STIPULATION AND [PROPOSED] ORDER

(Mississippi State Court – General Civil Matters)

[// GUIDANCE: Provide a statement of good cause referencing the operative scheduling order. Note whether the requested relief affects any statutory deadlines.]

1. CAPTION

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

Attorney for [PARTY NAME]

IN THE [CIRCUIT/CHANCERY] COURT OF [COUNTY] COUNTY, MISSISSIPPI

[PLAINTIFF NAME],
Plaintiff,

v. Civil Action No. [CASE NUMBER]

[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 pending deadlines].

2. Agreed Terms.
   a. [TERM 1: e.g., “The discovery deadline is extended to [DATE], without impacting the current trial setting.”]
   b. [TERM 2: e.g., “Expert disclosures pursuant to Miss. R. Civ. P. 26(b)(4) shall be exchanged by [DATE].”]
   c. [TERM 3: e.g., “The dispositive motion deadline is extended to [DATE].”]
   d. [Additional terms as necessary].

3. Authority. This stipulation is submitted under Miss. R. Civ. P. 6(b) and 16(b)(4), and is supported by good cause because [JUSTIFICATION].

4. Reservation. Except as expressly modified herein, all prior orders remain in full force and effect.

5. Request for Order. The Parties jointly 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]
MSB No. [NUMBER]
Counsel for [PLAINTIFF]

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

[// GUIDANCE: Include additional signatures for all parties. MEC accepts “/s/ Name” electronic signatures.]

4. [PROPOSED] ORDER

text
UPON CONSIDERATION of the Parties’ Stipulation and the record, the Court finds good cause and 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 Scheduling Order dated [DATE] remain in effect.

SO ORDERED this _ day of _____, 20__.

[NAME OF JUDGE]
[Title], [COUNTY] County, Mississippi
[// GUIDANCE: Insert the judge’s title (Circuit Judge/Chancellor) as appropriate.]

5. CERTIFICATE OF SERVICE

text
I certify that on [DATE], I electronically filed the foregoing with the MEC system, which sent notice to all registered counsel. Copies were served by [MAIL / EMAIL] on any parties not registered with MEC:

[NAME]
[ADDRESS / EMAIL]

[NAME OF DECLARANT]
MSB No. [NUMBER]
[// GUIDANCE: Update service methods to reflect actual delivery in compliance with Miss. R. Civ. P. 5(b).]

6. FILING & SERVICE CHECKLIST

• Reference Mississippi authority. Cite the Mississippi Rules of Civil Procedure supporting the stipulation (e.g., Rules 6(b), 16, 29, 41) and any standing orders in the circuit or chancery court.
• Use MEC properly. Select the correct docket event in the Mississippi Electronic Courts system, attach supporting exhibits, and provide a Word version of the proposed order if chambers requests it.
• Serve non-MEC participants. Deliver service by mail or hand delivery to litigants not registered in MEC and note compliance with Miss. R. Civ. P. 5(b).