STIPULATION AND [PROPOSED] ORDER

(Illinois Circuit Court – General Civil Matters)

[// GUIDANCE: Provide background sufficient for the Court to find good cause. For continuances, address factors under local rules and Supreme Court Rule 183. In Cook County, consult the Division/Section Standing Order for additional requirements (e.g., courtesy copies).]

1. CAPTION

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

Attorney for [PARTY NAME]

IN THE CIRCUIT COURT OF [COUNTY] COUNTY, ILLINOIS
[LAW DIVISION / CHANCERY DIVISION / ETC.]

[PLAINTIFF NAME],
Plaintiff,

v. Case No. [CASE NUMBER]
Calendar [#] – Hon. [JUDGE NAME]
[DEFENDANT NAME],
Defendant.

2. STIPULATION

The Parties stipulate and agree as follows:

1. Procedural Background.
   - A Case Management Order was entered on [DATE].
   - [Summarize relevant events and pending deadlines].

2. Agreed Terms.
   a. [TERM 1: e.g., “Fact discovery shall close on [DATE], extending the current deadline by [NUMBER] days.”]
   b. [TERM 2: e.g., “Expert disclosures pursuant to Supreme Court Rule 213(f) shall be served by [DATE]; Rule 213(g) depositions completed by [DATE].”]
   c. [TERM 3: e.g., “The dispositive motion briefing schedule shall be as follows: opening briefs due [DATE]; responses due [DATE]; replies due [DATE].”]
   d. [Additional terms as necessary].

3. Authority. This stipulation is made pursuant to Supreme Court Rule 183 and the Court’s Case Management Order ¶ [NUMBER], and is supported by good cause because [JUSTIFICATION].

4. Reservation of Rights. Except as modified herein, all prior orders remain in effect and all claims and defenses are preserved.

5. Request for Order. The Parties respectfully request that the Court approve this stipulation and enter the proposed order set forth below.

3. SIGNATURES

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Dated: ______

[LAW FIRM NAME]
By: ________
[ATTORNEY NAME]
ARDC No. [NUMBER]
Attorney for [PLAINTIFF]

[SECOND LAW FIRM NAME]
By: ________
[ATTORNEY NAME]
ARDC No. [NUMBER]
Attorney for [DEFENDANT]

[// GUIDANCE: Add signature blocks for all counsel. Use “/s/ Name” when filing electronically.]

4. [PROPOSED] ORDER

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THIS MATTER coming before the Court on the Parties’ Stipulation, due notice having been given and the Court being fully advised, IT IS HEREBY ORDERED:

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] shall remain in effect.

ENTERED:

Dated: ____ _________
Judge, Circuit Court of Cook County / [COUNTY] County
[// GUIDANCE: Modify the judge’s signature block to match local formatting (e.g., include “Judge’s No.”, “Prepared by” lines).]

5. CERTIFICATE OF SERVICE

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The undersigned certifies that on [DATE], the foregoing was filed via eFileIL and served upon all counsel of record by electronic service pursuant to Supreme Court Rule 11(b). Additional service was made as follows:

☐ U.S. Mail to: [NAME / ADDRESS]
☐ Hand Delivery to: [NAME / ADDRESS]

[NAME OF DECLARANT]
ARDC No. [NUMBER]
[// GUIDANCE: Update to reflect actual service method. In Cook County, add “Prepared by” block if required.]

6. FILING & SERVICE CHECKLIST

• Anchor relief in Illinois authority. Cite the Illinois Supreme Court Rules or Code of Civil Procedure provisions permitting the stipulation (e.g., Sup. Ct. R. 201, 206, 218, 219; 735 ILCS 5/2-1007) and verify compliance with any circuit-specific general order.
• Comply with eFileIL guidelines. File the stipulation and proposed order using the correct document type, include a PDF and, if required by chambers, email or upload a Word version pursuant to local standing orders.
• Serve parties outside eFileIL. Provide traditional service to self-represented litigants or exempt attorneys and describe the method consistent with Ill. Sup. Ct. R. 11.