How can I create a proposed stipulation order for an upcoming post mediation status hearing?

You can attend the hearing and update the judge on the progress of the case. The judge may not be happy that the parties have not completed the mediation as apparently ordered by the court. The fact that one of the parties is still deposing witness is not necessarily a valid excuse since (1) there is no requirement that all discovery be completed prior to a mediation, and (2) the parties could have been more diligent and taken the depositions earlier. As an alternative you can file a stipulation and proposed order continuing the hearing but there is no guarantee that the court will sign such an order. I think there is a good chance it will not. The parties may have to go in ex parte and request more time to complete the mediation.

The reason why judges set a Post Mediation Status Conference is to have counsel or self-represented parties appear in court to report on the status and outcome of the mediation. Therefore, you should plan on attending the PMSC to update the court on the progress of the case. Alternatively, you might try filing a stipulation with proposed order continuing the PMSC hearing, but I agree with Attorney Lee that there is no guarantee that the court will sign such an order. There is no Judicial Council form for such stipulation.

The court wants to be updated on the status of the case. If depositions are continuing in a prompt manner, then the court should understand why the Mediation has not occurred. But you should have an agreed upon time line to inform the court as to the progress of the case.