated motions, (4) purported 

related cases, (5) legal and factual issues, (6) issues related to the putative class, (7) claimed relief 

sought by Plaintiff, and (8) prospects for negotiating a mutually agreeable resolution; 

WHEREAS the parties have discussed the benefit of extending the time to file a Joint 

Status Report and Rule 26 initial disclosures, and believe such an extension will both help in the 

administration of this case and save judicial resources; 

WHEREAS the parties stipulate that the time to file a Joint Status Report be extended to 

March 27, 2006; and 

WHEREAS the parties stipulate that the time to exchange Rule 26 initial disclosures be 

extended to March 27, 2006. 

/ / / 

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JOINT STIPULATION AND ORDER TO CONTINUE DATES 

(CASE NO. CV 2:04-01750 FCD KJM) 1239519.1

Plaintiffs and Defendants hereby request the Court to approve this stipulation to continue 

the dates to file the Joint Status Report and exchange Rule 26 initial disclosures in accordance 

with the terms of this Stipulation. 

DATED: March 1, 2006 HANSON, BRIDGETT, MARCUS, 

VLAHOS & RUDY, LLP 

By: /s/ Kurt A. Franklin 

JERROLD C. SCHAEFER 

KURT A. FRANKLIN 

PAUL B. MELLO 

DOROTHY S. LIU 

Attorneys for Defendants 

CALIFORNIA DEPARTMENT OF 

CORRECTIONS AND 

REHABILITATION 

Dated: March 1, 2006 

The Legal Aid Society-Employment 

Law Center 

/s/ Claudia Center 

By: (as authorized on 3/1/06)_____

CLAUDIA CENTER 

Attorneys for Plaintiff 

Mitchell J. Klemaske 

GOOD CAUSE HAVING BEEN SHOWN, IT IS ORDERED. 

Dated: March 2, 2006 /s/ Frank C. Damrell Jr. 

 FRANK C. DAMRELL JR. 

 United States District Court, Eastern District 

Case 2:04-cv-01750-LKK-JFM Document 43 Filed 03/02/06 Page 3 of 3