STIPULATION AND [PROPOSED] ORDER

(Ohio Court of Common Pleas – General Civil Matters)

[// GUIDANCE: Provide a brief good-cause statement. Reference the operative scheduling order and note whether the requested relief affects trial dates.]

1. CAPTION

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IN THE COURT OF COMMON PLEAS
[COUNTY] COUNTY, OHIO

[PLAINTIFF NAME], ) Case No. [CASE NUMBER]
)
Plaintiff, ) Judge [JUDGE NAME]
)
v. ) STIPULATION AND [PROPOSED] ORDER
)
[DEFENDANT NAME], )
Defendant. )

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

2. STIPULATION

The Parties, through their counsel, stipulate and agree as follows:

1. Background.
   - The Court entered a Scheduling Order on [DATE].
   - [Summarize pertinent deadlines and procedural posture].

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 reports pursuant to Civ.R. 26(E) shall be exchanged by [DATE].”]
   c. [TERM 3: e.g., “Dispositive motions under Civ.R. 56 shall be filed by [DATE].”]
   d. [Additional terms as needed].

3. Authority. This stipulation is submitted pursuant to Civ.R. 6(B) and 16(D), and is supported by good cause because [JUSTIFICATION].

4. Reservation. Except as expressly modified, the Scheduling Order remains in effect and all rights are preserved.

5. Request for Order. The Parties respectfully request that the Court adopt this stipulation as an order.

3. SIGNATURES

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Respectfully submitted,

[LAW FIRM NAME]
By: _____
[ATTORNEY NAME]
Ohio Bar No. [NUMBER]
Counsel for [PLAINTIFF]
Date: __

[SECOND LAW FIRM NAME]
By: _____
[ATTORNEY NAME]
Ohio Bar No. [NUMBER]
Counsel for [DEFENDANT]
Date: __

[// GUIDANCE: Include additional signatures for all parties. Electronic signatures (“/s/ Name”) are accepted in most Ohio e-filing systems pursuant to Sup.R. 45.]

4. [PROPOSED] ORDER

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Upon review of the foregoing Stipulation and for good cause shown, 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 full force and effect.

IT IS SO ORDERED.

Date: ____ _______
Judge [JUDGE NAME]
Court of Common Pleas
[// GUIDANCE: Include “Copies to: All Counsel of Record” if required by local practice.]

5. CERTIFICATE OF SERVICE

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I certify that on [DATE], the foregoing was filed via [E-Filing System / Clerk’s Office], which will serve notice upon all registered counsel in accordance with Civ.R. 5(B)(2). Copies were served on non-registered parties by [MAIL / EMAIL] as follows:

[NAME]
[ADDRESS / EMAIL]

[NAME OF DECLARANT]
Ohio Bar No. [NUMBER]
[// GUIDANCE: Update service description to reflect actual method.]

6. FILING & SERVICE CHECKLIST

• Cite Ohio authority. Reference Ohio Civ.R. 6(B), 16, 29, 41, or any pertinent local rules or scheduling orders authorizing the stipulation.
• Follow local e-filing procedures. File through the county’s e-filing portal (if available), select the proper document type, and provide an editable proposed order if required by the judge.
• Serve non-e-filing parties. Deliver service by mail or personal delivery to parties outside the electronic system and document compliance with Civ.R. 5(B).