STIPULATION AND [PROPOSED] ORDER

(North Carolina Superior Court – General Civil Matters)

[// GUIDANCE: Provide sufficient background demonstrating good cause. Reference the operative Case Management or Scheduling Order and identify how the requested relief impacts the trial calendar.]

1. CAPTION

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

Attorney for [PARTY NAME]

IN THE GENERAL COURT OF JUSTICE
SUPERIOR COURT DIVISION
[COUNTY] COUNTY, NORTH CAROLINA

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 pertinent deadlines and procedural history].

2. Agreed Terms.
   a. [TERM 1: e.g., “The completion deadline for fact discovery is extended to [DATE].”]
   b. [TERM 2: e.g., “Expert reports under N.C. R. Civ. P. 26(b)(4) shall be exchanged by [DATE].”]
   c. [TERM 3: e.g., “The dispositive motion deadline is extended to [DATE]; hearings shall be scheduled with the Trial Court Coordinator.”]
   d. [Additional terms as needed].

3. Authority. This stipulation is made pursuant to N.C. R. Civ. P. 6(b) and 16(b), and is supported by good cause because [JUSTIFICATION].

4. Reservation. Except as expressly modified herein, the Case Management Order remains in effect, and all rights and defenses are preserved.

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

3. SIGNATURES

text
Respectfully submitted this ___ day of __, 20.

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

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

[// GUIDANCE: Include additional signature blocks as needed. Electronic signatures “/s/ Name” are accepted via eCourts File & Serve.]

4. [PROPOSED] ORDER

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The foregoing Stipulation having been presented and good cause appearing, 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 Case Management Order dated [DATE] remain in effect.

This the _ day of _____, 20__.

Superior Court Judge Presiding
[// GUIDANCE: Insert judge’s printed name beneath the signature if required by the county’s local rule.]

5. CERTIFICATE OF SERVICE

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I certify that on [DATE], I filed the foregoing via eCourts File & Serve (or served by [METHOD]), which provides service upon all registered counsel pursuant to N.C. R. Civ. P. 5(b). Copies were served on non-registered parties as follows:

[NAME]
[ADDRESS / EMAIL]

[NAME OF DECLARANT]
N.C. State Bar No. [NUMBER]
[// GUIDANCE: Update service details consistent with local requirements.]

6. FILING & SERVICE CHECKLIST

• Cite North Carolina authority. Reference the North Carolina Rules of Civil Procedure authorizing the stipulation (e.g., Rules 6(b), 16, 26, 29, 41) and any administrative orders of the Superior Court division.
• Use eCourts File & Serve correctly. Select the proper document type, attach supporting exhibits, and supply a Word version of the proposed order if required by chambers.
• Serve non-eCourts participants. Provide mail or personal service to parties not using File & Serve and note compliance with N.C. R. Civ. P. 5(b).