Stipulation And Order In The Court Of Common Pleas Of Philadelphia County printable pdf download

Stipulation And Order In The Court Of Common Pleas Of Philadelphia County

FORM B -- STIPULATION AND ORDER

IN THE COURT OF COMMON PLEAS OF PHILADELPHIA COUNTY

FIRST JUDICIAL DISTRICT

CIVIL TRIAL DIVISION

Caption

: court term and number

STIPULATION AND ORDER

AND NOW, this __________ day of _________________, 200_, the parties, by and

through their undersigned counsel, hereby stipulate and agree as follows, subject to entry of this

Stipulation as an Order of the Court:

The parties desire a prompt and final resolution of their disputes, and to that end agree

they shall conduct themselves so as to reach such a resolution as promptly and simply as possible

consistent with this Stipulation and Order.

The parties agree to the terms of the Commerce Case management Program Protocols for

Alternative Dispute Resolution Procedure Using Three Judge Panel and Common Law

Arbitration (revised January 2008), which are incorporated herein by reference, a copy of which

is attached to this Stipulation and Order.

The parties agree to submit their claims to binding, “Common Law Arbitration,”, subject

to 42 Pa.C.S. § 7341, before ____________________________________________ [names of

Arbitrator(s)] pursuant to a binding Arbitration Agreement, a true and correct copy of which has

been provided to the Court, and subject to the terms and conditions set forth below. The terms

and conditions in this Stipulation and Order shall be controlling over the terms and conditions of

the arbitration agreement.

All discovery shall be complete on or before _______________, including, by agreement

of the parties:

i. Interrogatories numbering no more than _________, each subpart constituting a

separate interrogatory if it asks a new question;

ii. Requests for Production of Documents, numbering no more than _________;

iii. Depositions, numbering no more than ___ per party;

iv. Requests for Admissions, numbering no more than _________;

v. Expert Reports. The Expert Reports shall be served by the parties on the

following dates:

Plaintiff’s Report ________________________________

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Stipulation And Order In The Court Of Common Pleas Of Philadelphia County