STIPULATION AND [PROPOSED] ORDER

(Maryland Circuit Court – General Civil Matters)

[// GUIDANCE: Provide background establishing good cause. Identify relevant sections of the Scheduling Order being modified. For Business & Technology track cases, reference the case management order issued by the assigned judge.]

1. CAPTION

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

Attorney for [PARTY NAME]

IN THE CIRCUIT COURT FOR [COUNTY] COUNTY, MARYLAND

Case No. [CASE NUMBER]

[PLAINTIFF NAME],
Plaintiff,

v.

[DEFENDANT NAME],
Defendant.

2. STIPULATION

The Parties stipulate and agree as follows:

1. Background.
   - The Court entered a Scheduling Order on [DATE].
   - [Summarize procedural posture and relevant deadlines].

2. Agreed Terms.
   a. [TERM 1: e.g., “Discovery shall remain open until [DATE], extending the current deadline by [NUMBER] days.”]
   b. [TERM 2: e.g., “Expert disclosures pursuant to Md. Rule 2-402(g) shall be served by [DATE], with rebuttal disclosures by [DATE].”]
   c. [TERM 3: e.g., “The dispositive motion deadline is extended to [DATE].”]
   d. [Additional terms as needed].

3. Authority. This stipulation is submitted under Md. Rule 2-311 and the Court’s Scheduling Order ¶ [NUMBER], and is supported by good cause because [JUSTIFICATION].

4. Reservation. Except as expressly modified herein, all provisions of the Scheduling Order remain in full force and effect.

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

3. SIGNATURES

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AGREED:

[LAW FIRM NAME]
By: _____
[ATTORNEY NAME]
CPF No. [NUMBER]
Attorneys for [PLAINTIFF]
Date: __

[SECOND LAW FIRM NAME]
By: _____
[ATTORNEY NAME]
CPF No. [NUMBER]
Attorneys for [DEFENDANT]
Date: __

[// GUIDANCE: Include additional counsel signatures. Electronic signatures (“/s/ Name”) are accepted in MDEC filings.]

4. [PROPOSED] ORDER

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Upon consideration of the Parties’ Stipulation and for good cause shown, it is this _ day of _____, 20__, by the Circuit Court for [COUNTY] County, Maryland, ORDERED that:

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 Scheduling Order dated [DATE] remain in effect.

Judge of the Circuit Court
[// GUIDANCE: Insert judge’s name beneath the signature line if required by chambers.]

5. CERTIFICATE OF SERVICE

text
I certify that on [DATE], I filed the foregoing via MDEC, which sent notice to all registered parties. Copies were served by [MAIL / EMAIL / HAND DELIVERY] on the following non-registered parties:

[NAME]
[ADDRESS / EMAIL]

[NAME OF DECLARANT]
CPF No. [NUMBER]
[// GUIDANCE: Ensure service conforms to Maryland Rule 1-321.]

6. FILING & SERVICE CHECKLIST

• Reference Maryland rules. Cite the Maryland Rules authorizing the stipulation (e.g., Rules 1-204, 2-504, 2-506, 2-541) and any case management order provisions that must be satisfied.
• Follow MDEC protocols. File the stipulation under the correct event, attach exhibits, and submit an editable proposed order if required by the judge or local administrative order.
• Serve outside MDEC. Provide alternative service to non-registered parties by mail or personal delivery, documenting compliance with Rule 1-321.