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

STIPULATION AND [PROPOSED] ORDER

(Colorado District Court – General Civil Matters)

1. CAPTION

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

Attorney for [PARTY NAME]

DISTRICT COURT, [COUNTY] COUNTY, COLORADO
Court Address: [COURTHOUSE ADDRESS]

Plaintiff: [PLAINTIFF NAME],

v.

Defendant: [DEFENDANT NAME].

▲ COURT USE ONLY ▲

Case Number: [CASE NUMBER]
Division/Courtroom: [DIVISION]

2. STIPULATION

The Parties, through undersigned counsel, state the following stipulation for the Court’s consideration:

1. Background and Procedural Status.
   - [Summarize relevant orders, deadlines, or motions].
   - [Identify the current trial/setting information].

2. Agreed Terms.
   a. [TERM 1: e.g., “The deadline for completion of written discovery is extended to [DATE], without altering the current trial date.”]
   b. [TERM 2: e.g., “Expert disclosures shall be exchanged pursuant to C.R.C.P. 26(a)(2) on [DATE], with rebuttal disclosures due [DATE].”]
   c. [TERM 3: e.g., “The dispositive motion deadline is extended to [DATE].”]
   d. [Add additional terms as necessary].

3. Good Cause and Authority. This stipulation is submitted pursuant to C.R.C.P. [CITE RULE] and C.R.C.P. 121 § 1-15(8) (motions by stipulation). Good cause exists because [STATE BASIS].

4. Reservation of Rights. All other deadlines and provisions of the existing Case Management Order remain in effect, and the Parties reserve all claims and defenses.

5. Request for Order. The Parties jointly request entry of the accompanying order adopting these terms pursuant to C.R.C.P. 58(a).

3. SIGNATURES

Respectfully submitted this ___ day of ____________, 20__.

[LAW FIRM NAME]
By: ________________________________
    [ATTORNEY NAME]
    Attorney for [PLAINTIFF]

[SECOND LAW FIRM NAME]
By: ________________________________
    [ATTORNEY NAME]
    Attorney for [DEFENDANT]

4. [PROPOSED] ORDER

The Court, having reviewed the Parties’ Stipulation and being otherwise fully advised, 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 Case Management Order dated [DATE] remain in effect unless expressly modified above.

DATED: _______________________

BY THE COURT:

____________________________________
[JUDGE NAME]
District Court Judge

5. CERTIFICATE OF SERVICE

I certify that on [DATE], the foregoing Stipulation and [Proposed] Order was filed via Colorado Courts E-Filing, which will send notice to all counsel of record. A copy was served by [MAIL / EMAIL / HAND DELIVERY] on the following party not registered with CCE:

[NAME]
[ADDRESS / EMAIL]

__________________________________
[NAME OF DECLARANT]

6. FILING & SERVICE CHECKLIST

• Reference controlling rules. Identify the Colorado Rules of Civil Procedure authorizing the stipulation (e.g., Rules 6(b), 16, 29, 41) and cite any Chief Judge Directives or local rules that govern scheduling modifications.
• Observe CCE/eFileColorado standards. Use the proper document codes when filing through Colorado Courts E-Filing, attach exhibits as required, and upload an editable Word version of the proposed order if mandated by the judicial officer.
• Detail alternate service. Serve non-e-filing participants by mail or hand delivery pursuant to C.R.C.P. 5 and record that service in the certificate with precise addresses and methods.