STIPULATION AND [PROPOSED] ORDER

(Supreme Court of the State of New York – General Civil Matters)

[// GUIDANCE: Provide a concise statement of good cause referencing the most recent Scheduling/Preliminary Conference Order. If the matter is in the Commercial Division, attach the required form of stipulation per Rule 34.]

1. CAPTION

text
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF [COUNTY]

---------------------------------------------X
[PLAINTIFF NAME],
Plaintiff, Index No. [INDEX NUMBER]
-against-
[DEFENDANT NAME],
Defendant.
---------------------------------------------X

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

2. STIPULATION

IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned counsel, as follows:

1. Procedural Background.
   - A [Preliminary / Compliance / Trial Readiness] Conference Order was entered on [DATE].
   - [Summarize current deadlines, discovery status, and any upcoming conferences or motions].

2. Stipulated Adjustments.
   a. [TERM 1: e.g., “All depositions shall be completed on or before [DATE].”]
   b. [TERM 2: e.g., “Plaintiff shall serve expert disclosures pursuant to CPLR 3101(d) on or before [DATE]; Defendant shall serve rebuttal disclosures by [DATE].”]
   c. [TERM 3: e.g., “Dispositive motions pursuant to CPLR 3212 shall be filed and served no later than [DATE].”]
   d. [Additional terms as required by the Part Rules (e.g., mediation deadlines, note of issue filing date).]

3. Good Cause. The Parties jointly request this relief pursuant to CPLR 2004 and Uniform Rule 202.19(b) because [JUSTIFICATION].

4. Reservation of Rights. Except as expressly modified herein, the prior orders of this Court remain in effect and all rights and defenses are preserved.

5. Submission to Court. The Parties respectfully request that the Court “So Order” this stipulation.

3. SIGNATURES

text
Dated: New York, New York
__, 20

[LAW FIRM NAME]
By: ________
[ATTORNEY NAME]
Attorneys for [PARTY]

[SECOND LAW FIRM NAME]
By: ________
[ATTORNEY NAME]
Attorneys for [PARTY]

[// GUIDANCE: Include signatures for additional parties. NYSCEF filings require “/s/ Name” electronic signatures pursuant to 22 NYCRR 202.5-b(d)(3).]

4. [PROPOSED] ORDER

text
SO ORDERED:

Dated: ____, 20

Hon. [JUSTICE NAME], J.S.C.
Part [PART]
[// GUIDANCE: Provide any additional language required by the Part (e.g., future conference dates).]

5. AFFIRMATION/PROOF OF SERVICE

text
STATE OF NEW YORK )
COUNTY OF __ ) ss.:

I, [NAME OF DECLARANT], affirm under penalty of perjury that on [DATE] I served the foregoing Stipulation and [Proposed] Order upon all parties through NYSCEF, which constitutes service pursuant to CPLR 2103(b)(5). For any non-NYSCEF participants, service was made by [MAIL / EMAIL] addressed as follows:

[NAME]
[ADDRESS / EMAIL]

[NAME OF DECLARANT]
[// GUIDANCE: Modify if the Part requires a separate Affirmation of Good Faith under Uniform Rule 202.7.]

6. FILING & SERVICE CHECKLIST

• Cite New York authority. Reference the CPLR sections or Uniform Rules (e.g., CPLR 2004, 2104; 22 NYCRR §§ 202.7, 202.21) that permit the stipulated relief and comply with any Part-specific practices.
• Use NYSCEF correctly. File the stipulation under the proper document type, upload a proposed order in Word format if the Part requires editable submissions, and request judicial approval through the correct NYSCEF workflow.
• Serve non-NYSCEF parties. Provide service by mail or other authorized means to parties exempt from NYSCEF and record compliance with CPLR 2103.