STIPULATION AND [PROPOSED] ORDER

(South Carolina Court of Common Pleas – General Civil Matters)

[// GUIDANCE: Provide good cause and reference the operative scheduling order. Note whether the request affects roster management or ADR deadlines (Rule 5 SCRADR).]

1. CAPTION

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STATE OF SOUTH CAROLINA
IN THE COURT OF COMMON PLEAS
[COUNTY] COUNTY
Case No. [CASE NUMBER]

[PLAINTIFF NAME],
Plaintiff,

v.

[DEFENDANT NAME],
Defendant.

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

2. STIPULATION

The Parties stipulate and agree as follows:

1. Background.
   - The Court entered a Scheduling Order on [DATE].
   - [Summarize discovery progress, pending motions, and scheduled roster calls or trial terms].

2. Stipulated Adjustments.
   a. [TERM 1: e.g., “All discovery shall be completed by [DATE].”]
   b. [TERM 2: e.g., “Expert disclosures pursuant to SCRCP 26(b)(4) shall be exchanged by [DATE].”]
   c. [TERM 3: e.g., “Motions for summary judgment shall be filed by [DATE].”]
   d. [Additional terms as needed].

3. Authority. This stipulation is submitted pursuant to SCRCP 6(b) and 16, and is supported by good cause because [JUSTIFICATION].

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

5. Request for Order. The Parties respectfully 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]
SC Bar No. [NUMBER]
Attorney for [PLAINTIFF]

[SECOND LAW FIRM NAME]
By: ________
[ATTORNEY NAME]
SC Bar No. [NUMBER]
Attorney for [DEFENDANT]

[// GUIDANCE: Include additional counsel signatures. Electronic signatures (“/s/ Name”) are accepted in the statewide e-filing system.]

4. [PROPOSED] ORDER

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IT IS HEREBY ORDERED that the foregoing Stipulation is APPROVED and incorporated herein. The Court further ORDERS:

1. [ORDERED TERM 1].
2. [ORDERED TERM 2].
3. [ORDERED TERM 3 / ADDITIONAL RELIEF].

All other provisions of the Scheduling Order dated [DATE] remain in effect.

AND IT IS SO ORDERED.

Circuit Court Judge
Date: ________
[// GUIDANCE: Insert the judge’s printed name beneath the signature if required by local administrative order.]

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 / EMAIL / U.S. MAIL] consistent with SCRCP 5(b). Service was made to:

[NAME]
[ADDRESS / EMAIL]

[NAME OF DECLARANT]
SC Bar No. [NUMBER]
[// GUIDANCE: Update service method to reflect actual practice.]

6. FILING & SERVICE CHECKLIST

• Cite South Carolina authority. Reference SCRCP 6(b), 16, 29, 41, or relevant administrative orders authorizing the stipulated relief.
• Follow SCE-File or local filing procedures. File electronically via the statewide system (where implemented) or deliver paper filings as required, and submit an editable proposed order if directed by chambers.
• Serve per SCRCP 5(b). Provide mail, hand delivery, or electronic service consistent with Rule 5(b) and document the method in the certificate.