Legal Stipulated Motion

LEGAL STIPULATED MOTION

Court:   County:

Case Number:   Judge:

Plaintiff:   Defendant:

RECITALS

WHEREAS, the parties identified above have been engaged in litigation in the captioned matter and have met and conferred regarding scheduling and discovery disputes arising from the actions and filings in this case; and

WHEREAS, counsel for Plaintiff and counsel for Defendant have agreed to the terms set forth in this Stipulated Motion in order to narrow issues for the Court, avoid unnecessary hearing time, and conserve party and judicial resources; and

WHEREAS, the parties desire that the Court enter an order reflecting the stipulation described herein and granting the relief set forth below.

NOW, THEREFORE

The parties jointly move the Court for an order approving the stipulation and granting the relief described in this Motion. The parties represent to the Court that the following facts are true and that the requested relief is reasonable and necessary under the circumstances.

1. Relief Requested

The parties stipulate and jointly request the following relief (check all that apply):

Extend deadline for filing responsive pleadings Continue scheduled hearing

If continuing a hearing, current hearing date: ,

Proposed new date or deadline (if applicable): ,

Other Specify other relief:

2. Stipulated Facts

The parties stipulate to the following matters of fact for the limited purpose of this Motion and any related scheduling order. The stipulation is not an admission for any other purpose:

3. Procedural Background

The following summarizes relevant prior procedural events in this case:

4. Legal BASIS FOR RELIEF

The parties submit that good cause exists to grant the requested relief. The delay or continuance is reasonable, will not unduly prejudice any party, and will further the interests of justice by allowing the parties to complete necessary efforts to narrow issues or complete discovery. The parties request the Court exercise its inherent authority and applicable procedural rules to enter the stipulated order requested herein.

5. PROPOSED ORDER

The parties propose that the Court enter an order adopting the stipulations and granting the relief requested. A proposed order reflecting the agreed-upon relief shall be lodged concurrently with this Motion or submitted separately by electronic filing as appropriate.

6. CERTIFICATION OF COUNSEL

Counsel for the parties hereby certify that they have conferred in good faith regarding the matters addressed in this Motion and that the stipulation reflected herein accurately represents the agreement reached between the parties. Counsel further certify that the relief requested is not sought for purposes of delay or harassment.

7. NOTICES

Service Contact for Plaintiff:

Service Contact for Defendant:

8. CERTIFICATE OF SERVICE

I certify that on the date below I served a true and correct copy of this Stipulated Motion and any accompanying proposed order upon the parties or counsel of record by the method(s) indicated.

Method of Service: Mail Email Hand Delivery

9. MISCELLANEOUS PROVISIONS

Governing Law: This Stipulated Motion and any order entered hereunder shall be governed by the substantive and procedural law of the jurisdiction in which the Court presides.

Entire Agreement: This document contains the complete and final agreement of the parties with respect to the subject matter hereof. Any prior agreements, whether written or oral, are superseded by this Stipulated Motion to the extent they are inconsistent.

Severability: If any provision of this Stipulated Motion is held to be invalid, illegal, or unenforceable, the remaining provisions shall remain in full force and effect.

Amendments and Waiver: Any amendment to this Stipulated Motion must be in writing and signed by counsel for all parties. No failure or delay by any party in exercising any right shall operate as a waiver of that right.

Counterparts: This Stipulated Motion may be executed in counterparts, each of which shall be deemed an original, and all of which together shall constitute one and the same instrument.

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