Stipulation: plaintiff's damages

[insert Heading]

STIPULATION AS TO FACT AND LAW

TO THE HONORABLE JUDGE OF SAID COURT:

COME NOW, [insert Plaintiff] , Plaintiff and [insert Defendant] , Defendant, all of the parties in the above- titled and numbered lawsuit by and through their attorneys, and enter into the following stipulations as to fact and law and stipulate and agree as follows:

1. All parties to this lawsuit hereby stipulate that the Plaintiff’s total damages incurred as a result of the wrongs alleged in this lawsuit are $_____________. This figure does not include any claim that Plaintiff may or may not have for attorneys' fees, pre-judgment interest or post- judgment interest.

AGREED AND APPROVED AS TO FORM AND CONTENT:

_________________________________ ________________

[insert attorney’s info] Date

Attorney for Plaintiff

_________________________________ ________________

[insert attorney’s info] Date

Attorney for Defendant

Use Note: This form is primarily drafted for use in a commercial dispute...