Sixth Judicial Circuit Court of Michigan, Oakland County Filing Timing and Cure Windows

A motion praecipe must be filed by the applicable deadline because a late praecipe will not be heard.

Praecipes are required for motions to be addressed by the Court and they MUST be filed timely. Praecipes filed late will NOT be heard.

A response not received by Monday at noon will not be considered by the court.

If a response is not received by Monday at 12:00p.m. (noon), the Court will not consider it.

When Monday is a court holiday, the response must be submitted by Friday at 4:30 p.m.

If Monday is a court holiday, responses must be submitted to the Court on Friday by 4:30p.m.

Responses are due Monday at noon; when Monday is a court holiday, they are instead due Friday at 4:30 p.m.

If a response is not received by Monday at 12:00p.m. (noon), the Court will not consider it. If Monday is a court holiday, responses must be submitted to the Court on Friday by 4:30p.m.

Jury instructions and the Verdict Form must be submitted one week before trial.

Jury instructions and the Verdict Form are due one week prior to trial.

Motions in limine must be heard no later than one week before trial, unless an issued scheduling or pretrial order sets a different time.

Motions in limine must be heard no later than one week before trial or pursuant to an issued scheduling or pretrial order.

Preliminary jury instructions are due no later than one week before the scheduled trial date.

Preliminary jury instructions must be submitted to the Court on plain paper, without citation to case law, no later than one week prior to the scheduled date of trial.

If no dispositive order is filed by the trial date, the parties must appear to place the settlement on the record, or the court may issue a dismissal order.

If no order is filed, the parties must appear on the trial date to place the settlement on the record or the court will issue a dismissal order.

A motion in limine must be filed at least two weeks before trial and heard no later than one week before trial, subject to the scheduling order.

Must be filed at least two weeks prior to the date of trial and heard no later than one week prior to the date of trial (dependent on compliance with all other scheduling order provisions).

Jury instructions and the verdict form must be submitted one week before trial.

Jury instructions and the Verdict Form are due one week prior to trial.

A motion in limine must be heard no later than one week before trial unless an issued scheduling or pretrial order provides otherwise.

Motions in limine must be heard no later than one week before trial or pursuant to an issued scheduling or pretrial order.

Preliminary jury instructions are due no later than one week before the scheduled trial date.

Preliminary jury instructions must be submitted to the Court on plain paper, without citation to case law, no later than one week prior to the scheduled date of trial.

For a civil case settled before trial, the disposition order must be filed before the trial date.

If a civil case is settled prior to trial, an order disposing of the case must be filed prior to the trial date.

Absent a final order entered by 4:30 p.m. on the preceding business day, parties must appear at the scheduled trial or face dismissal of their action.

Parties are expected to appear on the date and time set for trial if no final order has been entered by 4:30pm on the prior business day or their action will be dismissed.

Deadline

30 calendar days

All motions must be filed and heard at least 30 days before the party's scheduled final pretrial or settlement conference.

Motions may be filed during the pendency of litigation; however, all motions must be filed and heard at least thirty days before the party’s scheduled final pretrial and/or settlement conference.

Deadline

7 calendar days

The proposed motions-in-limine and jury-instructions filing deadline is at least seven days before the final pretrial or settlement conference.

At least seven days prior to the Court’s scheduled final pretrial and/or settlement conference each party to the Case must eFile a list of proposed motions in limine and proposed jury instructions.

Motions must be filed and heard at least 30 days before the final pretrial or settlement conference; later motions are waived.

However, all motions must be filed and heard at least thirty days before the party’s scheduled final pretrial and/or settlement conference. Motions not filed and heard at least 30 days prior to the final pretrial/settlement conference will be considered waived.

At least seven days before the scheduled final pretrial and/or settlement conference, each party must electronically file its proposed motions in limine and proposed jury instructions.

At least seven days prior to the Court’s scheduled final pretrial and/or settlement conference each party to the Case must efile a list of proposed motions in limine and the party’s proposed jury instructions.

A response to a motion must be received by Monday at noon during the week of the motion hearing for the court to consider it.

f. If a response to a motion is not received by Monday at noon the week of the motion hearing, it will not be considered by the Court.

When Monday is a court holiday, a motion response must be submitted to the court on Friday by 4:30 p.m.

If Monday is a court holiday, responses must be submitted to the court on Friday by 4:30 p.m.

Deadline

24 hours

The court states that it will issue a ruling within 24 hours after an emergency motion is filed.

There is a 24 hour turn around time from when the emergency motion is filed to when the Court will issue its ruling.

A motion praecipe, including an order for show cause, must be submitted at least one week before the chosen Wednesday hearing date.

Parties must praecipe motions for any Wednesday of their choice (including orders for show cause) at least one week prior to the chosen Wednesday.

Motion responses must comply with the Michigan Local Court Rules, and late responses will not be considered.

Any motion responses must be filed in accordance with the Michigan Local Court Rules. Any late filings will not be considered.

Summary-disposition motions exceeding the page limit and late filings will be rejected.

Motions which exceed the page limit will be rejected. Late filings will be rejected.

Criminal motions must be filed, noticed, and praeciped at least three weeks before trial, and late filings will not be considered.

All motions on criminal cases must be filed and heard at least three weeks prior to the scheduled trial date. Please notice and praecipe your motion(s). Late filings will not be considered.

Sentencing memoranda must be filed at least three days before sentencing.

All sentencing memoranda must be filed at least three days prior to sentencing.

Motions in limine must be filed and praeciped 30 days before trial.

Motions in limine must be filed and praeciped 30 days prior to trial.

Jury instructions are due one week before trial and must be submitted electronically in Word format by email to the listed judicial staff and assistant.

Jury instructions are due one week before trial and must be submitted electronically in Word format via email to the following: Judicial Staff Attorney, Carmen Lyon: lyonc@oaklandcountymi.gov Judicial Assistant, Jolie Wackter: wacktery@oaklandcountymi.gov

Motion responses must comply with the Michigan Local Court Rules, and late responses will not be considered.

Any motion responses must be filed in accordance with the Michigan Local Court Rules. Any late filings will not be considered.

A dispositive motion exceeding the applicable page limit will be rejected.

Motions which exceed the page limit will be rejected.

A late dispositive-motion filing will be rejected.

Late filings will be rejected.

Criminal-case motions must be filed and heard at least three weeks before the scheduled trial date.

All motions on criminal cases must be filed and heard at least three weeks prior to the scheduled trial date.

Late filings will not be considered.

Late filings will not be considered.

Every sentencing memorandum must be filed at least three days before sentencing.

All sentencing memoranda must be filed at least three days prior to sentencing.

Counsel must mark exhibits before trial and submit a complete set to the court on the first day of trial.

Exhibits must be marked by counsel prior to trial and a complete set must be submitted to the Court on the first day of trial.

Jury instructions are due one week before the trial.

Jury instructions are due one week before trial and must be submitted electronically in Word format via email to the following:

A motion must be properly noticed for consideration at the Court's Wednesday motion call.

Motions must be properly noticed in front of the Court to be heard as part of the Court’s Wednesday motion call.

An order on a motion is due by 4:30 p.m. on the day the motion is heard.

Orders on motions are due no later than 4:30 p.m. the day the motion was heard.

An order received after the 4:30 p.m. deadline must be submitted as a stipulated order or pursuant to MCR 2.602(B)(3).

An order received after this time must be submitted as a stipulated order, or pursuant to MCR 2.602(B)(3).

After every in-person motion hearing, the order must be presented to the Court immediately when the hearing concludes.

For all in person motion hearings, an order SHALL be presented to the Court for entry immediately following the conclusion of the hearing.

Responses must be filed through MiFILE by noon on the Monday before the motion call; responses absent from the court file by 9:00 a.m. Tuesday may not be reviewed.

Responses must be filed with MiFILE no later than 12:00 p.m. the Monday before the scheduled call; Responses not in the court file by 9:00am on the Tuesday prior to motion call may not be reviewed by the Court.

Deadline

1 working days

Trial and evidentiary hearing briefs must be filed at least one week before the hearing unless the scheduling order states otherwise, and must identify uncontested issues.

TRIAL AND EVIDENTIARY HEARING BRIEFS: Trial and Evidentiary Hearing briefs must be filed in all cases no less than one week prior to the hearing date, unless otherwise indicated in the scheduling order. Be sure to identify uncontested issues. Failure to follow requirements of the Scheduling Order may result in rejection of the trial brief. Parties should refer to the case’s Scheduling Order and/or Order setting the hearing for specific requirements.

A response not in the court file by 9:00 a.m. on the Tuesday before motion call may not be reviewed by the Court.

Responses not in the court file by 9:00am the Tuesday prior to motion call may not be reviewed by the Court.

Trial and evidentiary-hearing briefs must be filed at least one week before the hearing unless the scheduling order states otherwise.

Trial and Evidentiary Hearing briefs must be filed in all cases no less than one week prior to the hearing date, unless otherwise indicated in the scheduling order.

Proposed exhibits should be stipulated before the hearing, and objections must be raised by formal motion noticed no later than the last regular motion call before the hearing.

Proposed exhibits should be stipulated to prior to trial or evidentiary hearing, with objections raised by formal motion and noticed for no later than the Court’s last regular motion call preceding the trial/evidentiary hearing.

If a signed consent judgment is not received within 21 days, the Court may dismiss the case.

If the Court does not receive a signed consent judgment within 21 days, it is within the Court’s discretion to dismiss the case.

Requests for remote prisoner participation must be made to chambers at least one week before the hearing or as soon as practical given the incarceration date.

To make the necessary arrangements, requests for remote prisoner participation must be made to chambers no later than one week prior to the hearing date or as soon as practical based on the date of incarceration.

A motion not timely or properly filed cannot be added to the current motion call and must be re-praecipe for a later motion day.

If you were unable to timely or properly file a motion, we cannot add it to the motion call. You may re-praecipe the motion for hearing on a subsequent motion day.

An order on a motion must be submitted by 4:30 p.m. on the day the motion was heard.

Orders on motions are due no later than 4:30 p.m. the day the motion was heard.

To obtain an excused adjournment or cancellation, the moving party must call chambers by 4:00 p.m. Tuesday and advise the clerk that the motion was adjourned or withdrawn.

For an adjournment or cancellation to be excused by the Court, the moving party must call chambers by 4:00 p.m. on Tuesday to advise the clerk that the motion has been adjourned or withdrawn.

All documents and exhibits must be submitted to the court and the parties at least two days before the hearing.

Submit all documents/exhibits to the court and the parties at least two (2) days prior to the hearing;

Plea forms must be completed in advance and emailed to chambers before the hearing.

Plea forms need to be completed in advance and submitted to judgegantchambers@oakgov.com prior to the hearing.

Counsel for a moving party must check in with the court clerk by 9:30 a.m., or the motion praecipe may be dismissed.

If counsel for the moving party on a motion praeciped for hearing does not check in with the court clerk by 9:30 a.m., the court may dismiss the motion praecipe on its own motion or upon request of counsel for the opposing party.

Opposing counsel must check in with the clerk by 9:30 a.m.; after the moving party requests it, the clerk must call the motion for hearing.

If counsel for the opposing party in a motion praeciped for hearing does not check in with the clerk by 9:30 a.m., upon request of the moving party the clerk shall call the motion for hearing. If appropriate, the court shall grant the requested relief.

Deadline

1 hours

This rule will be enforced one hour from the assigned time of the scheduled motion and also applies to Settlement Conferences before the Friend of the Court.

PLEASE NOTE THIS RULE WILL BE ENFORCED ONE HOUR FROM THE ASSIGNED TIME OF THE SCHEDULED MOTION o This will also apply to Settlement Conferences before the Friend of the Court.

If referee resolution is unsuccessful, the moving party must repraecipe and renotice the motion within 30 days or may have to file a new or amended motion.

If the parties are unresolved with the Referee’s proposal, the moving party shall repraecipe their motion to come before the Court. If your motion is not repraeciped and renoticed within 30 days, you may be required to file a new or amended motion.

When a motion hearing's date and time are not stipulated, the Zoom hearing must be scheduled seven days out.

If the Motion hearing date and time is not stipulated to the Zoom hearing must be scheduled out 7 days

All hearing documents and exhibits must be submitted to the court and parties at least two days before the hearing.

Submit all documents/exhibits to the court and the parties at least two (2) days prior to the hearing;

Criminal-case motions must be filed and heard at least two weeks before the scheduled trial date.

All motions on criminal cases must be filed and heard at least two weeks prior to the scheduled trial date.

Sentencing memoranda and other documents for the Court's consideration must be submitted at least three days before sentencing.

All sentencing memoranda and any other documentation for the Court's consideration must be submitted at least three days prior to sentencing.

The stipulated jury instructions and verdict form must be filed no later than seven days before trial.

A stipulated set of jury instructions and verdict form must be filed no later than seven days prior to the trial date.

The bench brief must be filed no later than seven days before trial.

The brief must be filed no later than seven days prior to the trial date.

Responsive pleadings must be filed by 11:59 p.m. on the Monday before the motion hearing.

Any responsive pleadings must be filed no later than the Monday before the motion hearing at 11:59 p.m.

Late responsive pleadings will not be considered.

Any late filing will not be considered.

Late dispositive-motion filings will be rejected.

Late filings will be rejected.

Responsive pleadings must be filed by 11:59 p.m. on the Monday before the motion hearing, and late filings will not be considered.

Any responsive pleadings must be filed no later than the Monday before the motion hearing at 11:59 p.m. Any late filing will not be considered.

The prosecutor must provide final jury instructions and the verdict form electronically to the Judicial Staff Attorney by the day of trial.

Jury Instructions/ Verdict Form: The Prosecutor provides a set of final jury instructions and verdict form in electronic form to the Judicial Staff Attorney on or before the day of trial.

Attorneys must provide the Judicial Staff Attorney an electronic copy of the jury instructions and verdict form on the trial date.

The attorneys shall provide an electronic copy of the jury instructions including the verdict form to the Judicial Staff Attorney on the date of trial.

The bench brief must be filed no later than seven days before the trial date.

Bench Brief: The bench brief must be filed no later than seven days prior to the trial date.

Late filings will be rejected.

Late filings will be rejected.

Criminal motions must be filed and heard at least two weeks before the scheduled trial date.

Motion Cut-Off: All motions on criminal cases must be filed and heard at least two weeks prior to the scheduled trial date.

Sentencing memoranda and other documentation intended for the court’s consideration must be submitted at least three days before sentencing.

Sentencing Memoranda: All sentencing memoranda and any other documentation for the Court’s consideration must be submitted at least three days prior to sentencing.

A stipulated set of jury instructions and the verdict form must be filed no later than seven days before trial.

Jury Instructions: A stipulated set of jury instructions and verdict form must be filed no later than seven days prior to the trial date.

All motions in limine and other motions related to the pending trial must be filed no later than seven days before trial.

All motions in limine or other motions in relation to the pending trial shall be filed no later than 7 days prior to the scheduled trial.

Deadline

2 business days

Responses to motions relating to the pending trial must be filed no later than two business days before the scheduled hearing.

All responses to any such motions shall be filed no later than 2 business days prior to the scheduled hearing date.

A hearing brief is due no later than seven days before the scheduled hearing.

Each party shall file a hearing brief (including exhibits an supporting law) no later than 7 days prior to the scheduled hearing date.

Each party must exchange exhibits no later than seven days before the scheduled hearing.

Each party must file a Witness List (lay and expert), a Proposed Exhibit List, and exchange exhibits no later than 7 days prior to the scheduled hearing.

Motions relating to the evidentiary hearing must be filed for a Wednesday motion call before the hearing date.

All motions in limine or other motions in relation to the pending evidentiary hearing shall be filed for a Wednesday motion call day prior to the scheduled hearing date.

A motion may be repraeciped no more than twice before dismissal without prejudice.

A party may only repraecipe a motion twice before the court dismisses the motion without prejudice.

Deadline

60 calendar days

A motion may not be repraeciped more than 60 days after its original filing date.

A Motion brought before this Court may not be repraeciped more than sixty (60) days from the motion’s original filing date.

Trial exhibits must be emailed to the court’s staff attorney and opposing party or attorney no later than one week before trial, as required by the scheduling order.

Exhibits must be submitted to the court’s staff attorney (ostrowskik@oakgov.com) and the opposing party/attorney via email no later than one week before the trial per the scheduling order.

A filer is responsible for properly filing documents before any applicable deadline expires.

It is your responsibility to properly file all documents prior to the expiration of any deadlines.

Responsive pleadings must be filed by the deadline specified in MCR 2.119(C)(2).

Responsive pleadings must be filed no later than the deadline identified in MCR 2.119(C)(2)

Responsive pleadings must be filed by the deadline specified in MCR 2.119(C)(2).

Responsive pleadings must be filed no later than the deadline identified in MCR 2.119(C)(2)

A party may re-praecipe a motion only twice before it is dismissed without prejudice.

A party may only repraecipe a motion twice before the court dismisses the motion without prejudice.

A single motion may appear no more than three times on the docket.

Restated, a single motion may only appear a total of three times on the docket.

A fourth docket appearance of the same motion results in dismissal and requires refiling and service with updated information.

If the same motion appears on the docket a fourth time, the court will dismiss it and require it to be refiled and served with updated information.

The court will not consider a motion accompanied by an untimely or improper praecipe.

The court will not consider motions filed with untimely, or improper, praecipes.

Deadline

60 calendar days

A motion may not be re-praeciped more than 60 days after its original date.

A Motion brought before this Court may not be repraeciped more than sixty (60) days from the motion's original date.

Deadline

5 business days

The proposed default judgment and related orders must be submitted at least five business days before the hearing date.

The moving party must present the proposed default judgment and necessary related orders to the Court at least five (5) business days prior to the court date so the Court may review the documents in advance.

Deadline

5 business days

A signed consent judgment and related orders must be submitted at least five business days before the court date.

Please present the signed consent judgment and necessary related orders to the Court at least five (5) business days prior to your court date so the Court may review the documents in advance.

Deadline

5 business days

A request to take proofs by Zoom will be granted only if the court has reviewed the documents in advance, and the documents must be submitted at least five business days before the court date.

Requests to take proofs by Zoom will only be granted where the Court has reviewed documents in advance and will not be granted if the documents are not submitted as least five (5) business days before your Court date.

Deadline

30 calendar days

An attorney who wishes to withdraw as counsel within 30 days of a trial or evidentiary hearing must file a motion.

A motion must be filed if an attorney wishes to withdraw as counsel within 30 days of a trial or evidentiary hearing date.

A Praecipe must be filed with the Case Management Office by 4:30 p.m. on the Wednesday before the requested motion-hearing date.

To have your motion heard, you must file a Praecipe with the Case Management Office by 4:30 pm on the Wednesday prior to the date you wish your motion to be heard.

Responsive pleadings must be filed by the Friday before the Wednesday motion call.

Parties must file any responsive pleadings by the Friday before the Wednesday motion call.

Deadline

5 business days

All judgments and orders submitted for prooftaking must be provided to the court at least five business days before the hearing date.

The Court requires sufficient time to review proposed judgments and orders prior to taking proofs. All judgments and orders must be submitted to the Court at least five (5) business days in advance of the court date where you intend to take proofs.

If a case settles, the parties must file a proposed Final Order of Dismissal before the Final Pretrial Conference or attend with their clients to place the settlement on the record.

In the event of a settlement, the parties shall file their proposed Final Order of Dismissal prior to the date and time of the Final Pretrial Conference or appear for the scheduled Pretrial Conference with their respective clients to place the settlement on the record.

Applies to

Notice of motion

A movant may withdraw a motion by filing a notice of withdrawal, or obtain a later hearing by filing a replacement praecipe and hearing notice by noon on the Tuesday before Motion Call.

A movant may remove its motion from the Motion Call docket only by: (1) filing a notice of withdrawal; or (2) filing by 12:00 p.m. the Tuesday prior to Motion Call a praecipe and notice of hearing for a subsequent motion call date.

Deadline

2 calendar days

Applies to

Sentencing memorandum

A sentencing memorandum must be e-filed at least two days before sentencing, with immediate email notice to the judge's judicial assistant.

Any Sentencing Memorandum for this Court’s consideration shall bee-filed at least 2 days prior to the scheduled Sentencing date, and an email shall be immediately sent to the Judge’s Judicial Assistant, Kristin Humenchick, at humenchickk@oaklandcountymi.gov to notify the Court of said filing.

Deadline

2 calendar days

A sentencing memorandum must be submitted electronically at least two days before the sentencing date.

Sentencing Memorandums: Any Sentencing Memorandum for this Court’s consideration shall be e-filed at least 2 days prior to the scheduled Sentencing date, and an email shall be immediately sent to the Judge’s Judicial Assistant, Kristin Humenchick, at humenchickk@oakgov.com to notify the Court of said filing.

To remove a motion from the Motion Call docket, the movant must file a withdrawal notice or, by noon on the Tuesday before Motion Call, file a praecipe and hearing notice for a later motion-call date.

A movant may remove its motion from the Motion Call docket only by: (1) filing a notice of withdrawal; or (2) filing by 12:00 p.m. the Tuesday prior to Motion Call a praecipe and notice of hearing for a subsequent motion call date.

All dispositive motions must be scheduled within the Scheduling Order's time constraints under MCR 2.116(G)(1)(a).

Summary Disposition Motions. All dispositive motions shall be scheduled, pursuant to MCR 2.116(G)(1)(a), within the time constraints of the Scheduling Order.

MCR 2.119 and MCR 2.116(C) govern motion filing deadlines and notice requirements unless the court orders otherwise.

MCR 2.119 continues to govern all motions filed with the Court, including the filing deadlines and notice requirements set forth in MCR 2.116(C), unless otherwise ordered by the Court.

A notice of hearing or order required for oral argument must be electronically filed on the preceding Tuesday.

In the event the Court determines oral argument is necessary on any given motion, the Court will issue a notice of hearing and, or order setting forth the date and time of hearing via ZOOM video conference or in person and will be e-filed the Tuesday before.

A motion response is due by noon on Monday.

A response to a motion is due by Monday at noon.

Jury instructions must be delivered to chambers in a three-ring binder one week before trial.

Jury instructions are due one week prior to trial and must be delivered to chambers in a 3-ring binder.

After a summary disposition motion is filed, the court will issue a scheduling order, hearing date, and briefing schedule within 21 days.

Once the motion is filed, the Court will enter a scheduling order with a hearing date and briefing schedule within 21 days of motion being filed.

Deadline

48 hours

A request for a 21-day return-of-judgment order requires a signed settlement agreement or mediation recording at least 48 hours before the statutory-proof proceeding.

If the parties are requesting a 21-day order for return of judgment, the Court must be provided with a signed settlement agreement, or a mediation audio recording at least 48 hours in advance of the Court proceeding with the statutory proofs.

After entry of a 21-day ROJOD order, parties must submit signed final documents by noon on the preceding day or appear at the hearing and return-of-judgment date.

If a 21-day Return of Judgment of Divorce (ROJOD) Order is entered, parties shall submit signed final documents by 12:00 p.m. (noon) the day before or appear at the hearing/Return of Judgment date.

A response not received by noon on Monday will not be considered by the Court.

If a response is not received by Monday at 12:00 p.m. (noon), the Court will not consider it.

When Monday is a court holiday, a response must be submitted by 4:30 p.m. on Friday.

If Monday is a court holiday, responses must be submitted to the Court on Friday by 4:30 p.m.

Deadline

48 hours

The required divorce judgment and ancillary documents must be provided at least 48 hours before Zoom statutory proofs.

The Court will take statutory proofs via Zoom if the Court has been provided with a proposed judgment of divorce and ancillary documents, 48 hours prior to the proofs being offered.

A response not received by noon on Monday will not be considered by the Court.

If a response is not received by Monday at 12:00 p.m. (noon), the Court will not consider it.

When Monday is a court holiday, the response deadline is 4:30 p.m. on the preceding Friday.

If Monday is a court holiday, responses must be submitted to the Court on Friday by 4:30 p.m.

Deadline

48 hours

The Court may take statutory proofs by Zoom only if it receives the proposed judgment of divorce and ancillary documents at least 48 hours beforehand.

The Court will take statutory proofs via Zoom if the Court has been provided with a proposed judgment of divorce and ancillary documents, 48 hours prior to the proofs being offered.

Deadline

48 hours

A request for a 21-day order for return of judgment requires a signed settlement agreement or mediation audio recording at least 48 hours before statutory proofs.

If the parties are requesting a 21-day order for return of judgment, the Court must be provided with a signed settlement agreement, or a mediation audio recording at least 48 hours in advance of the Court proceeding with the statutory proofs.

After entry of a 21-day ROJOD order, parties must submit signed final documents by noon on the preceding day or appear on the hearing or return-of-judgment date.

If a 21-day Return of Judgment of Divorce (ROJOD) Order is entered, parties shall submit signed final documents by 12:00 p.m. (noon) the day before or appear at the hearing/Return of Judgment date.

In civil cases, the theory of the case, jury instructions, and verdict form in written and Word format—or trial briefs for a bench trial—must be filed seven days before trial unless a pretrial order states otherwise.

For all civil cases, a theory of the case, jury instructions and verdict form in written and electronic form (Word) (or trial briefs in the event of a bench trial) must be filed with the Court 7 days prior to trial (if not otherwise set forth in a pre-trial order).

Initial-disclosure filing deadlines may be modified only by court order, although the court will consider stipulated orders showing good cause and may deny them or require a motion for leave.

Filing deadlines may only be modified by Court Order (the Court will consider proposed Stipulated Orders demonstrating good cause, but retains discretion to deny them or direct the parties to file a motion for leave).

When an ESI conference is held, the ESI discovery plan is due 14 days after the conference.

if so, the ESI discovery plan shall be filed 14 days following the conference

Initial-disclosure requirements and deadlines are strictly enforced unless the court orders otherwise, and filing deadlines may be modified only by court order, with proposed stipulated orders considered only when they demonstrate good cause.

The Court strictly enforces the disclosure requirements, duties, and filing deadlines established in MCR 2.302(A), unless otherwise ordered by the Court. Filing deadlines may only be modified by Court Order (the Court will consider proposed Stipulated Orders demonstrating good cause, but retains discretion to deny them or direct the parties to file a motion for leave).

Discovery may be extended before the cutoff by stipulation, but an extension after the cutoff requires a motion.

The scheduling order dictates the time for discovery. It can be extended prior to cutoff by stipulation; after cutoff by motion.

Preliminary jury instructions are due by noon on the business day before trial.

no later than noon of the business day preceding the scheduled date of trial.

The joint final pretrial order must be filed shortly after issuance of the scheduling order and is due one week before trial.

The Court utilizes a joint final pretrial order, filed shortly after issuance of scheduling order; due one week before trial.

The trial brief must be submitted one week before trial.

A trial brief is due one week prior to trial

A trial brief must be filed one week before trial.

A trial brief is due one week prior to trial

A motion is considered unopposed if no response arrives by close of business on the Monday before its hearing, except for dispositive motions.

If a Motion Response is not received by close of business on the Monday prior to the scheduled motion hearing, the motion will be considered unopposed (excepting dispositive motions).

Preliminary jury instructions must be submitted no later than noon on the business day preceding trial.

Preliminary jury instructions must be submitted to the Court on plain paper, 14 point font, one instruction per page, double spaced, without citation to case law, no later than noon of the business day preceding the scheduled date of trial.

Trial and evidentiary-hearing briefs must be filed at least one week before the hearing unless the scheduling order states otherwise.

Trial and Evidentiary Hearing briefs must be filed in all cases no less than one week prior to the hearing date, unless otherwise indicated in the scheduling order.

The response filing deadline is 12:00 p.m. on the Monday before the motion call.

Responses must be filed with MiFILE no later than 12:00 p.m. the Monday before the scheduled call

A response not in the court file by 9:00 a.m. Tuesday before the motion call will not be reviewed.

Responses not in the court file by 9:00 a.m. the Tuesday prior to motion call will not be reviewed by the Court.

An order submitted after 4:30 p.m. on the day the motion was heard is untimely and must be submitted as a stipulated order or under MCR 2.602(B)(3).

Orders on motions that are filed with the Court after 4:30 p.m. the day the motion was heard are considered untimely; an order received after this time must be submitted as a stipulated order, or pursuant to MCR 2.602(B)(3).

The court will not review an emergency motion until the clerk accepts it for filing and it is added to the court file.

The Court will not review an emergency motion until it has been accepted for filing by the Clerk’s Office and the motion is added to the court file.

Final orders generally must be submitted at least three days before the scheduled appearance or statutory-proof taking.

Generally, the Court requires final orders to be submitted at least three days in advance of when the parties are scheduled to appear or otherwise plan to take statutory proofs.

A consent judgment must be submitted at least three days before the statutory-proof appearance.

Consent judgments must be submitted via MiFILE at least three days prior to appearing for statutory proofs.

If a signed consent judgment is not received within 21 days, the court may rescind the statutory proofs and dismiss the case.

If the Court does not receive a signed consent judgment within 21 days, it is within the Court’s discretion to rescind proofs and dismiss the case.

A motion must be properly noticed for consideration during the Court’s Wednesday motion call.

MOTION CALL: Motions must be properly noticed in front of the Court to be heard as part of the Court’s Wednesday motion call.

Consent judgments must be submitted at least three days before the statutory-proof appearance.

CONSENT JUDGMENTS: Consent judgments must be submitted via MiFILE at least three days prior to appearing for statutory proofs.

Responses must be filed through MiFILE by noon on the Monday before the scheduled call, and responses absent from the court file by 9:00 a.m. Tuesday will not be reviewed.

Responses must be filed with MiFILE no later than 12:00 p.m. the Monday before the scheduled call; Responses not in the court file by 9:00 a.m. the Tuesday prior to motion call will not be reviewed by the Court.

A response not in the court file by 9:00 a.m. on the Tuesday before motion call will not be reviewed.

Responses not in the court file by 9:00 a.m. the Tuesday prior to motion call will not be reviewed by the Court.

Answers or replies to responses must receive chambers approval before filing.

Answers/Replies to Responses must be approved for filing by chambers pursuant to MCR 2.119(2)(b).

The Court will not review an emergency motion until the Clerk’s Office accepts it for filing and places it in the court file.

Please note that the Court will not review an emergency motion until it has been accepted for filing by the Clerk’s Office and the motion is added to the court file.

Trial and evidentiary-hearing briefs must be filed at least one week before the hearing unless the scheduling order provides otherwise.

TRIAL AND EVIDENTIARY HEARING BRIEFS: Trial and Evidentiary Hearing briefs must be filed in all cases no less than one week prior to the hearing date, unless otherwise indicated in the scheduling order.

The bench trial or hearing brief must be filed and served two weeks before the hearing.

TWO (2) WEEKS prior to Bench Trial/Hearing date:

The stipulated and proposed exhibit list is due by email at least one week before the bench trial or hearing.

A LIST of EXHIBITS indicating Stipulated and/or Proposed must be submitted to Judge Valentine’s Staff Attorney, Shelli Feinberg, at feinbergs@oakgov.com at least ONE (1) WEEK prior to Bench Trial/Hearing

The hearing date for oral argument must be requested and noticed at least 21 days after filing.

Hearing date for ORAL ARGUMENT must be e-praeciped and noticed for hearing pursuant to court rule at least 21 days after filing.

A stipulated adjournment order must be electronically filed by 4:30 p.m. on the Friday before the hearing, and a late submission will be rejected without consideration.

Stipulated orders must be e-filed no later than 4:30 p.m. on the Friday before the hearing. Late submissions will be rejected without consideration.

Responsive pleadings must be filed by noon on the Monday before the motion, and late filings will not be considered.

Responsive Pleadings: Any responsive pleadings must be filed no later than the Monday before the motion. The cut-off time is noon. Any late filings will not be considered.

Untimely dispositive motions and dispositive motions exceeding the page limit will be rejected.

Untimely motions and motions which exceed the page limit will be rejected.

An arraignment by mail must be e-filed by 4:30 p.m. on the Friday before the arraignment; late submissions are rejected, requiring the party to appear for arraignment.

Arraignments by mail must be e-filed no later than 4:30 p.m. on the Friday prior to the arraignment. Late submissions will be rejected without consideration. Parties must appear for arraignment if an arraignment by mail is not timely submitted.

Applies to

Criminal motion

All criminal motions must be filed and heard at least two weeks before the scheduled trial date.

All motions on criminal cases must be filed and heard at least two weeks prior to the scheduled trial date.

Applies to

Sentencing memorandum

A sentencing memorandum must be filed at least three days before sentencing.

All sentencing memoranda must be filed at least three days prior to sentencing.

Applies to

Stipulated order of dismissal

Before the show-cause date, the parties must enter a stipulated order of dismissal; otherwise, all trial counsel and clients must appear at the show cause.

A stipulated order of dismissal must be entered prior to the show cause date, or all trial counsel and clients must appear for the scheduled show cause.

For civil cases, the Case Management Office issues an initial scheduling order approximately 75 days after the complaint is filed, setting an early scheduling conference.

The Case Management Office issues an initial scheduling order for all civil cases approximately 75 days after the complaint is filed and this initial order will set an early scheduling conference.

A party that fails to file its proposed list waives all of its motions in limine.

Failure to file the proposed list will result in the waiver of all motions in limine by the party not in compliance with the Court’s order.

The court may accelerate briefing for a temporary-restraining-order or preliminary-injunction motion when good cause is shown.

The Court may accelerate the briefing schedule for motions for a temporary restraining order or a preliminary injunction if good cause is shown.

A motion not timely or properly filed cannot be added to the current motion call and may be re-praeciced for a later motion day.

If you were unable to timely or properly file a motion, we cannot add it to the motion call. You may re-praecipe the motion for hearing on a subsequent motion day.

A response not in the court file by 9:00 a.m. Tuesday may not be reviewed by the Court.

Responses not in the court file by 9:00am on the Tuesday prior to motion call may not be reviewed by the Court.

Objections to proposed exhibits must be raised by formal motion and noticed no later than the court’s last regular motion call before the hearing.

Proposed exhibits should be stipulated to prior to trial or evidentiary hearing, with objections raised by formal motion and noticed for hearing no later than the Court’s last regular motion call preceding the trial/evidentiary hearing.

A motion for reconsideration will not receive a hearing unless the Court orders one.

Due to the Court Rules, a hearing will not be held unless ordered by the Court.

An interpreter request made with less than one week’s notice may result in no interpreter being available or the hearing being adjourned.

Any requests for interpreter made with less than one weeks’ notice may result an inability for the Court to provide an interpreter for the hearing or the adjournment of the hearing.

An order received after the 4:30 p.m. deadline must be submitted as a stipulated order or under MCR 2.602(B)(3).

An order received after this time must be submitted as a stipulated order, or pursuant to MCR 2.602(B)(3).

The signed judgment and companion orders may be electronically filed three days before the scheduled trial or settlement conference.

The parties may e-file the signed Judgment and any companion orders three (3) days before the scheduled trial/settlement conference date.

When all parties agree, a motion may be heard without seven days' notice on any available day and time.

If all parties agree for a Motion to be heard without 7-day notice, it can be heard on any day and at any time available.

Parties may electronically file the signed judgment and companion orders three days before the scheduled trial or settlement conference.

The parties may e-file the signed Judgment and any companion orders three (3) days before the scheduled trial/settlement conference date.

If all signatures cannot be obtained, the order must be filed under the 7-Day Rule.

Parties are required to file the order under the 7-Day Rule if unable to obtain all signatures.

Deadline

7 business days

Parties are strongly encouraged to file final judgment documents at least seven business days before the hearing.

The court strongly encourages parties to file their documents no later than seven (7) business days before the hearing to ensure sufficient processing time.

Deadline

7 business days

Parties are strongly encouraged to file documents at least seven business days before the hearing.

The court strongly encourages parties to file their documents no later than seven (7) business days before the hearing to ensure sufficient processing time.

Deadline

21 calendar days

The court may dismiss the case if it does not receive the signed consent judgment and related orders within 21 days.

If the court does not receive a signed consent judgment with any necessary related orders within the twenty-one (21) days, it is within the court's discretion to dismiss the case.

Deadline

5 business days

A party may place a settlement on the record without filing a motion by notifying the judge's clerk and requesting a hearing time at least five business days in advance.

Parties may place a settlement on the record without filing a motion by notifying the judge's clerk and requesting a hearing time with at least five (5) business days’ advance notice.

Motion Call is generally conducted by Zoom on Wednesday mornings beginning at 8:30 a.m.

The Oakland County Circuit Court conducts Motion Call on Wednesday mornings beginning at 8:30 a.m., which this Court generally conducts electronically via Zoom video conference.

An Early Facilitation Order provides for facilitation within 90 days after the CMC date.

Joint Agreement to Facilitate Within 90 Days after the CMC Date (a/k/a “Early Facilitation Order”)

The privilege log, document production, and written discovery responses must be produced at the same time.

The log shall be produced at the same time as the document production. The document production shall be made at the same time as the written responses.

A party should initiate written discovery at least 28 days before the discovery cutoff so that the opposing party has sufficient time to respond.

That is, discovery must be served sufficiently in advance of the discovery cutoff date so as to allow the opposing party sufficient time to respond prior to the discovery cutoff. As a practical matter, a party shall initiate written discovery at least 28 days before the deadline for

A motion that was not timely or properly filed cannot be added to the current motion call and may be re-praecipe for a later motion day.

If you were unable to timely or properly file a motion, we cannot add it to the motion call. You may re-praecipe the motion for hearing on a subsequent motion day.

When a consent judgment is not prepared at the statutory-proof appearance, the Court generally allows 21 days to submit a signed judgment if only signatures remain outstanding.

If the consent judgment has not been prepared when the parties appear before the Court to take statutory proofs, the Court will generally allow the parties 21 days to submit a signed consent judgment based on a recorded settlement so long as there are no pending disagreements over the judgment and it is only a matter of obtaining signatures.

If a signed consent judgment is not received within 21 days, the Court may rescind the statutory proofs and dismiss the case.

If the Court does not receive a signed consent judgment within 21 days, it is within the Court’s discretion to rescind proofs and dismiss the case.

Proposed exhibits should be stipulated before the trial or evidentiary hearing, and objections should be raised by formal motion noticed no later than the last regular motion call before the hearing.

Proposed exhibits should be stipulated to prior to trial or evidentiary hearing, with objections raised by formal motion and noticed for no later than the Court’s last regular motion call preceding the trial/evidentiary hearing.

Emergency motions may be filed at any time.

An emergency motion can be filed at any time.

The brief scheduling order will issue only after the motion is accepted for filing.

The brief scheduling order will be issued after the motion has been accepted for filing.

The brief scheduling order for a summary-disposition motion will issue only after the motion is accepted for filing.

The brief scheduling order will be issued after the motion has been accepted for filing.