STIPULATION AND [PROPOSED] ORDER

(Nebraska District Court – General Civil Matters)

[// GUIDANCE: Provide a concise explanation of good cause referencing the progression order. Identify deadlines being modified and confirm that the requested relief will not impact the trial term absent court approval.]

1. CAPTION

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

Attorney for [PARTY NAME]

IN THE DISTRICT COURT OF [COUNTY] COUNTY, NEBRASKA

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 Progression Order on [DATE].
   - [Summarize relevant deadlines and procedural history].

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 witness disclosures pursuant to Neb. Ct. R. Disc. § 6-326(b)(6) shall be served by [DATE].”]
   c. [TERM 3: e.g., “The dispositive motion deadline is extended to [DATE].”]
   d. [Additional terms as needed].

3. Authority. This stipulation is submitted pursuant to Neb. Ct. R. Pldg. §§ 6-1106(b) and 6-1116, and is supported by good cause because [JUSTIFICATION].

4. Reservation. Except as modified herein, all provisions of the Progression Order 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]
Neb. Bar No. [NUMBER]
Counsel for [PLAINTIFF]

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

[// GUIDANCE: Include additional counsel signatures. Electronic signatures (“/s/ Name”) are accepted in Nebraska eFiling.]

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 Progression Order dated [DATE] remain in effect.

DATED this _ day of _____, 20__.

BY THE COURT:

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

5. CERTIFICATE OF SERVICE

text
I certify that on [DATE], the foregoing was filed via the Nebraska Judicial Branch eFiling system, which provided service to all registered counsel. Copies were served by [MAIL / EMAIL] on any parties not registered:

[NAME]
[ADDRESS / EMAIL]

[NAME OF DECLARANT]
Neb. Bar No. [NUMBER]
[// GUIDANCE: Update service details to comply with Neb. Ct. R. Pldg. § 6-1105(b).]

6. FILING & SERVICE CHECKLIST

• Cite Nebraska authority. Reference Neb. Ct. R. Pldg. §§ 6-1106, 6-1116, 6-1129, or pertinent statutes supporting the stipulation, and confirm consistency with any local case progression order.
• Follow Nebraska eFiling standards. Use the correct document type, attach exhibits, and provide an editable proposed order if required by the judge or local rule.
• Serve outside the eFiling system. Mail or email documents to parties not registered for eFiling and document service in compliance with § 6-1105.