STIPULATION AND [PROPOSED] ORDER

(Missouri Circuit Court – General Civil Matters)

[// GUIDANCE: Provide a concise explanation of good cause. Reference the controlling Case Management Order and identify which paragraphs are modified.]

1. CAPTION

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

Attorney for [PARTY NAME]

IN THE CIRCUIT COURT OF [COUNTY] COUNTY, MISSOURI
[DIVISION]

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 Case Management Order on [DATE].
   - [Summarize relevant deadlines and procedural history].

2. Agreed Terms.
   a. [TERM 1: e.g., “All discovery shall be completed by [DATE], extending the current deadline by [NUMBER] days.”]
   b. [TERM 2: e.g., “Expert disclosures pursuant to Mo. Sup. Ct. R. 56.01(b)(4) shall be exchanged by [DATE].”]
   c. [TERM 3: e.g., “The dispositive motion deadline is extended to [DATE], with hearings to be scheduled through Division [#].”]
   d. [Additional terms as necessary].

3. Authority. This stipulation is submitted under Mo. Sup. Ct. R. 44.01(b), 44.02, and the Court’s Case Management Order ¶ [NUMBER], and is supported by good cause because [JUSTIFICATION].

4. Reservation. Except as expressly modified, the Case Management Order remains 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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DATED: ______

[LAW FIRM NAME]
By: ________
[ATTORNEY NAME]
Mo. Bar No. [NUMBER]
Counsel for [PLAINTIFF]

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

[// GUIDANCE: Include signature lines for all parties. Electronic signatures (“/s/ Name”) are accepted via Case.net.]

4. [PROPOSED] ORDER

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The Court, having reviewed the Parties’ Stipulation and finding good cause, hereby ORDERS:

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] remain in effect.

SO ORDERED this _ day of _____, 20__.

Judge of the Circuit Court
Division [DIVISION]
[// GUIDANCE: Insert the judge’s typed name beneath the signature if required.]

5. CERTIFICATE OF SERVICE

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I certify that on [DATE], I filed the foregoing via the Missouri eFiling system, which served all registered counsel. Copies were served by [MAIL / EMAIL] on any parties not registered for electronic service:

[NAME]
[ADDRESS / EMAIL]

[NAME OF DECLARANT]
Mo. Bar No. [NUMBER]
[// GUIDANCE: Update service information to reflect actual method pursuant to Mo. Sup. Ct. R. 43.01.]

6. FILING & SERVICE CHECKLIST

• Cite Missouri authority. Reference Missouri Supreme Court Rules (e.g., Rules 44.01, 50.01, 51.05, 56.01) or local circuit rules supporting the stipulation.
• Use the statewide eFiling system correctly. Choose the proper document category, attach exhibits, and provide an editable proposed order if required by the judge’s division.
• Serve outside eFiling. Mail or personally serve litigants not registered in the Missouri eFiling system and detail compliance with Mo. Sup. Ct. R. 43.01.