STIPULATION AND [PROPOSED] ORDER

(Virginia Circuit Court – General Civil Matters)

[// GUIDANCE: Provide a concise statement establishing good cause and referencing any existing scheduling order. Confirm that the requested changes comply with the circuit’s differentiated case management plan.]

1. CAPTION

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VIRGINIA:
IN THE CIRCUIT COURT OF [COUNTY/CITY]

[PLAINTIFF NAME],
Plaintiff,

v. Case No. [CASE NUMBER]

[DEFENDANT NAME],
Defendant.

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

2. STIPULATION

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

1. Background.
   - The Court entered a Scheduling Order on [DATE].
   - [Summarize current deadlines, discovery status, and any scheduled hearings/trial dates].

2. Agreed Adjustments.
   a. [TERM 1: e.g., “All discovery shall be completed by [DATE].”]
   b. [TERM 2: e.g., “Expert disclosures pursuant to Rule 4:1(b)(4) shall be exchanged by [DATE].”]
   c. [TERM 3: e.g., “Dispositive motions shall be filed by [DATE] and set for hearing no later than [DATE].”]
   d. [Additional terms as needed].

3. Authority. This stipulation is made pursuant to Va. Sup. Ct. R. 1:9 and 4:13, and is supported by good cause because [JUSTIFICATION].

4. Reservation. Except as expressly modified herein, the Scheduling Order remains 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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SEEN AND AGREED:

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

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

[// GUIDANCE: Include signatures for all counsel. Electronic signatures (“/s/ Name”) are accepted in VJEFS filings.]

4. [PROPOSED] ORDER

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Upon consideration of the Parties’ Stipulation and for good cause shown, it is 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 Scheduling Order dated [DATE] shall remain in effect.

ENTERED this _ day of _____, 20__.

Judge
[// GUIDANCE: Provide the judge’s typed name beneath the signature line if required by the local circuit.]

5. CERTIFICATE OF SERVICE

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I certify that on [DATE], I filed the foregoing via [VJEFS / HAND DELIVERY] and served all counsel of record in accordance with Rule 1:12 by [E-MAIL / U.S. MAIL]. Service was made to:

[NAME]
[ADDRESS / EMAIL]

[NAME OF DECLARANT]
VSB No. [NUMBER]
[// GUIDANCE: Update service method to reflect actual delivery.]

6. FILING & SERVICE CHECKLIST

• Cite Virginia authority. Reference Va. Sup. Ct. R. 1:13, 1:15, 4:13, or Va. Code §§ 8.01-4, 8.01-334 governing stipulated orders, and address any local case scheduling order.
• Follow VJEFS/local filing procedures. File through Virginia’s Judicial Electronic Filing System when available, select the proper document type, and submit an editable Word order if required by the circuit court.
• Serve per Rule 1:12. Provide service by email, mail, or hand delivery consistent with Rule 1:12 and document the method in the certificate.