STIPULATION AND [PROPOSED] ORDER

(Kentucky Circuit Court – General Civil Matters)

[// GUIDANCE: Provide sufficient background showing good cause. If modifying scheduling deadlines, reference the operative Pretrial/Scheduling Order and note compliance with local administrative procedures.]

1. CAPTION

text
[ATTORNEY OR SELF-REPRESENTED PARTY]
Name: [NAME] (KY Bar No. [NUMBER])
Firm: [LAW FIRM NAME]
Address: [STREET ADDRESS]
City, State ZIP: [CITY], Kentucky [ZIP]
Telephone: [TEL] | Facsimile: [FAX]
E-Mail: [EMAIL]

Attorney for [PARTY NAME]

COMMONWEALTH OF KENTUCKY
[COUNTY] CIRCUIT COURT
CIVIL ACTION NO. [CASE NUMBER]

[PLAINTIFF NAME],
Plaintiff,

v.

[DEFENDANT NAME],
Defendant.

2. STIPULATION

The Parties stipulate and agree as follows:

1. Background.
   - A Scheduling Order was entered on [DATE].
   - [Summarize relevant deadlines or proceedings].

2. Agreed Terms.
   a. [TERM 1: e.g., “All discovery shall be completed by [DATE], extending the current deadline by [NUMBER] days.”]
   b. [TERM 2: e.g., “Expert disclosures pursuant to CR 26.02(4) shall be served by [DATE].”]
   c. [TERM 3: e.g., “The final pretrial conference set for [DATE] is continued to [DATE], subject to court availability.”]
   d. [Additional terms as needed].

3. Authority. This stipulation is made pursuant to CR [CITE RULES] and the Court’s Scheduling Order ¶ [NUMBER], and good cause exists because [JUSTIFICATION].

4. Reservation. Except as stated herein, all prior orders remain in effect.

5. Request for Order. The Parties jointly request that the Court approve this stipulation and enter the proposed order below.

3. SIGNATURES

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AGREED BY:

[LAW FIRM NAME]
By: _____
[ATTORNEY NAME]
KY Bar No. [NUMBER]
Counsel for [PLAINTIFF]
Date: __

[SECOND LAW FIRM NAME]
By: _____
[ATTORNEY NAME]
KY Bar No. [NUMBER]
Counsel for [DEFENDANT]
Date: __

[// GUIDANCE: Include signatures for all counsel of record. Electronic signatures “/s/ Name” are accepted in KYeCourts.]

4. [PROPOSED] ORDER

text
The foregoing Stipulation having been reviewed and the Court being otherwise sufficiently advised, IT IS HEREBY ORDERED:

1. The Stipulation is APPROVED and incorporated herein.
2. [ORDERED TERM 1].
3. [ORDERED TERM 2].
4. [ORDERED TERM 3 / ADDITIONAL RELIEF].

All other provisions of the Scheduling Order entered [DATE] remain in effect.

Entered this _ day of _____, 20__.

Hon. [JUDGE NAME]
Judge, [COUNTY] Circuit Court
[// GUIDANCE: Add the judge’s typed name and distribution list if required by local practice.]

5. CERTIFICATE OF SERVICE

text
This is to certify that on [DATE], the foregoing was electronically filed via KYeCourts, which served all registered counsel of record. Copies were served by [MAIL / EMAIL] on the following parties not registered for e-service:

[NAME]
[ADDRESS / EMAIL]

[NAME OF DECLARANT]
KY Bar No. [NUMBER]
[// GUIDANCE: Update service information to match actual delivery method consistent with CR 5.]

6. FILING & SERVICE CHECKLIST

• Cite Kentucky authority. Reference the Kentucky Rules of Civil Procedure that authorize the stipulation (e.g., CR 6.02, 16, 29, 41) and include any applicable local rules or administrative orders.
• File through KYeCourts. Choose the appropriate filing code, attach supporting documents, and provide a Word version of the proposed order if chambers requires editable submissions.
• Serve non-e-filing parties. Deliver service by mail or personal delivery to litigants not registered with KYeCourts and describe the method in compliance with CR 5.02.