[COURT NAME]
[COUNTY], [STATE]

[PLAINTIFF NAME], )
Plaintiff, ) Case No. [CASE NUMBER]
v. )
[DEFENDANT NAME], )
Defendant. )

MOTION TO STAY PROCEEDINGS

NOTICE OF MOTION AND MOTION

PLEASE TAKE NOTICE that on [HEARING DATE] at [TIME], or as soon thereafter as counsel may be heard, [MOVING PARTY] will and hereby does move the Court for an order staying this action pending [ARBITRATION/APPEAL/RELATED ACTION].

MEMORANDUM OF POINTS AND AUTHORITIES

I. Introduction

A temporary stay will promote efficiency, avoid inconsistent rulings, and prevent unnecessary expense.

II. Background

• Basis for stay: [ARBITRATION AGREEMENT/APPEAL/RELATED CASE]
• Status of related matter: [STATUS]
• Anticipated duration: [TIMEFRAME]

III. Legal Standard

Courts may stay proceedings to control their dockets and in the interest of justice. Relevant factors include potential hardship, judicial economy, and prejudice to the non-moving party.

IV. Argument

A. A stay will promote judicial economy.
[Explain overlap and efficiencies.]

B. A stay will prevent prejudice and inconsistent rulings.
[Explain risk of conflicting outcomes.]

C. Any prejudice to [OPPOSING PARTY] is minimal and can be mitigated.
[Address interim relief or status reports.]

V. Requested Relief

[MOVING PARTY] respectfully requests that the Court:
1. Stay this action until [TRIGGERING EVENT].
2. Require status reports every [NUMBER] days.
3. Grant any other relief the Court deems just.

CONCLUSION

For the foregoing reasons, the Court should grant the motion to stay proceedings.

Respectfully submitted,

text
Dated: [DATE]

______________________________
[ATTORNEY NAME]
[LAW FIRM]
[ADDRESS]
[PHONE]
[EMAIL]
Attorney for [MOVING PARTY]

CERTIFICATE OF SERVICE

I certify that on [DATE], I served the foregoing Motion to Stay Proceedings on all counsel of record via [METHOD OF SERVICE].

text
______________________________
[ATTORNEY NAME]

[PROPOSED] ORDER

The Court, having considered the Motion to Stay Proceedings, ORDERS as follows:
1. This action is stayed pending [TRIGGERING EVENT].
2. The parties shall file joint status reports every [NUMBER] days.

IT IS SO ORDERED.

Dated: [DATE]

__________________________________
[JUDGE NAME]
[STATE] Judge