STIPULATION AND [PROPOSED] ORDER

(Michigan Circuit Court – General Civil Matters)

[// GUIDANCE: Provide background establishing good cause. If the relief alters scheduling, reference the controlling Scheduling Order and local administrative orders (e.g., Wayne County LCR).]

1. CAPTION

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

Attorney for [PARTY NAME]

STATE OF MICHIGAN
IN THE [__]TH JUDICIAL CIRCUIT COURT
FOR THE COUNTY OF [COUNTY]

Case No. [CASE NUMBER]
Hon. [JUDGE NAME]

[PLAINTIFF NAME],
Plaintiff,

v.

[DEFENDANT NAME],
Defendant.

2. STIPULATION

The Parties stipulate and agree as follows:

1. Background.
   - A Scheduling Order was entered on [DATE].
   - [Summarize pertinent deadlines or motions].

2. Agreed Terms.
   a. [TERM 1: e.g., “The discovery cutoff is extended to [DATE].”]
   b. [TERM 2: e.g., “Expert disclosures under MCR 2.302(B) shall be exchanged by [DATE].”]
   c. [TERM 3: e.g., “The dispositive motion deadline is extended to [DATE], with hearing dates to be coordinated with the Court.”]
   d. [Additional terms as needed].

3. Authority. This stipulation is submitted pursuant to MCR 2.119 and 2.401(B)(2), and is supported by good cause because [JUSTIFICATION].

4. Reservation. Except as expressly modified, the Scheduling Order and all other court directives remain in effect.

5. Request for Order. The Parties jointly request that the Court adopt this stipulation as an order.

3. SIGNATURES

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Dated: ______

[LAW FIRM NAME]
By: ________
[ATTORNEY NAME] (P[NUMBER])
Attorney for [PLAINTIFF]

[SECOND LAW FIRM NAME]
By: ________
[ATTORNEY NAME] (P[NUMBER])
Attorney for [DEFENDANT]

[// GUIDANCE: Include signatures for all counsel. Electronic signatures (“/s/ Name”) are acceptable under MCR 1.109(E)(4).]

4. [PROPOSED] ORDER

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At a session of said Court held in the [COUNTY] County Circuit Courthouse on the _ day of _____, 20__:

PRESENT: Honorable [JUDGE NAME], Circuit Court Judge

The Court having reviewed the Parties’ Stipulation and being otherwise fully advised in the premises, IT IS 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 unchanged.

IT IS SO ORDERED.

Hon. [JUDGE NAME]
Circuit Court Judge
[// GUIDANCE: Include “Approved as to form and substance” lines if requested by the judge.]

5. CERTIFICATE OF SERVICE

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I certify that on [DATE], I electronically filed the foregoing through MiFILE (or served by [METHOD]), which will send notice to all counsel of record pursuant to MCR 2.107. Copies were served on any non-registered parties as follows:

[NAME]
[ADDRESS / EMAIL]

[NAME OF DECLARANT]
P[NUMBER]
[// GUIDANCE: Update service description to match actual method.]

6. FILING & SERVICE CHECKLIST

• Cite Michigan authority. Reference the Michigan Court Rules enabling the stipulation (e.g., MCR 2.401, 2.402, 2.506, 2.507) and any local administrative order for the circuit.
• Comply with MiFILE/Local filing practices. Use the correct filing type within MiFILE (or submit paper filings where MiFILE is not implemented), and provide a Word version of the proposed order if required by the judge.
• Serve per MCR 2.107. Deliver service to non-MiFILE participants by mail or other authorized method and detail the service within the certificate.