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

STIPULATION AND [PROPOSED] ORDER

(Texas State Court – General Civil Matters)

1. CAPTION

CAUSE NO. [CASE NUMBER]

[PLAINTIFF NAME],                              §          IN THE ☐ JUDICIAL DISTRICT COURT
                                               §
       Plaintiff,                              §
                                               §          OF [COUNTY] COUNTY, TEXAS
v.                                             §
                                               §
[DEFENDANT NAME],                              §
       Defendant.                              §

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

2. STIPULATION

COMES NOW Plaintiff and Defendant (collectively, the “Parties”) and stipulate as follows:

1. Background. The Court entered a Docket Control/Scheduling Order on [DATE]. The current deadlines are:
   - Discovery cutoff: [DATE]
   - Expert designation deadlines: [DATES]
   - Dispositive motion deadline: [DATE]

2. Agreed Modifications.
   a. [TERM 1: e.g., “The discovery cutoff is extended to [DATE].”]
   b. [TERM 2: e.g., “Plaintiff shall designate experts by [DATE]; Defendant shall designate experts by [DATE].”]
   c. [TERM 3: e.g., “Dispositive motions shall be filed by [DATE] and set for submission/hearing on [DATE].”]
   d. [Additional terms such as mediation deadlines or pretrial filings.]

3. Good Cause & Authority. Pursuant to Tex. R. Civ. P. 11, 166, and 190, good cause exists for the modifications because [JUSTIFICATION]. The requested adjustments will not affect the trial date of [TRIAL DATE] (unless otherwise stated).

4. Reservation. Except as modified herein, the Docket Control/Scheduling Order remains in full force and effect.

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

3. SIGNATURES

AGREED:

[LAW FIRM NAME]
By: ________________________________
    [ATTORNEY NAME]
    State Bar No. [NUMBER]
    ATTORNEY FOR [PLAINTIFF]
Date: ___________

[SECOND LAW FIRM NAME]
By: ________________________________
    [ATTORNEY NAME]
    State Bar No. [NUMBER]
    ATTORNEY FOR [DEFENDANT]
Date: ___________

<!-- GUIDANCE: Include signatures for all parties. Electronic signatures (“/s/ Name”) are acceptable in eFileTexas filings under Tex. R. Civ. P. 21(f). -->

4. [PROPOSED] ORDER

ORDER APPROVING STIPULATION

On this day, the Court considered the Parties’ Stipulation. After review 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 Docket Control/Scheduling Order dated [DATE] remain in effect except as expressly modified herein.

SIGNED on ______________________, 20__.

____________________________________
JUDGE PRESIDING

5. CERTIFICATE OF SERVICE

I certify that on [DATE], a true and correct copy of the foregoing Stipulation and [Proposed] Order was served on all counsel of record via [E-SERVICE / EMAIL / CERTIFIED MAIL] in accordance with Tex. R. Civ. P. 21a.

[NAME]
State Bar No. [NUMBER]
Counsel for [PARTY]

6. FILING & SERVICE CHECKLIST

• Cite Texas authority. Reference Tex. R. Civ. P. 11, 166, 190, 191, or other applicable rules/statutes and address any docket control order provisions being modified.
• Follow eFileTexas protocols. File the stipulation and proposed order using the correct filing code, attach supporting documents, and upload a Word version of the order if required by the court or local rules.
• Serve per Tex. R. Civ. P. 21a. Ensure all parties receive service via electronic service, mail, or other permitted methods, and document the precise method in the certificate.