STIPULATION AND [PROPOSED] ORDER

(Montana District Court – General Civil Matters)

[// GUIDANCE: Provide sufficient factual support demonstrating diligence and good cause. If altering scheduling orders, reference the controlling Order Setting Deadlines and confirm that the requested changes will not impact the trial setting absent court approval.]

1. CAPTION

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

Attorney for [PARTY NAME]

MONTANA [__]TH JUDICIAL DISTRICT COURT
[COUNTY] COUNTY, STATE OF MONTANA

Cause No. [CASE NUMBER]
Dept. No. [DEPARTMENT]

[PLAINTIFF NAME],
Plaintiff,

v.

[DEFENDANT NAME],
Defendant.

2. STIPULATION

The Parties stipulate and agree as follows:

1. Background.
   - The Court entered an Order Setting Deadlines on [DATE].
   - [Summarize procedural status and deadlines affected].

2. Agreed Terms.
   a. [TERM 1: e.g., “Discovery shall close on [DATE], extending the current deadline by [NUMBER] days.”]
   b. [TERM 2: e.g., “Expert witness disclosures under Mont. R. Civ. P. 26(a)(2) shall be served by [DATE].”]
   c. [TERM 3: e.g., “The dispositive motion deadline is extended to [DATE].”]
   d. [Additional terms as necessary].

3. Authority. This stipulation is made under Mont. R. Civ. P. 6(b)(1) and 16(b)(4), and is supported by good cause because [JUSTIFICATION].

4. Reservation. Except as expressly modified, all other provisions of the Order Setting Deadlines remain in effect.

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

3. SIGNATURES

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DATED: ______

[LAW FIRM NAME]
By: ________
[ATTORNEY NAME]
Mont. Bar No. [NUMBER]
Counsel for [PLAINTIFF]

[SECOND LAW FIRM NAME]
By: ________
[ATTORNEY NAME]
Mont. Bar No. [NUMBER]
Counsel for [DEFENDANT]

[// GUIDANCE: Include additional signatures for all parties. Electronic signatures (“/s/ Name”) are accepted through the Montana e-filing system.]

4. [PROPOSED] ORDER

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Upon review of the Parties’ Stipulation and good cause appearing, IT IS 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 Order Setting Deadlines dated [DATE] remain in effect.

DATED this _ day of _____, 20__.

Hon. [JUDGE NAME]
District Court Judge, Dept. [DEPARTMENT]
[// GUIDANCE: Include the judge’s typed name and department number beneath the signature line if required.]

5. CERTIFICATE OF SERVICE

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I certify that on [DATE], the foregoing was filed via the Montana Courts e-filing system, which served registered counsel. Copies were served by [MAIL / EMAIL] on any parties not registered:

[NAME]
[ADDRESS / EMAIL]

[NAME OF DECLARANT]
Mont. Bar No. [NUMBER]
[// GUIDANCE: Update service details consistent with Mont. R. Civ. P. 5(b).]

6. FILING & SERVICE CHECKLIST

• Reference Montana authority. Cite the Montana Rules of Civil Procedure authorizing the stipulation (e.g., Rules 6(b), 16, 29, 41) and any local district court standing orders.
• File through the Montana Courts e-filing system. Use the proper filing type, attach supporting exhibits, and provide an editable proposed order if required by the judge.
• Serve non-e-file participants. Deliver service by mail or personal delivery to parties outside the e-filing system, documenting compliance with Mont. R. Civ. P. 5(b).