STIPULATION AND [PROPOSED] ORDER

(Minnesota District Court – General Civil Matters)

[// GUIDANCE: Provide a concise statement of good cause. If the case is subject to the Expedited Litigation Track or Complex Case designation, ensure the requested adjustments comply with the applicable scheduling protocols.]

1. CAPTION

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

Attorney for [PARTY NAME]

STATE OF MINNESOTA
DISTRICT COURT
[__] JUDICIAL DISTRICT
COUNTY OF [COUNTY]

Court File No. [CASE NUMBER]
Case Type: [CASE TYPE]

[PLAINTIFF NAME],
Plaintiff,

v.

[DEFENDANT NAME],
Defendant.

2. STIPULATION

The Parties agree as follows:

1. Background.
   - The Court issued a Scheduling Order on [DATE].
   - [Summarize relevant procedural history].

2. Stipulated Terms.
   a. [TERM 1: e.g., “Fact discovery shall be completed by [DATE], extending the current deadline by [NUMBER] days.”]
   b. [TERM 2: e.g., “Expert disclosures pursuant to Minn. R. Civ. P. 26.01(b) shall be exchanged by [DATE].”]
   c. [TERM 3: e.g., “Dispositive motions shall be filed and served by [DATE], with hearings scheduled in accordance with Minn. Gen. R. Prac. 115.04.”]
   d. [Additional terms as needed].

3. Authority. This stipulation is submitted under Minn. R. Civ. P. 16.02 and 29, and is supported by good cause because [JUSTIFICATION].

4. Reservation. All other provisions of the Scheduling Order remain in effect unless expressly modified herein.

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

3. SIGNATURES

text
DATED: ______

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

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

[// GUIDANCE: Include additional counsel signatures. Electronic signatures (“/s/ Name”) are acceptable via eFS.]

4. [PROPOSED] ORDER

text
Based upon the Parties’ Stipulation and good cause appearing, IT IS 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 Scheduling Order dated [DATE] remain in effect.

BY THE COURT:

Dated: _____ _______
Judge of District Court
[// GUIDANCE: Add the judge’s typed name below the signature per local practice.]

5. CERTIFICATE OF SERVICE

text
I certify that on [DATE], the foregoing was filed via eFS, which provided service to all attorneys of record under Minn. R. Civ. P. 5.02. Copies were served by [MAIL / EMAIL] on any parties not participating in eFS:

[NAME]
[ADDRESS / EMAIL]

[NAME OF DECLARANT]
Attorney Reg. No. [NUMBER]
[// GUIDANCE: Update service details to match actual delivery method.]

6. FILING & SERVICE CHECKLIST

• Cite Minnesota authority. Reference Minn. R. Civ. P. 6.02, 16, 29, 41, or other applicable rules and note any district-wide case management orders that must be satisfied.
• Follow eFile/eServe (eFS) protocols. Select the proper filing type, include supporting documents, and, if required, email a Word version of the proposed order to chambers consistent with Minn. Gen. R. Prac. 14.
• Serve non-eFS participants. Provide mail or personal service to parties exempt from eFS and record compliance with Minn. R. Civ. P. 5.02.