STIPULATION AND [PROPOSED] ORDER

(Louisiana District Court – General Civil Matters)

[// GUIDANCE: Provide sufficient factual background. Identify the Article(s) under which the relief is sought. For scheduling adjustments, reference the operative Scheduling Order and any judge-specific standing orders.]

1. CAPTION

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

Attorney for [PARTY NAME]

TWENTY-[NUMBER]TH JUDICIAL DISTRICT COURT
PARISH OF [PARISH], STATE OF LOUISIANA

NO. [CASE NUMBER] DIVISION “[DIVISION]”

[PLAINTIFF NAME],
Plaintiff,

VERSUS

[DEFENDANT NAME],
Defendant.

2. STIPULATION

NOW INTO COURT, through undersigned counsel, come Plaintiff and Defendant, who stipulate and agree as follows:

1. Background.
   - The Court issued a Scheduling Order on [DATE].
   - [Brief description of procedural posture].

2. Agreed Terms.
   a. [TERM 1: e.g., “All discovery deadlines are extended to [DATE], without affecting the current trial date.”]
   b. [TERM 2: e.g., “Expert reports pursuant to La. Code Civ. Proc. art. 1425(F) shall be exchanged by [DATE].”]
   c. [TERM 3: e.g., “The pre-trial conference set for [DATE] is continued to [DATE], subject to court approval.”]
   d. [Additional terms as needed].

3. Authority. This stipulation is submitted pursuant to La. Code Civ. Proc. arts. [CITE ARTICLES] and the Court’s Scheduling Order, and is supported by good cause because [JUSTIFICATION].

4. Reservation. Except as modified herein, all prior orders remain in effect and all rights are reserved.

5. Request for Order. The Parties respectfully request that the Court approve this stipulation and enter the accompanying order.

3. SIGNATURES

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Respectfully submitted:

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

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

[// GUIDANCE: Provide signature lines for all parties. Electronic signatures in the format “/s/ Name” are acceptable where permitted by local rules.]

4. [PROPOSED] ORDER

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CONSIDERING THE FOREGOING STIPULATION AND GOOD CAUSE SHOWN, IT IS ORDERED that:

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 dated [DATE] remain in full force and effect.

THUS DONE AND SIGNED at [CITY], Louisiana, this _ day of _____, 20__.

JUDGE, DIVISION “[DIVISION]”
[// GUIDANCE: Insert the judge’s typed name below the signature line if required.]

5. CERTIFICATE OF SERVICE

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I hereby certify that a copy of the foregoing was served on [DATE] by:

☐ E-service through the clerk’s electronic filing system to all counsel of record.
☐ U.S. Mail, postage prepaid, to: [NAME / ADDRESS]
☐ Facsimile or E-mail (with consent) to: [NAME / CONTACT]

[NAME OF DECLARANT]
La. Bar No. [NUMBER]
[// GUIDANCE: Modify to comply with La. Code Civ. Proc. arts. 1313 and 1314.]

6. FILING & SERVICE CHECKLIST

• Ground the stipulation in Louisiana law. Cite the relevant provisions of the Louisiana Code of Civil Procedure (e.g., arts. 1601, 1911, 1916, 1551, 1671) or local rules that permit the agreed relief.
• Observe parish filing protocols. File via the parish clerk’s electronic system or in paper form as required, ensure the proposed order is editable if chambers demands Word format, and pay any mandated filing fee.
• Comply with service articles. Serve parties consistent with La. Code Civ. Proc. arts. 1313–1314, noting any need for certified mail or personal service and documenting the method in the certificate.