STIPULATION AND [PROPOSED] ORDER

(Nevada District Court – General Civil Matters)

[// GUIDANCE: Provide the factual basis for good cause. If extending discovery beyond the 180-day limit, address NRCP 16(b)(4) and EDCR requirements, including the number of prior extensions.]

1. CAPTION

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

Attorney for [PARTY NAME]

DISTRICT COURT
[COUNTY] COUNTY, NEVADA

Case 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 a Scheduling Order on [DATE].
   - [Summarize discovery completed, outstanding tasks, and upcoming deadlines].

2. Stipulated Terms.
   a. [TERM 1: e.g., “Discovery cutoff is extended to [DATE].”]
   b. [TERM 2: e.g., “Expert disclosures pursuant to NRCP 16.1(a)(2) shall be served by [DATE]; rebuttal expert disclosures by [DATE].”]
   c. [TERM 3: e.g., “Dispositive motions must be filed by [DATE], with hearings to be set by the Court.”]
   d. [Additional terms such as ADR, pretrial conference adjustments].

3. Authority. This stipulation is made pursuant to NRCP 16(b)(4) and 29, and EDCR [RULE NUMBER], and is supported by good cause because [JUSTIFICATION].

4. Reservation. Except as modified, 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

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DATED: ______

[LAW FIRM NAME]
By: ________
[ATTORNEY NAME]
Nev. Bar No. [NUMBER]
Attorneys for [PLAINTIFF]

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

[// GUIDANCE: Include signature lines for all counsel. eFileNV accepts “/s/ Name” electronic signatures pursuant to NEFCR 11.]

4. [PROPOSED] ORDER

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Based upon the Parties’ Stipulation and good cause appearing, 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 effect.

DATED this _ day of _____, 20__.

DISTRICT COURT JUDGE
[// GUIDANCE: Insert the judge’s typed name beneath the signature line. Some departments require the inclusion of “Submitted by” lines.]

5. CERTIFICATE OF SERVICE

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I certify that on [DATE], I e-filed the foregoing via [eFileNV/Wiznet], which provided service on all registered counsel pursuant to NRCP 5(b). Copies were served by [MAIL / EMAIL] on the following non-registered parties:

[NAME]
[ADDRESS / EMAIL]

[NAME OF DECLARANT]
Nev. Bar No. [NUMBER]
[// GUIDANCE: Update service method to match actual practice.]

6. FILING & SERVICE CHECKLIST

• Cite Nevada authority. Reference the Nevada Rules of Civil Procedure that authorize the stipulation (e.g., NRCP 6(b), 16, 29, 41) and any local district court rules or administrative orders.
• File via eFileNV/Wiznet. Use the correct document type, attach exhibits, and upload a Word version of the proposed order if the department requires editable submissions.
• Serve non-registered parties. Provide service by mail or email to litigants outside the e-filing system and document compliance with NRCP 5(b).