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Guidelines for Concluding an Adversary Proceeding - Northern ...

Guidelines for Concluding an Adversary Proceeding - Northern ...

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EXHIBIT E<br />

UNITED STATES BANKRUPTCY COURT<br />

NORTHERN DISTRICT OF OKLAHOMA<br />

IN RE:<br />

____________________________,<br />

Debtor(s).<br />

Case No. _________-R<br />

Chapter ____<br />

____________________________,<br />

Plaintiff,<br />

v.<br />

Adv. No. _________-R<br />

____________________________,<br />

Defend<strong>an</strong>t.<br />

AGREED STIPULATION OF DISMISSAL<br />

[If applicable, (Subject to Reopening, without fee, <strong>for</strong><br />

purposes of entering judgment in the event of default)]<br />

Pursu<strong>an</strong>t to Federal Rule of Civil Procedure 41(a)(1)(ii), made applicable to adversary<br />

proceedings by Federal Rule of B<strong>an</strong>kruptcy Procedure 7041, Plaintiff _______________ (the “Plaintiff”)<br />

<strong>an</strong>d Defend<strong>an</strong>t _______________ (the “Defend<strong>an</strong>t”), being all parties that entered <strong>an</strong> appear<strong>an</strong>ce in the<br />

above-referenced adversary proceeding, hereby jointly <strong>an</strong>d mutually stipulate to the dismissal of the<br />

adversary proceeding [subject to reopening <strong>for</strong> purposes of entering judgment against the Defend<strong>an</strong>t in<br />

the event of default under the settlement agreement]. The parties have agreed that [insert terms of<br />

agreement, repayment terms, if <strong>an</strong>y, terms of default, etc.]<br />

Dated this ____ day of ______, 200___.<br />

_____________________________<br />

Attorney Name, OBA #__________<br />

[Address/Telephone/Fax/Email]<br />

ATTORNEY FOR PLAINTIFF<br />

_____________________________<br />

Attorney Name, OBA #__________<br />

[Address/Telephone/Fax/Email]<br />

ATTORNEY FOR DEFENDANT

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