STIPULATION AND [PROPOSED] ORDER

(New Jersey Superior Court – General Civil Matters)

[// GUIDANCE: Provide a statement of good cause referencing the Track assignment and current case management order. If seeking an extension beyond the discovery end date, include reasons satisfying R. 4:24-1(c).]

1. CAPTION

text
[ATTORNEY OR SELF-REPRESENTED PARTY]
Name: [NAME] (Attorney ID [NUMBER])
Firm: [LAW FIRM NAME]
Address: [STREET ADDRESS]
City, State ZIP: [CITY], New Jersey [ZIP]
Telephone: [TEL] | Facsimile: [FAX]
E-Mail: [EMAIL]

Attorney for [PARTY NAME]

SUPERIOR COURT OF NEW JERSEY
LAW DIVISION: [COUNTY] COUNTY
DOCKET NO. [CASE NUMBER]
Civil Action

[PLAINTIFF NAME],
Plaintiff,

v.

[DEFENDANT NAME],
Defendant.

2. STIPULATION

The Parties, through counsel, stipulate and agree as follows:

1. Background.
   - This matter is assigned to Track [TRACK] under the Case Management Order dated [DATE].
   - [Summarize current deadlines, discovery status, or scheduled events].

2. Stipulated Terms.
   a. [TERM 1: e.g., “Discovery end date is extended to [DATE], with depositions to be completed by [DATE].”]
   b. [TERM 2: e.g., “Expert reports pursuant to R. 4:17-4(e) shall be exchanged by [DATE], and responsive reports by [DATE].”]
   c. [TERM 3: e.g., “Dispositive motions under R. 4:46 shall be filed by [DATE] and returnable on the first available motion day thereafter.”]
   d. [Additional terms as needed].

3. Authority. This stipulation is made pursuant to R. 1:6-2 and R. 4:24-1, and is supported by good cause because [JUSTIFICATION].

4. Reservation. Except as modified herein, the existing Case Management Order remains in full force and effect.

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

3. SIGNATURES

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Dated: ______

[LAW FIRM NAME]
By: ________
[ATTORNEY NAME]
Attorney ID [NUMBER]
Counsel for [PLAINTIFF]

[SECOND LAW FIRM NAME]
By: ________
[ATTORNEY NAME]
Attorney ID [NUMBER]
Counsel for [DEFENDANT]

[// GUIDANCE: Include additional counsel. eCourts accepts “/s/ Name” electronic signatures consistent with R. 1:5-6(c)(1)(B).]

4. [PROPOSED] ORDER

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This matter having been opened to the Court by consent of the Parties and for good cause shown, IT IS on this _ day of _____, 20__, 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.

Hon. [JUDGE NAME], J.S.C.
[// GUIDANCE: Include “Opposed / Unopposed” checkboxes or attach form orders if required by the vicinage.]

5. CERTIFICATION OF SERVICE

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I certify that on [DATE], I filed the foregoing via eCourts (or served by [METHOD]) and thereby served all counsel of record pursuant to R. 1:5-2. Copies were served on non-eCourts participants as follows:

[NAME]
[ADDRESS / EMAIL]

[NAME OF DECLARANT]
Attorney ID [NUMBER]
[// GUIDANCE: Update service description to reflect actual method and compliance with R. 1:5-2.]

6. FILING & SERVICE CHECKLIST

• Cite New Jersey authority. Reference applicable New Jersey Court Rules (e.g., R. 1:6-2, 4:24-1(c), 4:36-3, 4:42-1) or case management orders permitting the stipulated relief.
• Utilize eCourts effectively. Select the proper case document type, attach supporting materials, and provide a Word version of the proposed order if the vicinage requires editable submissions.
• Serve non-eCourts parties. Deliver service by mail or hand delivery to individuals not on eCourts and document compliance with R. 1:5-2 and R. 1:5-3.