STIPULATION AND [PROPOSED] ORDER

(Vermont Superior Court, Civil Division – General Civil Matters)

[// GUIDANCE: Provide a concise good-cause statement referencing the case management order. Note whether ADR or jury draw dates are affected.]

1. CAPTION

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STATE OF VERMONT
SUPERIOR COURT
[CITY/COUNTY] UNIT
CIVIL DIVISION
Docket No. [DOCKET NUMBER]

[PLAINTIFF NAME],
Plaintiff,

v.

[DEFENDANT NAME],
Defendant.

text
[ATTORNEY OR SELF-REPRESENTED PARTY]
Name: [NAME] (Vermont Bar No. [NUMBER])
Firm: [LAW FIRM NAME]
Address: [STREET ADDRESS]
City, State ZIP: [CITY], Vermont [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 Case Management Order on [DATE].
   - [Summarize discovery status, pending motions, and scheduled hearings].

2. Agreed Adjustments.
   a. [TERM 1: e.g., “Fact discovery shall be completed by [DATE].”]
   b. [TERM 2: e.g., “Expert disclosures under V.R.C.P. 26(b)(4) shall be exchanged by [DATE].”]
   c. [TERM 3: e.g., “Dispositive motions pursuant to V.R.C.P. 56 shall be filed by [DATE].”]
   d. [Additional terms as needed].

3. Authority. This stipulation is submitted pursuant to V.R.C.P. 6(b) and 16.2, and is supported by good cause because [JUSTIFICATION].

4. Reservation. Except as expressly modified, the Case Management 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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DATED: ______

[LAW FIRM NAME]
By: ________
[ATTORNEY NAME]
Vermont Bar No. [NUMBER]
Attorney for [PLAINTIFF]

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

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

4. [PROPOSED] ORDER

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The Court, having reviewed the Parties’ Stipulation and for good cause shown, hereby ORDERS:

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 effect.

SO ORDERED at [CITY], Vermont, this _ day of _____, 20__.

Hon. [JUDGE NAME]
Superior Court Judge
[// GUIDANCE: Add the judge’s typed name beneath the signature line if required.]

5. CERTIFICATE OF SERVICE

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I certify that on [DATE], I filed the foregoing Stipulation and [Proposed] Order via the Vermont Judiciary e-filing system, which provides service on registered parties pursuant to V.R.C.P. 5(b). Copies were served by [MAIL / EMAIL] on any non-registered parties:

[NAME]
[ADDRESS / EMAIL]

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

6. FILING & SERVICE CHECKLIST

• Cite Vermont authority. Reference V.R.C.P. 6(b), 16, 29, 41, or applicable Administrative Order 44 provisions that permit the stipulation.
• Comply with Vermont e-filing procedures. File through Odyssey File & Serve (Vermont Judiciary e-filing), choose the correct filing type, and provide a Word version of the proposed order if required by chambers.
• Serve non-e-filing parties. Deliver service in accordance with V.R.C.P. 5(b) to parties not registered for e-filing and document the method in the certificate.