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

STIPULATION AND [PROPOSED] ORDER

Illinois Circuit Court — General Civil Matters

I. ATTORNEY IDENTIFICATION BLOCK

Filing Attorney Information:

Name: [________________________________]

ARDC No.: [________________________________]

Firm: [________________________________]

Address: [________________________________]

City, State, ZIP: [________________________________], Illinois [____]

Telephone: [________________________________]

Facsimile: [________________________________]

Email: [________________________________]

Attorney for: ☐ Plaintiff [________________________________] ☐ Defendant [________________________________]

II. COURT CAPTION

IN THE CIRCUIT COURT OF [________________________________] COUNTY, ILLINOIS

[________________________________] DIVISION

☐ Law Division ☐ Chancery Division ☐ Municipal Division ☐ Domestic Relations Division ☐ Other: [________________________________]

STIPULATION

The undersigned parties, by and through their respective attorneys of record, hereby stipulate and agree as follows:

III. RECITALS AND PROCEDURAL BACKGROUND

1. This civil action was filed on [__/__/____] and is currently assigned to the Honorable [________________________________] in the [________________________________] Division of the Circuit Court of [________________________________] County.

2. A Case Management Order was entered on [__/__/____] establishing the following relevant deadlines:

a. Fact discovery closes: [__/__/____]

b. Expert disclosures due: [__/__/____]

c. Dispositive motions due: [__/__/____]

d. Trial date / next status date: [__/__/____]

3. The current procedural posture of this case is as follows:

[________________________________]

4. This Stipulation is supported by good cause, as described below.

IV. GOOD CAUSE STATEMENT

5. Good cause exists for the relief requested herein because:

[________________________________]

[________________________________]

[________________________________]

Note to Practitioner: Illinois Supreme Court Rule 183 requires a showing of "good cause" for extensions of time. The statement should address specific factual circumstances — such as discovery complexity, pending settlement negotiations, expert scheduling, or other legitimate grounds — rather than mere convenience. If seeking to modify a Supreme Court Rule 218 scheduling order, the good cause showing may be more rigorous.

V. STIPULATED TERMS

The parties agree to the following terms:

Term 1:

6. [________________________________]

(Example: "The deadline for completion of fact discovery is extended from [__/__/____] to [__/__/____], an extension of [____] days.")

Term 2:

7. [________________________________]

(Example: "Expert disclosures pursuant to Illinois Supreme Court Rule 213(f)(1), (2), and (3) shall be served by the following dates: Plaintiff's disclosures by [__/__/____]; Defendant's disclosures by [__/__/____].")

Term 3:

8. [________________________________]

(Example: "Rule 213(g) expert depositions shall be completed by [__/__/____].")

Term 4:

9. [________________________________]

(Example: "Dispositive motions under 735 ILCS 5/2-615 and/or 735 ILCS 5/2-619 shall be filed by [__/__/____]. Response briefs due [__/__/____]. Reply briefs due [__/__/____].")

Term 5:

10. [________________________________]

(Example: "The next status hearing is continued from [__/__/____] to [__/__/____] at [____] ☐ a.m. ☐ p.m.")

Additional Terms:

11. [________________________________]

12. [________________________________]

VI. AUTHORITY FOR STIPULATION

13. This Stipulation is made pursuant to the following authority:

☐ Illinois Supreme Court Rule 183 — Extension of time for good cause shown

☐ Illinois Supreme Court Rule 201(c)(1) — Agreements regarding discovery procedures

☐ Illinois Supreme Court Rule 218 — Modification of case management order

☐ 735 ILCS 5/2-1007 — Stipulations between parties

☐ Local Circuit Court Rule: [________________________________]

☐ Standing Order of the Court: [________________________________]

☐ Other: [________________________________]

14. The parties represent that this Stipulation does not prejudice the rights of any party, does not affect any statutory deadline that cannot be modified by agreement of the parties, and is consistent with the orderly administration of justice.

VII. PRESERVATION OF RIGHTS

15. Except as expressly modified by this Stipulation, all prior orders of this Court remain in full force and effect.

16. All claims, defenses, counterclaims, cross-claims, and affirmative defenses of all parties are preserved.

17. This Stipulation shall not be construed as an admission of liability, fault, or damages by any party.

18. Each party reserves all rights not expressly waived herein.

VIII. REQUEST FOR ENTRY OF ORDER

19. The parties respectfully request that the Court approve this Stipulation, find that good cause has been shown, and enter the Proposed Order set forth below.

IX. PARTY SIGNATURES

Plaintiff's Counsel:

Dated: [__/__/____]

[________________________________] (Law Firm Name)

By: /s/ [________________________________]

[________________________________] (Attorney Name)

ARDC No. [________________________________]

[________________________________] (Address)

[________________________________], Illinois [____]

Telephone: [________________________________]

Email: [________________________________]

Attorney for Plaintiff [________________________________]

Defendant's Counsel:

Dated: [__/__/____]

[________________________________] (Law Firm Name)

By: /s/ [________________________________]

[________________________________] (Attorney Name)

ARDC No. [________________________________]

[________________________________] (Address)

[________________________________], Illinois [____]

Telephone: [________________________________]

Email: [________________________________]

Attorney for Defendant [________________________________]

Additional Party Counsel (if applicable):

Dated: [__/__/____]

[________________________________] (Law Firm Name)

By: /s/ [________________________________]

[________________________________] (Attorney Name)

ARDC No. [________________________________]

[________________________________] (Address)

[________________________________], Illinois [____]

Telephone: [________________________________]

Email: [________________________________]

Attorney for [________________________________]

Self-Represented Party (if applicable):

Dated: [__/__/____]

By: /s/ [________________________________]

[________________________________] (Printed Name)

[________________________________] (Address)

[________________________________], Illinois [____]

Telephone: [________________________________]

Email: [________________________________]

☐ Plaintiff ☐ Defendant ☐ Third-Party [________________________________]

[PROPOSED] ORDER

IN THE CIRCUIT COURT OF [________________________________] COUNTY, ILLINOIS

[________________________________] DIVISION

ORDER

THIS MATTER coming before the Court on the Stipulation of the parties, and the Court having reviewed the Stipulation, and due notice having been given to all parties of record, and the Court being fully advised in the premises and finding good cause shown:

IT IS HEREBY ORDERED THAT:

1. The parties' Stipulation filed on [__/__/____] is APPROVED and incorporated herein by reference.

2. [________________________________]

(Mirror each stipulated term as an ordered term.)

3. [________________________________]

4. [________________________________]

5. [________________________________]

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

7. This Order is entered pursuant to Illinois Supreme Court Rule [________________________________] and [________________________________].

ENTERED:

Date: [__/__/____]

________________________________________

Hon. [________________________________]

Judge, Circuit Court of [________________________________] County, Illinois

CERTIFICATE OF SERVICE

I, [________________________________], an attorney, hereby certify that on [__/__/____], I caused the foregoing STIPULATION AND [PROPOSED] ORDER to be filed and served as follows:

Electronic Filing and Service:

☐ Filed via the eFileIL system (https://efiling.illinoiscourts.gov), which automatically served all registered counsel of record pursuant to Illinois Supreme Court Rule 11(b)(6).

Additional Service (for parties not served via eFileIL):

☐ United States Mail, first-class, postage prepaid, addressed to:

Name: [________________________________]

Address: [________________________________]

City, State, ZIP: [________________________________]

☐ Hand Delivery to:

Name: [________________________________]

Address: [________________________________]

☐ Email (with prior consent) to:

Name: [________________________________]

Email: [________________________________]

☐ Facsimile to:

Name: [________________________________]

Fax No.: [________________________________]

/s/ [________________________________]

[________________________________] (Attorney Name)

ARDC No. [________________________________]

PRACTITIONER CHECKLIST

☐ Verified all party signatures are obtained before filing — stipulations require consent of all affected parties

☐ Good cause statement is specific and factual (not boilerplate) to satisfy Ill. Sup. Ct. R. 183

☐ Proposed Order mirrors the stipulated terms exactly

☐ Correct division (Law/Chancery/Municipal) and calendar number are included in caption

☐ ARDC numbers included for all attorneys (required under Ill. Sup. Ct. R. 13)

☐ Filed via eFileIL using the correct document type category

☐ If required by the assigned judge's standing order, provided courtesy copy (PDF and/or Word version) to chambers

☐ For Cook County: verified compliance with Division/Section Standing Orders for additional formatting or filing requirements

☐ Self-represented parties served by traditional methods if not registered on eFileIL (Ill. Sup. Ct. R. 11)

☐ Confirmed stipulation does not modify a non-waivable statutory deadline

☐ Calendar new deadlines immediately upon entry of the order

☐ Retained copy of the entered (judge-signed) order for the file

ILLINOIS-SPECIFIC PRACTICE NOTES

eFileIL Requirements

All civil cases in Illinois circuit courts require electronic filing through the eFileIL system. When filing a stipulation and proposed order:

• Select the document type: "Stipulation" or "Agreed Order" (varies by county)
• Attach the proposed order as a separate PDF if required by the assigned judge
• Some judges require a Word-editable version of the proposed order to be emailed to chambers

Cook County Special Requirements

In Cook County, practitioners should review the standing orders for the applicable division and section. Some judges require:

• A "Prepared By" block on the proposed order
• Courtesy copies delivered to chambers
• Specific formatting for the case number and calendar designation

Verification Under 735 ILCS 5/1-109

Stipulations generally do not require verification under oath. However, if the stipulation addresses factual matters or is submitted in lieu of an affidavit, it may be certified pursuant to 735 ILCS 5/1-109 ("under penalties as provided by law pursuant to Section 1-109 of the Code of Civil Procedure, the undersigned certifies that the statements set forth in this instrument are true and correct...").

Rule 213 Expert Disclosures

If the stipulation modifies expert disclosure deadlines, ensure compliance with the specific requirements of Ill. Sup. Ct. R. 213(f)(1) (controlled expert opinions), (f)(2) (independent expert opinions), and (f)(3) (lay opinions). Expert depositions are governed by Ill. Sup. Ct. R. 213(g).

Sources and References

• Illinois Supreme Court Rules (current): https://www.illinoiscourts.gov/rules-law/supreme-court-rules/
• Illinois Supreme Court Rule 11 — Manner of serving documents on parties
• Illinois Supreme Court Rule 13 — Filing with the court
• Illinois Supreme Court Rule 131 — Form and format of papers filed
• Illinois Supreme Court Rule 183 — Extensions of time
• Illinois Supreme Court Rule 201 — General discovery provisions
• Illinois Supreme Court Rule 213 — Written interrogatories; expert disclosures
• Illinois Supreme Court Rule 218 — Discovery and case management conferences
• 735 ILCS 5/1-109 — Verification by certification
• 735 ILCS 5/2-1007 — Stipulations
• eFileIL system: https://efiling.illinoiscourts.gov
• Cook County Circuit Court Local Rules: https://www.cookcountycourt.org/