STIPULATION AND [PROPOSED] ORDER

(Tennessee Circuit/Chancery Court – General Civil Matters)

[// GUIDANCE: Provide a concise explanation of good cause and reference the operative scheduling order. Address any impact on trial dates and pretrial deadlines.]

1. CAPTION

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IN THE [CIRCUIT/CHANCERY] COURT FOR [COUNTY] COUNTY, TENNESSEE

[PLAINTIFF NAME],
Plaintiff,

v. No. [CASE NUMBER]
[DIVISION]
[DEFENDANT NAME],
Defendant.

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[ATTORNEY OR SELF-REPRESENTED PARTY]
Name: [NAME] (BPR No. [NUMBER])
Firm: [LAW FIRM NAME]
Address: [STREET ADDRESS]
City, State ZIP: [CITY], Tennessee [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 current deadlines, discovery status, and upcoming hearings].

2. Agreed Terms.
   a. [TERM 1: e.g., “The discovery cutoff is extended to [DATE].”]
   b. [TERM 2: e.g., “Expert disclosures pursuant to Tenn. R. Civ. P. 26.05 shall be served by [DATE].”]
   c. [TERM 3: e.g., “Dispositive motions shall be filed by [DATE], with hearings to be scheduled through the Court.”]
   d. [Additional terms as needed].

3. Authority. This stipulation is submitted pursuant to Tenn. R. Civ. P. 6.02 and 16.01, and is supported by good cause because [JUSTIFICATION].

4. Reservation. Except as expressly modified herein, all provisions of the Scheduling Order 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]
BPR No. [NUMBER]
Attorney for [PLAINTIFF]

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

[// GUIDANCE: Include signatures for all parties. Electronic signatures (“/s/ Name”) are accepted in Tennessee e-filing.]

4. [PROPOSED] ORDER

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Upon consideration of the Parties’ Stipulation and for good cause shown, it is ORDERED:

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 Scheduling Order dated [DATE] shall remain in full force and effect.

SO ORDERED this _ day of _____, 20__.

Chancellor / Circuit Court Judge
[// GUIDANCE: Insert the judge’s printed name and division beneath the signature if required.]

5. CERTIFICATE OF SERVICE

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I certify that on [DATE], the foregoing Stipulation and [Proposed] Order was served on all counsel of record via [E-FILING / EMAIL / U.S. MAIL] in accordance with Tenn. R. Civ. P. 5.02. Service was made to:

[NAME]
[ADDRESS / EMAIL]

[NAME OF DECLARANT]
BPR No. [NUMBER]
[// GUIDANCE: Update service method to match actual practice.]

6. FILING & SERVICE CHECKLIST

• Cite Tennessee authority. Reference Tenn. R. Civ. P. 6.02, 16, 26.04, 29, 41, or applicable local rules authorizing the stipulation.
• Use eFileTN or local filing procedures. File electronically where available, select the correct document type, and provide an editable proposed order if required by the court or local practice.
• Serve per Tenn. R. Civ. P. 5.02. Provide mail, email, or personal service to parties as permitted, noting the method in the certificate with sufficient detail.