State Court Stipulation and [Proposed] Order (General Civil) - Oklahoma

STIPULATION AND [PROPOSED] ORDER

(Oklahoma District Court – General Civil Matters)

1. CAPTION

IN THE DISTRICT COURT OF [COUNTY] COUNTY
STATE OF OKLAHOMA

[PLAINTIFF NAME],
    Plaintiff,

v.                                                   Case No. [CASE NUMBER]
                                                     Judge [JUDGE NAME]
[DEFENDANT NAME],
    Defendant.

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

2. STIPULATION

The Parties stipulate and agree as follows:

1. Background.
   - A Scheduling Order was entered on [DATE].
   - [Summarize relevant deadlines and procedural posture].

2. Agreed Terms.
   a. [TERM 1: e.g., “Discovery shall close on [DATE], extending the current deadline by [NUMBER] days.”]
   b. [TERM 2: e.g., “Expert disclosures pursuant to 12 O.S. § 3226 shall be exchanged by [DATE].”]
   c. [TERM 3: e.g., “Dispositive motions shall be filed by [DATE], with hearings scheduled at the Court’s convenience.”]
   d. [Additional terms as needed].

3. Authority. This stipulation is submitted pursuant to 12 O.S. § 2006(B) and District Court Rule 5, and is supported by good cause because [JUSTIFICATION].

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

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

3. SIGNATURES

DATED: ____________

[LAW FIRM NAME]
By: ________________________________
    [ATTORNEY NAME]
    OBA No. [NUMBER]
    Counsel for [PLAINTIFF]

[SECOND LAW FIRM NAME]
By: ________________________________
    [ATTORNEY NAME]
    OBA No. [NUMBER]
    Counsel for [DEFENDANT]

4. [PROPOSED] ORDER

NOW on this ____ day of ______________, 20__, the Court having reviewed the Parties’ Stipulation and finding good cause, hereby 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 full force and effect.

____________________________________
JUDGE OF THE DISTRICT COURT

5. CERTIFICATE OF SERVICE

I certify that on [DATE], I served the foregoing Stipulation and [Proposed] Order upon all counsel of record via [E-FILING / EMAIL / U.S. MAIL] in accordance with 12 O.S. § 2005(B). Service was made to:

[NAME]
[ADDRESS / EMAIL]

__________________________________
[NAME OF DECLARANT]
OBA No. [NUMBER]

6. FILING & SERVICE CHECKLIST

• Reference Oklahoma authority. Cite 12 O.S. § 2006, § 2007, § 2016, § 2023, or District Court Rules governing the stipulation, and address any local administrative orders.
• Comply with e-filing or paper requirements. Use the Oklahoma Odyssey eFileOK system where mandated, select the proper document type, and submit a Word version of the proposed order if the judge requires editable format.
• Serve all parties per § 2005(B). Provide mail, hand delivery, or email service to parties not receiving electronic service and record the method within the certificate.