STIPULATION AND [PROPOSED] ORDER

(Delaware Superior Court – General Civil Matters)

[// GUIDANCE: For CCLD or Complex Commercial matters, reference the controlling Scheduling Order paragraph. For stipulations affecting trial dates, include a statement that the parties have conferred with chambers if required.]

1. CAPTION

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[ATTORNEY OR SELF-REPRESENTED PARTY]
Name: [NAME] (DE Bar ID [NUMBER])
Firm: [LAW FIRM NAME]
Address: [STREET ADDRESS]
City, State ZIP: [CITY], Delaware [ZIP]
Telephone: [TEL] | Facsimile: [FAX]
E-Mail: [EMAIL]

Attorney for [PARTY NAME]

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE
IN AND FOR [NEW CASTLE / KENT / SUSSEX] COUNTY

[PLAINTIFF NAME],
Plaintiff,

v. C.A. No. [CASE NUMBER]

[DEFENDANT NAME],
Defendant.

2. STIPULATION

The Parties, by and through their undersigned counsel, stipulate as follows:

1. Background.
   - The Court entered its [Scheduling Order/Trial Scheduling Order] on [DATE] (D.I. [NUMBER]).
   - [Brief factual/procedural context].

2. Stipulated Terms.
   a. [TERM 1: e.g., “Expert discovery deadlines are extended by thirty (30) days such that opening reports are due [DATE] and rebuttal reports [DATE].”]
   b. [TERM 2: e.g., “The Parties shall conduct mediation with [MEDIATOR] on or before [DATE].”]
   c. [TERM 3: e.g., “The pending Motion to Compel (D.I. [NUMBER]) is withdrawn without prejudice.”]
   d. [Additional terms as needed].

3. Authority and Good Cause. This stipulation is entered pursuant to Super. Ct. Civ. R. [CITE RULE] and the Scheduling Order, ¶ [NUMBER], which permits modifications on written agreement for good cause shown. Good cause exists because [JUSTIFICATION].

4. Reservation. Except as modified herein, all prior orders remain in full force and effect.

5. Request for Order. The Parties respectfully request that the Court approve the foregoing stipulation and enter the accompanying order.

3. SIGNATURES

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Dated: ______

[LAW FIRM NAME]
By: ________
[ATTORNEY NAME] (Bar ID [NUMBER])
Attorneys for [PLAINTIFF]

[SECOND LAW FIRM NAME]
By: ________
[ATTORNEY NAME] (Bar ID [NUMBER])
Attorneys for [DEFENDANT]

[// GUIDANCE: Include signature blocks for every counsel of record. File & ServeXpress recognizes “/s/ Name” electronic signatures per Super. Ct. Civ. R. 11.]

4. [PROPOSED] ORDER

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AND NOW, this _ day of _____, 20__, the Court having considered the foregoing Stipulation, IT IS HEREBY ORDERED that:

1. The Stipulation is APPROVED and incorporated by reference.
2. [ORDERED TERM 1].
3. [ORDERED TERM 2].
4. [ORDERED TERM 3 / ADDITIONAL RELIEF].

All remaining provisions of the Court’s [Scheduling Order/Trial Scheduling Order] remain in effect.

The Honorable [JUDGE NAME]
Judge, Superior Court of the State of Delaware
[// GUIDANCE: Insert the judge’s judicial title (e.g., Resident Judge, Judge of the Complex Commercial Litigation Division) if required.]

5. SERVICE CERTIFICATE

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I hereby certify that on [DATE], I caused the foregoing Stipulation and [Proposed] Order to be filed and served via File & ServeXpress upon all registered counsel of record. Copies were served by [MAIL / EMAIL] on the following non-registered parties:

[NAME]
[ADDRESS / EMAIL]

[NAME OF DECLARANT]
[// GUIDANCE: Update service descriptions to comply with Super. Ct. Civ. R. 5(b).]

6. FILING & SERVICE CHECKLIST

• Cite the controlling Superior Court rule. Identify the Delaware Superior Court Civil Rules that authorize the relief (e.g., Rules 6(b), 16, 29, 41) and mention any standing orders for the assigned division.
• Utilize File & ServeXpress correctly. Select the proper transaction type, upload a proposed order in Word format if requested, and confirm payment of the electronic filing fee.
• Handle non-eFile service. Deliver paper or electronic copies to parties not in File & ServeXpress and describe the method consistent with Super. Ct. Civ. R. 5(b).