State Court Stipulation and [Proposed] Order (General Civil) - Virginia
STIPULATION AND [PROPOSED] ORDER
(Virginia Circuit Court – General Civil Matters)
NOT EFFECTIVE UNTIL ENTERED. The parties may agree to proposed terms, but only an order entered by the court changes a scheduling order or imposes court-ordered relief.
1. CAPTION
VIRGINIA: IN THE CIRCUIT COURT OF [COUNTY/CITY]
| Party | Role |
|---|---|
| [PLAINTIFF NAME], | Plaintiff |
| v. | |
| [DEFENDANT NAME], | Defendant |
Case No.: [CASE NUMBER]
| Filing-party information | Entry |
|---|---|
| Attorney or self-represented party | [NAME] |
| VSB number | [NUMBER] |
| Firm | [LAW FIRM NAME] |
| Address | [STREET ADDRESS], [CITY], Virginia [ZIP] |
| Telephone / facsimile | [TEL] / [FAX] |
| [EMAIL] | |
| Counsel for | [PARTY NAME] |
2. STIPULATION
The Parties, by counsel, stipulate and agree as follows:
-
Background.
- The Court entered a Scheduling Order on [DATE].
- [Summarize current deadlines, discovery status, and any scheduled hearings/trial dates]. -
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]. -
Authority and Case-Specific Basis. If this filing seeks a change to a pretrial scheduling order, the parties submit the agreed proposal for court approval under Va. Sup. Ct. R. 1:18. The requested change is supported by the following facts and is consistent with efficient and orderly case administration: [JUSTIFICATION]. If the request concerns another subject, replace this sentence with the actual rule, statute, prior order, or other authority.
-
Reservation. Except as expressly modified herein, the Scheduling Order remains in effect.
-
Request for Order. The Parties respectfully request that the Court approve this stipulation and enter the proposed order below.
3. SIGNATURES
SEEN AND AGREED:
| Counsel for [PLAINTIFF] | Counsel for [DEFENDANT] |
|---|---|
| [LAW FIRM NAME] | [SECOND LAW FIRM NAME] |
| By: ________________________________ | By: ________________________________ |
| [ATTORNEY NAME] | [ATTORNEY NAME] |
| VSB No. [NUMBER] | VSB No. [NUMBER] |
| Date: ___________ | Date: ___________ |
4. [PROPOSED] ORDER
Upon consideration of the Parties’ Stipulation and for good cause shown, it is ORDERED that:
- The Stipulation is APPROVED and incorporated herein.
- [ORDERED TERM 1].
- [ORDERED TERM 2].
- [ORDERED TERM 3 / ADDITIONAL RELIEF].
All other provisions of the Scheduling Order dated [DATE] shall remain in effect.
ENTERED this ____ day of ______________, 20__.
[________________________________]
Judge
5. CERTIFICATE OF SERVICE
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]
E-mail service basis: ☐ electronically filed case governed by Rule 1:17 ☐ written consent signed by the person served ☐ not served by e-mail
If ordinary e-mail was used: This certificate of counsel was separately ☐ mailed ☐ faxed to each counsel of record on or before the service date.
6. FILING & SERVICE CHECKLIST
- Identify the actual authority. Rule 1:13 governs endorsement or notice of presenting a draft order; it is not substantive authority for the requested relief. Use Rule 1:18 for an agreed pretrial scheduling order and cite the correct case-specific authority for any other request.
- Obtain endorsements or give presentation notice. Under Rule 1:13, counsel of record must endorse the draft, or non-endorsing counsel must receive the draft and reasonable notice of when and where it will be presented. The court may modify or dispense with compliance.
- Check local rules and the existing order. Rule 1:15 makes counsel responsible for ascertaining and following the selected circuit's local rules. Confirm chambers procedures, hearing or praecipe requirements, and whether an editable courtesy copy is requested.
- Use e-filing only where applicable. Rule 1:17 applies in a court with an established electronic filing system. In an electronically filed case, follow the applicable portal; the statewide rule identifies PDF as the filing format, though a court may separately request an editable courtesy copy.
- Serve under Rule 1:12. Serve each counsel of record on or before filing and state the date and method. Ordinary e-mail service requires Rule 1:17 to apply or written signed consent; if the sender learns the e-mail did not arrive, service is ineffective.
7. OFFICIAL SOURCE
[END OF DOCUMENT]
About this template
- Last updated
- September 8, 2026
- Jurisdiction
- Virginia
- Category
- Litigation & Court Documents
Legal authority
- Va. Sup. Ct. R. 1:12
- Va. Sup. Ct. R. 1:13
- Va. Sup. Ct. R. 1:15
- Va. Sup. Ct. R. 1:17
- Va. Sup. Ct. R. 1:18
These are the filings that drive a lawsuit through the system: complaints, answers, motions, briefs, discovery requests and responses, and post-judgment papers. Each has its own format requirements under federal and state procedural rules, and each has a deadline that cannot be missed without consequences. Clean, procedurally correct filings move a case forward; sloppy ones invite motions to strike, amended responses, and avoidable delays.
Not legal advice
This template is provided for informational purposes. We recommend having an attorney review any legal document before signing, especially for high-value or complex matters.
Checked against the law it cites
The statutes this template relies on are listed under Legal authority.
Va. Sup. Ct. R. 1:13 (checked August 20, 2026): "Drafts of orders and decrees must be endorsed by counsel of record, or reasonable notice of the time and place of presenting such drafts together with copies thereof must be served pursuant to Rule 1:12 upon all counsel of record who have not endorsed them."
Va. Sup. Ct. R. 1:12 (checked August 20, 2026): "All pleadings, motions and other papers served after the initial process in an action and not required to be served otherwise and requests for subpoenas duces tecum must be served by delivering, dispatching by commercial delivery service for same-day or next-day delivery, transmitting by facsimile, transmitting by electronic mail when Rule 1:17 so provides or when consented to in writing signed by the person to be served, or by mailing, a copy to each counsel of record on or before the day of filing."
Va. Sup. Ct. R. 1:12 (email-service certificate) (checked September 8, 2026): "When service is made by electronic mail, a certificate of counsel that the document was served by electronic mail must be served by mail or transmitted by facsimile to each counsel of record on or before the day of service."
Va. Sup. Ct. R. 1:15 (checked August 20, 2026): "whenever an attorney becomes counsel of record in any proceedings in a circuit court in which he does not regularly practice, it is his responsibility to ascertain the rules of that court and abide thereby."
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