STIPULATION AND [PROPOSED] ORDER

(New Mexico District Court – General Civil Matters)

[// GUIDANCE: Provide an explanation of good cause referencing the Scheduling Order. Address the impact on trial dates and ADR deadlines.]

1. CAPTION

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

Attorney for [PARTY NAME]

STATE OF NEW MEXICO
COUNTY OF [COUNTY]
[__] JUDICIAL DISTRICT COURT

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 relevant deadlines, pending motions, or upcoming settings].

2. Agreed Terms.
   a. [TERM 1: e.g., “The discovery deadline is extended to [DATE], with all discovery motions to be heard by [DATE].”]
   b. [TERM 2: e.g., “Expert disclosures pursuant to NMRA 1-026(B)(6) shall be served by [DATE].”]
   c. [TERM 3: e.g., “The dispositive motion deadline is extended to [DATE]; hearings will be set in coordination with the Court.”]
   d. [Additional terms as needed].

3. Authority. This stipulation is made pursuant to NMRA 1-006 and 1-016(B), and is supported by good cause because [JUSTIFICATION].

4. Reservation. Except as expressly modified, the Scheduling Order remains 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]
NM Bar No. [NUMBER]
Counsel for [PLAINTIFF]

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

[// GUIDANCE: Include additional counsel signatures. Electronic signatures (“/s/ Name”) are accepted in File & Serve filings.]

4. [PROPOSED] ORDER

text
The Court, having reviewed the 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.

SO ORDERED this _ day of _____, 20__.

Hon. [JUDGE NAME]
District Judge
[// GUIDANCE: Include the judge’s typed name beneath the signature line if requested by chambers.]

5. CERTIFICATE OF SERVICE

text
I certify that on [DATE], the foregoing was filed via New Mexico File & Serve, which provided electronic service to all registered counsel pursuant to NMRA 1-005. Copies were served by [MAIL / EMAIL] on any parties not registered:

[NAME]
[ADDRESS / EMAIL]

[NAME OF DECLARANT]
NM Bar No. [NUMBER]
[// GUIDANCE: Update service details to match actual delivery method.]

6. FILING & SERVICE CHECKLIST

• Cite New Mexico authority. Reference NMRA 1-006, 1-016, 1-029, 1-041, or other applicable rules and any case management order provisions that must be satisfied.
• Use File & Serve properly. Select the correct filing code, include supporting exhibits, and provide an editable proposed order if chambers requires a Word version.
• Serve non-File & Serve parties. Deliver mail or personal service to parties outside the system and document compliance with NMRA 1-005.