Stipulation and [Proposed] Order — General Civil

STIPULATION AND [PROPOSED] ORDER

SUPERIOR COURT OF THE DISTRICT OF COLUMBIA

CIVIL DIVISION

Attorney for [________________________________]:

[________________________________] (D.C. Bar No. [________________________________])

[________________________________] (Firm Name)

[________________________________] (Street Address)

Washington, DC [____]

Telephone: [________________________________]

Facsimile: [________________________________]

Email: [________________________________]

[________________________________],

Plaintiff,

v. Civil Action No. [________________________________]

Calendar [________________________________]

Judge [________________________________]

Next Event Date: [__/__/____]

[________________________________],

Defendant.

STIPULATION

The parties, by and through their undersigned counsel (or appearing pro se as indicated), respectfully submit this Stipulation and state as follows:

I. PROCEDURAL BACKGROUND

1. This civil action was commenced by the filing of a Complaint on [__/__/____].

2. The Court entered a Scheduling Order on [__/__/____] (Docket Entry No. [____]).

3. The case is assigned to Calendar [____] before the Honorable [________________________________].

4. Current case status and procedural posture:

[________________________________]

[________________________________]

[________________________________]

5. The following proceedings have occurred or are currently pending:

☐ Initial scheduling conference was held on [__/__/____]

☐ Discovery is open and scheduled to close on [__/__/____]

☐ Dispositive motion deadline is [__/__/____]

☐ Mediation is scheduled for / was completed on [__/__/____]

☐ Pretrial conference is scheduled for [__/__/____]

☐ Trial is scheduled for [__/__/____]

☐ Other: [________________________________]

II. MEET AND CONFER CERTIFICATION

6. Pursuant to D.C. Superior Court Civil Rule 16 and the Court's Scheduling Order, counsel for the parties have met and conferred regarding the matters addressed in this Stipulation.

7. Method and date of conference:

☐ In-person meeting on [__/__/____]

☐ Telephone conference on [__/__/____]

☐ Video conference on [__/__/____]

☐ Exchange of correspondence (dates): [________________________________]

8. All parties are in agreement with the terms set forth herein.

☐ All counsel have been authorized by their respective clients to enter into this Stipulation.

☐ Pro se parties have consented personally to the terms set forth herein.

III. NATURE OF STIPULATION

The parties stipulate to the following type(s) of modification or agreement (check all that apply):

☐ Extension of discovery deadlines

☐ Modification of the Scheduling Order

☐ Extension of time to file dispositive motions

☐ Continuance of trial date

☐ Continuance of pretrial conference scheduled for [__/__/____]

☐ Continuance of status conference scheduled for [__/__/____]

☐ Extension of mediation deadline pursuant to applicable Administrative Order

☐ Modification of expert disclosure deadlines

☐ Stipulation regarding discovery procedures (D.C. Super. Ct. Civ. R. 29)

☐ Stipulation to dismiss claims or parties (specify): [________________________________]

☐ Stipulation regarding admission of facts (D.C. Super. Ct. Civ. R. 36)

☐ Stay of proceedings

☐ Amendment of pleadings

☐ Settlement of specific issues

☐ Other: [________________________________]

IV. STIPULATED TERMS

The parties agree to the following specific terms:

Term 1: [________________________________]

[________________________________]

[________________________________]

Term 2: [________________________________]

[________________________________]

[________________________________]

Term 3: [________________________________]

[________________________________]

[________________________________]

Term 4: [________________________________]

[________________________________]

[________________________________]

Term 5 (Additional terms as needed): [________________________________]

[________________________________]

[________________________________]

V. GOOD CAUSE

9. Good cause exists for the relief requested because:

[________________________________]

[________________________________]

[________________________________]

10. The stipulated modifications will not prejudice any party and will promote the just, speedy, and inexpensive resolution of this action.

11. The requested modification is necessitated by (check all that apply):

☐ The complexity of the issues and discovery required

☐ Ongoing settlement negotiations between the parties

☐ Scheduling conflicts of counsel

☐ The need for additional expert analysis or evaluation

☐ Recently discovered facts requiring additional investigation

☐ Changes in party representation

☐ Third-party discovery or subpoena compliance timelines

☐ Compliance with mediation or ADR requirements

☐ Coordination with related proceedings in: [________________________________]

☐ Other: [________________________________]

VI. MEDIATION AND ADR STATUS

12. Status of mediation or alternative dispute resolution:

☐ Mediation has been completed (date: [__/__/____])

☐ Mediation is scheduled for [__/__/____]

☐ The parties have agreed to extend the mediation deadline to [__/__/____]

☐ Mediation has not yet been scheduled

☐ Mediation is not required in this case

☐ The parties request referral to: ☐ Multi-Door Dispute Resolution Division ☐ Private mediator ☐ Other: [________________________________]

VII. RESERVATION OF RIGHTS

13. Except as expressly modified by this Stipulation, all provisions of the Court's Scheduling Order dated [__/__/____] and all other existing orders of this Court shall remain in full force and effect.

14. This Stipulation shall not be construed as a waiver of any party's rights, claims, or defenses.

15. The parties reserve the right to seek further modification of the Scheduling Order upon a showing of good cause.

VIII. AUTHORITY

16. This Stipulation is submitted pursuant to:

☐ D.C. Super. Ct. Civ. R. 6(b) (Enlargement of Time)

☐ D.C. Super. Ct. Civ. R. 16 (Pretrial Conferences; Scheduling; Management)

☐ D.C. Super. Ct. Civ. R. 29 (Stipulations About Discovery Procedure)

☐ D.C. Super. Ct. Civ. R. 36 (Requests for Admission)

☐ D.C. Super. Ct. Civ. R. 41(a)(1)(B) (Voluntary Dismissal by Stipulation)

☐ D.C. Super. Ct. Civ. R. 83 (Rules by the Court; Judge's Directives)

☐ Paragraph [____] of the Court's Scheduling Order dated [__/__/____]

☐ Other: [________________________________]

IX. REQUEST FOR ENTRY OF ORDER

The parties respectfully and jointly request that the Court approve this Stipulation and enter the [Proposed] Order set forth below.

SIGNATURES

Respectfully submitted,

For Plaintiff:

DATED: [__/__/____]

[________________________________] (Firm Name)

By: _______________________________________________

[________________________________] (Attorney Name)

D.C. Bar No. [________________________________]

Counsel for Plaintiff [________________________________]

For Defendant:

DATED: [__/__/____]

[________________________________] (Firm Name)

By: _______________________________________________

[________________________________] (Attorney Name)

D.C. Bar No. [________________________________]

Counsel for Defendant [________________________________]

For Additional Party (if applicable):

DATED: [__/__/____]

[________________________________] (Firm Name)

By: _______________________________________________

[________________________________] (Attorney Name)

D.C. Bar No. [________________________________]

Counsel for [________________________________]

Pro Se Party Signatures (if applicable)

DATED: [__/__/____]

Signature: _______________________________________________

Printed Name: [________________________________]

Address: [________________________________]

Washington, DC [____]

Telephone: [________________________________]

Email: [________________________________]

☐ Plaintiff, Pro Se ☐ Defendant, Pro Se

[PROPOSED] ORDER

Upon consideration of the parties' Stipulation, the representations of counsel, and the entire record herein, it is this [____] day of [________________________________], 20[____], hereby

ORDERED, that the Stipulation is APPROVED and incorporated herein; and it is further

ORDERED, that:

1. [________________________________]

2. [________________________________]

3. [________________________________]

4. [________________________________]

5. All other provisions of the Scheduling Order dated [__/__/____] shall remain in full force and effect.

SO ORDERED.

_______________________________________________

Honorable [________________________________]

Associate Judge, Superior Court of the District of Columbia

CERTIFICATE OF SERVICE

I hereby certify that on [__/__/____], I caused to be filed and served a true and correct copy of the foregoing Stipulation and [Proposed] Order by the following method(s):

☐ CaseFileXpress / eFileDC — Electronic filing and service on all registered users

☐ Email to the following addresses:

[________________________________]

[________________________________]

☐ First-class U.S. Mail, postage prepaid, to the following non-registered parties or pro se litigants:

[________________________________]

[________________________________]

☐ Hand delivery to:

[________________________________]

Signature: _______________________________________________

Printed Name: [________________________________]

D.C. Bar No. [________________________________]

FILING INSTRUCTIONS AND PRACTICE NOTES

D.C. Superior Court — Specific Requirements:

1. Electronic Filing: As of September 2025, D.C. Superior Court has transitioned certain civil filings to the eFileDC system. For all other case types, parties should continue to use CaseFileXpress (File & ServeXpress). Check the current e-filing requirements at the time of filing. When filing:

• Select the correct event code for a "Stipulation" or "Joint Stipulation"
• Upload the proposed order as a separate attachment
• Some judges require the proposed order in an editable Word format; check the assigned judge's chambers procedures

2. Scheduling Order Modification (D.C. Super. Ct. Civ. R. 16): A scheduling order may only be modified upon a showing of good cause. The court will consider whether the party seeking modification was diligent in attempting to meet the original deadlines. A stipulation alone does not guarantee the court will grant the modification.

3. Meet and Confer Requirement: D.C. Superior Court Rule 16 requires attorneys to meet and confer before the pretrial conference and, in practice, before seeking modifications to the scheduling order. Certify in the stipulation that the parties have conferred and reached agreement.

4. Electronic Signatures: Electronic signatures in the format "/s/ [Name]" are accepted for documents filed through CaseFileXpress or eFileDC, consistent with applicable Administrative Orders.

5. Service on Non-Registered Parties: Under D.C. Super. Ct. Civ. R. 5, parties who are not registered for electronic filing must be served by mail, hand delivery, or other permitted means. Document compliance in the Certificate of Service.

6. Multi-Door Dispute Resolution Division: D.C. Superior Court operates the Multi-Door Dispute Resolution Division, which provides mediation and other ADR services. Stipulations regarding mediation deadlines should reference the applicable mediation program and any pending referral.

7. Calendar System: D.C. Superior Court Civil Division cases are assigned to specific calendars. Include the calendar number and assigned judge in all filed documents.

8. Judge-Specific Requirements: Individual judges may have standing orders or chambers procedures that impose additional requirements for stipulations and proposed orders. Review the assigned judge's standing order, which is typically available on the D.C. Courts website or from the Clerk's Office.

9. Proposed Order Format: The proposed order should begin with the standard introductory language ("Upon consideration of...") and use the "ORDERED" format customary in D.C. Superior Court. Include "SO ORDERED." at the conclusion with a signature line for the assigned judge.

10. Filing Fees: No separate filing fee is generally required for stipulations and proposed orders in pending civil actions. Confirm with the Clerk's Office if any fees apply.

Sources and References

• D.C. Superior Court Rules of Civil Procedure: https://www.dccourts.gov/sites/default/files/superior-rules/Superior-Court-Rules-of-Civil-Procedure-2025.pdf
• D.C. Superior Court E-Filing Information (eFileDC): https://efiledcsuperiorcourt.gov/
• D.C. Superior Court E-Filing (CaseFileXpress): https://www.dccourts.gov/superior-court/e-filing
• Rules of the Superior Court: https://www.dccourts.gov/superior-court/superior-court-resources/rules-of-the-superior-court
• D.C. Superior Court Rule 16 (Pretrial Conferences; Scheduling; Management): https://www.dccourts.gov/sites/default/files/rules-superior-court/Civil%20Rule%2016.%20Pretrial%20Conferences_%20Pretrial%20Status%20Conferences_%20Scheduling_%20Management.pdf
• D.C. Multi-Door Dispute Resolution Division: https://www.dccourts.gov/superior-court/multi-door-dispute-resolution-division