STIPULATION AND [PROPOSED] ORDER

(North Dakota District Court – General Civil Matters)

[// GUIDANCE: Provide sufficient background describing diligence and good cause. If the case is subject to the expedited civil action program (Rule 36), ensure compliance with that schedule.]

1. CAPTION

text
[ATTORNEY OR SELF-REPRESENTED PARTY]
Name: [NAME] (ND Bar ID [NUMBER])
Firm: [LAW FIRM NAME]
Address: [STREET ADDRESS]
City, State ZIP: [CITY], North Dakota [ZIP]
Telephone: [TEL] | Facsimile: [FAX]
E-Mail: [EMAIL]

Attorney for [PARTY NAME]

STATE OF NORTH DAKOTA
IN DISTRICT COURT
[___] JUDICIAL DISTRICT
COUNTY OF [COUNTY]

Case No. [CASE NUMBER]

[PLAINTIFF NAME],
Plaintiff,

v.

[DEFENDANT NAME],
Defendant.

2. STIPULATION

The Parties stipulate and agree as follows:

1. Background.
   - The Court entered a Scheduling Order on [DATE].
   - [Summarize key deadlines or proceedings impacted].

2. Agreed Terms.
   a. [TERM 1: e.g., “Discovery shall be completed by [DATE], extending the current deadline by [NUMBER] days.”]
   b. [TERM 2: e.g., “Expert disclosures under N.D.R.Civ.P. 26(b)(4) 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 pursuant to N.D.R.Civ.P. 6(b) and 16(b)(4), and is supported by good cause because [JUSTIFICATION].

4. Reservation. Except as expressly modified herein, all provisions of the Scheduling Order remain in effect.

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

3. SIGNATURES

text
DATED: ______

[LAW FIRM NAME]
By: ________
[ATTORNEY NAME]
ND Bar ID [NUMBER]
Counsel for [PLAINTIFF]

[SECOND LAW FIRM NAME]
By: ________
[ATTORNEY NAME]
ND Bar ID [NUMBER]
Counsel for [DEFENDANT]

[// GUIDANCE: Include additional counsel signatures. Electronic signatures (“/s/ Name”) are accepted via Odyssey.]

4. [PROPOSED] ORDER

text
The Court, having reviewed the Parties’ Stipulation and finding good cause, ORDERS:

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 effect.

Dated this _ day of _____, 20__.

Judge of the District Court
[// GUIDANCE: Add the judge’s printed name beneath the signature if required by local practice.]

5. CERTIFICATE OF SERVICE

text
I certify that on [DATE], the foregoing was filed via Odyssey, which served all registered users. Copies were served by [MAIL / EMAIL] on any parties not registered with the system:

[NAME]
[ADDRESS / EMAIL]

[NAME OF DECLARANT]
ND Bar ID [NUMBER]
[// GUIDANCE: Update service details to comply with N.D.R.Civ.P. 5(b).]

6. FILING & SERVICE CHECKLIST

• Cite North Dakota authority. Reference N.D.R.Civ.P. 6(b), 16, 29, 41, or other applicable rules supporting the stipulation and acknowledge any administrative orders for the judicial district.
• Follow Odyssey File & Serve requirements. Select the correct filing code, attach supporting materials, and provide a Word version of the proposed order if directed by chambers.
• Serve non-Odyssey participants. Mail or email documents to parties not registered for Odyssey and describe the method consistent with N.D.R.Civ.P. 5(b).