State Court Stipulation and Order — Minnesota

STIPULATION AND [PROPOSED] ORDER

Minnesota District Court — General Civil Matters

IMPORTANT INSTRUCTIONS

This template is designed for use when all parties to a Minnesota civil action have reached an agreement on procedural or substantive matters and wish to submit that agreement to the court as a stipulation with a proposed order for judicial adoption. Under Minnesota practice, stipulations are commonly used to modify scheduling orders, extend discovery deadlines, continue hearings, agree upon discovery protocols, and memorialize settlement terms.

Minnesota civil actions are filed in the District Court, which is the court of general jurisdiction. Each judicial district may have its own local rules or general orders supplementing the Minnesota Rules of Civil Procedure. Always check the applicable district court's local rules and any standing Case Management Orders before filing. The Minnesota Judicial Branch maintains court information at www.mncourts.gov.

Before Filing:

☐ Confirm all parties have reviewed and consented to the stipulated terms in writing

☐ Verify the assigned judge's individual practices and chambers requirements for stipulations and proposed orders

☐ Confirm compliance with Minn. R. Civ. P. 16.02 and 16.03 if the stipulation modifies a Case Management Order or Scheduling Order

☐ Check whether the proposed modification will affect the trial date, and if so, whether the court requires a separate motion or hearing

☐ Determine whether e-filing is required through the Minnesota Judicial Branch eFiling system (eFS)

☐ Prepare a proposed order in Word format if required by the assigned judge under Minn. Gen. R. Prac. 14

☐ Attach any referenced exhibits, prior scheduling orders, or supporting declarations

☐ Identify which judicial district (1st through 10th) and county this action is pending in

☐ Verify whether the case has been designated as a Complex Case, Expedited Track, or Standard Track under the Minnesota General Rules of Practice

☐ Confirm compliance with Minn. R. Civ. P. 29 if the stipulation modifies discovery procedures

SECTION 1: CASE CAPTION

STATE OF MINNESOTA

DISTRICT COURT

[________________________________] JUDICIAL DISTRICT

COUNTY OF [________________________________]

(Select applicable judicial district)

☐ First Judicial District (Carver, Dakota, Goodhue, Le Sueur, McLeod, Scott, Sibley)

☐ Second Judicial District (Ramsey)

☐ Third Judicial District (Dodge, Fillmore, Freeborn, Houston, Mower, Olmsted, Rice, Steele, Wabasha, Waseca, Winona)

☐ Fourth Judicial District (Hennepin)

☐ Fifth Judicial District (Blue Earth, Brown, Cottonwood, Faribault, Jackson, Lincoln, Lyon, Martin, Murray, Nobles, Pipestone, Redwood, Rock, Watonwan)

☐ Sixth Judicial District (Carlton, Cook, Lake, St. Louis)

☐ Seventh Judicial District (Becker, Beltrami, Clay, Clearwater, Douglas, Grant, Mahnomen, Norman, Otter Tail, Pennington, Polk, Pope, Red Lake, Roseau, Stevens, Todd, Traverse, Wadena, Wilkin)

☐ Eighth Judicial District (Big Stone, Chippewa, Kandiyohi, Lac Qui Parle, Meeker, Renville, Swift, Yellow Medicine)

☐ Ninth Judicial District (Aitkin, Cass, Crow Wing, Hubbard, Itasca, Koochiching, Lake of the Woods, Morrison, Mille Lacs, Wadena)

☐ Tenth Judicial District (Anoka, Chisago, Isanti, Kanabec, Pine, Sherburne, Washington, Wright)

Court File No.: [________________________________]

Case Type: [________________________________]

Judge: [________________________________]

Referee: [________________________________] (if applicable)

[________________________________],

Plaintiff(s),

v.

[________________________________],

Defendant(s).

SECTION 2: PARTY AND ATTORNEY IDENTIFICATION

Plaintiff's Counsel

Defendant's Counsel

Additional Parties (if applicable)

SECTION 3: STIPULATION OF THE PARTIES

COME NOW Plaintiff [________________________________] ("Plaintiff") and Defendant [________________________________] ("Defendant") (collectively, the "Parties"), by and through their respective undersigned counsel of record, and pursuant to the Minnesota Rules of Civil Procedure and the applicable rules of the [________________________________] Judicial District, respectfully submit this Stipulation and jointly request that the Court enter the attached Proposed Order. In support thereof, the Parties state as follows:

3.1 Recitals and Background

1. This action was commenced on [__/__/____] by the filing of a Complaint in the District Court, [________________________________] Judicial District, County of [________________________________], Minnesota.

2. The case is presently assigned to the Honorable [________________________________], Judge of District Court.

3. The Court entered the following relevant prior order(s) on [__/__/____]: [________________________________]

4. The current Case Management Order and Scheduling Order, dated [__/__/____], governs the following deadlines pursuant to Minn. R. Civ. P. 16.02:

• Fact Discovery Cutoff: [__/__/____]
• Expert Disclosures (Plaintiff) pursuant to Minn. R. Civ. P. 26.01(b): [__/__/____]
• Expert Disclosures (Defendant) pursuant to Minn. R. Civ. P. 26.01(b): [__/__/____]
• Dispositive Motion Deadline: [__/__/____]
• Note of Issue / Certificate of Trial Readiness: [__/__/____]
• Pretrial Conference (Minn. R. Civ. P. 16.03): [__/__/____]
• Trial Date: [__/__/____]

5. The Parties have conferred in good faith and have agreed upon the terms set forth below.

6. The basis for this Stipulation is as follows: [________________________________]

3.2 Stipulated Terms

The Parties hereby stipulate and agree to the following terms:

Term 1: [________________________________]

Term 2: [________________________________]

Term 3: [________________________________]

Term 4: [________________________________]

Term 5: [________________________________]

(Add or remove terms as necessary)

3.3 Type of Stipulation

(Select all that apply)

☐ Scheduling Modification — Extension or modification of deadlines set by the Court's Case Management Order or Scheduling Order under Minn. R. Civ. P. 16.02. The Parties represent that the requested modification ☐ will not / ☐ will affect the current trial date. If modification of the trial date is required, the Parties propose a new trial date of [__/__/____] or the first available date thereafter convenient to the Court.

☐ Discovery Stipulation — Modification of discovery procedures or deadlines pursuant to Minn. R. Civ. P. 29. Expert disclosure deadlines are governed by Minn. R. Civ. P. 26.01(b). The Parties agree that: [________________________________]. Note: Pursuant to Minn. R. Civ. P. 29, stipulations extending the time for responses to discovery may, if they would interfere with any time set for completion of discovery or for trial, be made only with the approval of the court.

☐ Continuance — The Parties jointly request that the hearing/conference/trial currently scheduled for [__/__/____] be continued to [__/__/____] or the first available date thereafter convenient to the Court, for the following reason: [________________________________]. This request is made pursuant to Minn. Gen. R. Prac. 115.04 and the Court's scheduling authority under Minn. R. Civ. P. 16.

☐ Voluntary Dismissal — The Parties stipulate to the voluntary dismissal of this action ☐ with prejudice / ☐ without prejudice pursuant to Minn. R. Civ. P. 41.01, with each party to bear its own costs and attorney fees unless otherwise stated herein. A Stipulation of Dismissal signed by all parties who have appeared in the action shall be filed with the Court.

☐ Settlement Terms — The Parties have reached a settlement agreement and request that the following terms be incorporated into a court order: [________________________________]

☐ Confidentiality / Protective Order — The Parties agree to the entry of a confidentiality order governing [________________________________] pursuant to Minn. R. Civ. P. 26.02.

☐ Mediation / ADR Scheduling — Pursuant to Minn. Stat. § 484.73 and any applicable court ADR program requirements, the Parties agree to mediation or alternative dispute resolution as follows: [________________________________]

☐ Pretrial Conference Matters — This stipulation addresses matters raised or to be raised at the Pretrial Conference under Minn. R. Civ. P. 16.03, including: [________________________________]

☐ Other — [________________________________]

3.4 Track Designation

(Select the applicable case track designation, if known)

☐ Expedited Track — Case subject to expedited litigation procedures under Minn. Gen. R. Prac. This track typically applies to cases with streamlined discovery and shorter timelines.

☐ Standard Track — Case proceeding on the standard civil track under the Case Management Order of the [________________________________] Judicial District.

☐ Complex Case — Case designated as complex pursuant to the Case Management Order. Complex cases are subject to additional case management protocols established by the assigned judge.

☐ Track designation unknown or not yet made

3.5 Good Cause Statement

Good cause exists for the relief requested herein because: [________________________________]

The Parties represent that this Stipulation is not made for the purpose of delay, is not the result of lack of diligence, and is consistent with the fair and efficient resolution of the action. Under Minn. R. Civ. P. 16.03, the assigned judge retains authority to modify the Scheduling Order to prevent manifest injustice.

3.6 Impact on Schedule

☐ This stipulation will not affect the current trial date or other pending deadlines.

☐ This stipulation will affect the following deadlines, and the Parties propose the following revised schedule:

3.7 District-Specific Filing Requirements

(Identify the applicable judicial district and confirm compliance)

☐ Fourth Judicial District (Hennepin County) — Civil actions filed in Hennepin County District Court are subject to the Fourth Judicial District's local rules and general orders. E-filing through the Minnesota eFS system is required for attorneys. The Fourth District has specific case management tracks and standing orders available at www.mncourts.gov/district/4.

☐ Second Judicial District (Ramsey County) — Actions in Ramsey County District Court are subject to Second Judicial District local rules. E-filing through eFS is required for attorneys. Court information is available at www.mncourts.gov/district/2.

☐ First Judicial District (including Dakota and Scott Counties) — Subject to the First Judicial District's local rules and case management protocols available at www.mncourts.gov/district/1.

☐ Other District: [________________________________] — Subject to the applicable judicial district's local rules and general orders. Specific requirements: [________________________________]. Court information available at www.mncourts.gov.

3.8 Reservation of Rights

Nothing in this Stipulation shall be construed as a waiver of any claim, defense, right, or objection not expressly addressed herein. The Parties expressly reserve all rights not specifically modified by this agreement, including but not limited to all claims and defenses asserted in the pleadings.

3.9 Authority to Stipulate

Each undersigned attorney represents that he or she is duly licensed to practice law in the State of Minnesota, has full authority from his or her respective client to enter into this Stipulation, and has the authority to bind said client to the terms set forth herein. Under Minn. R. Civ. P. 16.03, at least one attorney for each party participating in any pretrial conference shall have authority to enter into stipulations and to make admissions regarding all matters that the participants may reasonably anticipate will be discussed.

3.10 Governing Rules

This Stipulation is governed by and submitted in accordance with the Minnesota Rules of Civil Procedure, including Minn. R. Civ. P. 16.02, 16.03, 29, and any applicable local rules or general orders of the [________________________________] Judicial District.

3.11 Request for Court Approval

The Parties jointly and respectfully request that the Court adopt this Stipulation as its Order and enter the Proposed Order set forth in Section 5 below. Pursuant to Minn. Gen. R. Prac. 14, the Parties are submitting a proposed order in Word format to chambers as directed by the assigned judge.

SECTION 4: SIGNATURE BLOCKS — PARTIES AND ATTORNEYS

RESPECTFULLY SUBMITTED this [____] day of [________________________________], 20[____].

Plaintiff's Counsel

By: _______________________________________________

[________________________________]

Minnesota Attorney Registration No. [________________________________]

[________________________________] (Firm Name)

[________________________________] (Street Address)

[________________________________], Minnesota [____]

Telephone: [________________________________]

Facsimile: [________________________________]

Email: [________________________________]

Counsel for Plaintiff [________________________________]

Defendant's Counsel

By: _______________________________________________

[________________________________]

Minnesota Attorney Registration No. [________________________________]

[________________________________] (Firm Name)

[________________________________] (Street Address)

[________________________________], Minnesota [____]

Telephone: [________________________________]

Facsimile: [________________________________]

Email: [________________________________]

Counsel for Defendant [________________________________]

Additional Party or Self-Represented Party (if applicable)

By: _______________________________________________

[________________________________] (Printed Name)

Minnesota Attorney Registration No. [________________________________] (if counsel)

[________________________________] (Firm or Address)

[________________________________], Minnesota [____]

Telephone: [________________________________]

Email: [________________________________]

☐ Counsel for [________________________________] ☐ Self-Represented Party — ☐ Plaintiff / ☐ Defendant

Additional Party Signatures

(Reproduce this block for each additional party as needed)

By: _______________________________________________

[________________________________] (Printed Name or Attorney Name)

Minnesota Attorney Registration No. [________________________________] (if applicable)

☐ Counsel for / ☐ Self-Represented — [________________________________]

SECTION 5: [PROPOSED] ORDER

STATE OF MINNESOTA

DISTRICT COURT

[________________________________] JUDICIAL DISTRICT

COUNTY OF [________________________________]

Court File No.: [________________________________]

[________________________________],

Plaintiff(s),

v.

[________________________________],

Defendant(s).

ORDER

UPON the foregoing Stipulation of the Parties, and the Court finding good cause for the relief requested therein, and pursuant to the Court's case management and scheduling authority under Minn. R. Civ. P. 16.02 and 16.03,

IT IS HEREBY ORDERED as follows:

1. The Parties' Stipulation is APPROVED and incorporated herein by reference as if fully set forth.

2. [________________________________] (Restate Term 1 in operative order language)

3. [________________________________] (Restate Term 2 in operative order language)

4. [________________________________] (Restate Term 3 in operative order language)

5. [________________________________] (Additional terms as needed)

IT IS FURTHER ORDERED that, except as specifically modified herein, the Case Management Order and Scheduling Order dated [__/__/____] shall remain in full force and effect and all prior orders of this Court are unaffected.

IT IS FURTHER ORDERED that a copy of this Order shall be served by the Court Administrator upon all counsel of record through the eFS electronic notification system, or by such other method as is appropriate for self-represented parties.

BY THE COURT:

_______________________________________________

Honorable [________________________________]

Judge of District Court, [________________________________] Judicial District

County of [________________________________], State of Minnesota

Dated: [__/__/____]

SECTION 6: CERTIFICATE OF SERVICE

I hereby certify that on [__/__/____], I served a true and correct copy of the foregoing Stipulation and [Proposed] Order upon all counsel of record and parties in this action via the method(s) checked below, in accordance with Minn. R. Civ. P. 5.02:

☐ Minnesota eFS (Electronic Filing and Service) — Filed and served via the Minnesota Judicial Branch eFS system, which provided service on all attorneys registered with eFS at their registered e-mail addresses in accordance with Minn. R. Civ. P. 5.02.

☐ First-Class U.S. Mail — A true and correct copy was placed in the United States mail, first-class postage prepaid, addressed to the following parties not registered with eFS:

☐ Hand Delivery / Personal Service — A true and correct copy was delivered by hand to the following:

☐ Electronic Mail (by written agreement of all parties) — A true and correct copy was sent via e-mail by written agreement of counsel to:

☐ Facsimile — A true and correct copy was transmitted by facsimile to:

_______________________________________________

[________________________________]

Minnesota Attorney Registration No. [________________________________]

Counsel for [________________________________]

SECTION 7: FILING AND PRACTICE CHECKLIST

Pre-Filing

☐ Obtain written confirmation of consent from all parties or their counsel

☐ Identify the controlling Minnesota Rule(s) of Civil Procedure applicable to the stipulation (e.g., Minn. R. Civ. P. 29, 41.01, 56)

☐ Review the assigned judge's chambers rules and the applicable judicial district's local rules and general orders

☐ Determine whether the case is designated as Expedited, Standard, or Complex track under the district's Case Management Order

☐ Confirm whether the proposed relief affects the trial date; if so, determine whether a separate motion or hearing is required

☐ Confirm eFS registration and account status for all filing attorneys

☐ Draft the stipulation with specificity as to each term agreed upon

☐ Prepare a proposed order as a separate document in compliance with Minn. Gen. R. Prac. 14

☐ Confirm whether the assigned judge requires a Word version of the proposed order submitted to chambers by email

Filing

☐ Access the Minnesota eFS system at https://efsfilingportal.courts.state.mn.us and select the correct case and filing type

☐ Upload the Stipulation as the lead document in PDF format

☐ Attach the Proposed Order as a separate exhibit

☐ Attach all referenced exhibits, prior scheduling orders, or supporting materials

☐ Submit a Word version of the proposed order to chambers if required by the assigned judge

☐ Confirm successful submission and retain the eFS confirmation number

Post-Filing

☐ Verify that eFS electronic notification was transmitted to all registered counsel of record

☐ Serve any parties not registered with eFS by mail, hand delivery, or other method permitted under Minn. R. Civ. P. 5.02

☐ Calendar all new deadlines established by the stipulation

☐ Monitor the docket for entry of the Order

☐ Update the case management schedule and internal calendars upon entry of the Order

SECTION 8: MINNESOTA-SPECIFIC PRACTICE NOTES

Minnesota eFS Electronic Filing System

The Minnesota Judicial Branch eFiling system (eFS) is the statewide electronic filing platform, accessible at https://efsfilingportal.courts.state.mn.us. Attorneys are generally required to file through eFS in civil cases. The system provides automatic electronic service on all attorneys registered for the case. Self-represented parties may file conventionally through the court administrator's office. Documents must be submitted in PDF format. Confirmation numbers should be retained for each filing.

Minn. R. Civ. P. 16.02 and 16.03 — Case Management and Pretrial

Under Minn. R. Civ. P. 16.02, in all complex cases the assigned judge shall enter a Case Management Order and Scheduling Order addressing discovery timelines, motion deadlines, and trial date. The order controls the subsequent course of the action and may be modified only to prevent manifest injustice. Attorneys participating in any pretrial conference must have authority to enter into stipulations and to make admissions per Minn. R. Civ. P. 16.03.

Minn. R. Civ. P. 29 — Discovery Stipulations

Under Minn. R. Civ. P. 29, the parties may by stipulation modify discovery procedures, including the time and manner of depositions. However, stipulations that would interfere with any time set for completion of discovery, for hearing of a motion, or for trial may only be made with court approval. Stipulations modifying discovery deadlines in the operative Scheduling Order therefore require this court order.

Minn. R. Civ. P. 26.01(b) — Expert Disclosures

Expert witness disclosures in Minnesota civil actions are governed by Minn. R. Civ. P. 26.01(b), which requires disclosure of the identity, opinions, and qualifications of each expert witness expected to be called at trial. Stipulations modifying expert disclosure deadlines should expressly cite this rule and identify the specific deadline being modified.

Minn. R. Civ. P. 41.01 — Voluntary Dismissal

Under Minn. R. Civ. P. 41.01, an action may be dismissed without court order by filing a notice of dismissal before the adverse party serves an answer or motion for summary judgment, or by filing a stipulation of dismissal signed by all parties who have appeared. After an answer or summary judgment motion has been served, dismissal requires either court order or a signed stipulation of all appearing parties.

Minn. Gen. R. Prac. 14 — Proposed Orders

Minnesota General Rule of Practice 14 requires that when filing a motion or stipulation, the moving party must include a proposed order in both PDF and Word format. The Word version must be submitted directly to the assigned judge's chambers per the method specified by that judge (typically by email to the chambers address listed on the court's website). Failure to provide a Word version may result in delay in the court's consideration of the stipulation.

Minn. Gen. R. Prac. 115.04 — Motion Scheduling

Under Minn. Gen. R. Prac. 115.04, motions in district court proceedings are scheduled by the court administrator, and counsel must comply with the district's specific scheduling procedures. For uncontested stipulations, many districts allow submission directly to the judge for approval without a hearing, provided the stipulation is accompanied by a proposed order.

Minn. Stat. § 484.73 — Civil Mediation

Minnesota's Civil Mediation Act, Minn. Stat. § 484.73, encourages the use of alternative dispute resolution in civil matters. Courts may order mediation as part of case management. Stipulations scheduling or addressing mediation should reference this statute and any applicable district ADR program requirements.

Sources and References

• Minnesota Rules of Civil Procedure (complete text): Minnesota Office of the Revisor of Statutes
• Minnesota General Rules of Practice for District Courts: Minnesota Courts
• Minnesota eFS Electronic Filing System: Minnesota Judicial Branch
• Fourth Judicial District (Hennepin County) Local Information: www.mncourts.gov/district/4
• Second Judicial District (Ramsey County) Local Information: www.mncourts.gov/district/2
• Minn. R. Civ. P. 16 (Case Management): Minnesota Rules of Civil Procedure, Rule 16
• Minn. R. Civ. P. 29 (Discovery Stipulations): Minnesota Rules of Civil Procedure, Rule 29
• Minn. R. Civ. P. 41.01 (Voluntary Dismissal): Minnesota Rules of Civil Procedure, Rule 41.01
• Minnesota Civil Mediation Act: Minn. Stat. § 484.73

This template is provided for informational purposes only and does not constitute legal advice. Consult a licensed attorney before use. Laws and court rules change frequently; verify all citations and local requirements before filing.