Dear Hate140Delay,
If you have already recd your GC then go with this updated one:
"Plaintiff, proceeding pro se, and defendants, by and through their attorneys of record, hereby stipulate, subject to the approval of the court, to dismissal of the action because the petitioner's I-485 application for adjustment of status has been adjudicated. The Plaintiff's AOS application was long delayed for ### of days or months, which is now processed as a result of filing his/her complaint with this honorable court. Each of the parties shall bear their own costs and fees."
If you have not physically recd your GC and has been verbally or in written form informed that it is approved then go for this updated format:
"Plaintiff, proceeding pro se, and defendants, by and through their attorneys of record, hereby stipulate, subject to the approval of the court, to dismiss without prejudice the action because the petitioner's I-485 application for adjustment of status as per USCIS (Exhibit Notice of Approval if any) has been adjudicated. The Plaintiff's AOS application was long delayed for ### of days or months, which is now processed as a result of filing his/her complaint with this honorable court. Each of the parties shall bear their own costs and fees."
I dont know if you have seen my old posts but we in this form long time ago discussed to state about some kind of indication in the dismissal part which will help Pro Se filers after us... this way not only they can refer to our cases but also feel confident about filing Pro Se complaints.
I hope this help...