STIPULATION AND [PROPOSED] ORDER

(Pennsylvania Court of Common Pleas – General Civil Matters)

[// GUIDANCE: Provide a summary showing good cause and compliance with any case management orders. Include information about upcoming conferences (e.g., Case Management, Pretrial) impacted by the changes.]

1. CAPTION

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IN THE COURT OF COMMON PLEAS OF [COUNTY] COUNTY, PENNSYLVANIA
[CIVIL / COMMERCE / ARBITRATION] DIVISION

[PLAINTIFF NAME], : No. [DOCKET NUMBER]
:
Plaintiff :
:
v. : STIPULATION AND [PROPOSED] ORDER
:
[DEFENDANT NAME], :
Defendant :

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

2. STIPULATION

The Parties stipulate and agree as follows:

1. Background.
   - A Case Management Order dated [DATE] presently governs this action.
   - [Summarize discovery status, pending motions, and scheduled conferences or trial dates].

2. Stipulated Adjustments.
   a. [TERM 1: e.g., “Fact discovery is extended to [DATE].”]
   b. [TERM 2: e.g., “Expert reports pursuant to Pa.R.C.P. 4003.5 shall be served by [DATE].”]
   c. [TERM 3: e.g., “Dispositive motions shall be filed by [DATE] in accordance with Pa.R.C.P. 1035.2.”]
   d. [Additional terms such as mediation deadlines or pretrial statement dates].

3. Authority and Good Cause. This stipulation is submitted pursuant to Pa.R.C.P. 208.3(a) and the Court’s Case Management Order, and is supported by good cause because [JUSTIFICATION].

4. Reservation. Except as expressly modified herein, all prior orders remain in effect and all rights are preserved.

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

3. SIGNATURES

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Respectfully submitted,

[LAW FIRM NAME]
By: _____
[ATTORNEY NAME]
Pa. I.D. No. [NUMBER]
Counsel for [PLAINTIFF]
Date: __

[SECOND LAW FIRM NAME]
By: _____
[ATTORNEY NAME]
Pa. I.D. No. [NUMBER]
Counsel for [DEFENDANT]
Date: __

[// GUIDANCE: Include additional counsel signatures. Electronic signatures (“/s/ Name”) are acceptable in Pennsylvania e-filing systems.]

4. [PROPOSED] ORDER

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AND NOW, this _ day of _____, 20__, upon consideration of the foregoing Stipulation, it is hereby ORDERED and DECREED 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 full force and effect.

BY THE COURT:

J.
[// GUIDANCE: Insert judge’s full name and add distribution list if required by local rules.]

5. CERTIFICATE OF SERVICE

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I certify that on [DATE], I served the foregoing Stipulation and [Proposed] Order upon all counsel of record via [E-FILING / FIRST-CLASS MAIL / EMAIL] in accordance with Pa.R.C.P. 440. Service was made to:

[NAME]
[ADDRESS / EMAIL]

[NAME OF DECLARANT]
Pa. I.D. No. [NUMBER]
[// GUIDANCE: Update the service description to match actual delivery.]

6. FILING & SERVICE CHECKLIST

• Cite Pennsylvania authority. Reference Pa.R.C.P. 190, 212.2, 213, 229, or applicable local rules that authorize the stipulation and confirm compliance with any case management order.
• Follow county filing practices. Use PACFile or the county e-filing system when available, select the correct document type, and provide a Word version of the proposed order if required by chambers.
• Serve per Pa.R.C.P. 440. Deliver service to parties via mail, hand delivery, or electronic means permitted by the rule and detail the method in the certificate.