Limits & Logistics
Document Limits
Courtesy Copies
Motion
- No Later Than 7 Days Before Hearing
- Within 3 Days of Order Entry
Reconsideration Motions
Response
- No Later Than 3 Days Before Hearing
Response, Reply Brief
- Within 3 Days of Filing
Adjournments
- A motion to extend a Status Conference Scheduling Order must show good cause, address impediments to completing the case on time, include the specified dates and scheduling order, and attach a proposed order detailing remaining discovery and issues.
- A Settlement Conference adjournment must be requested by motion; a stipulated order will not be accepted.
- A scheduled trial date may be adjourned only by motion and upon a showing of good cause.
- +3 more
Request must include
Page & Word Limits2 rules
Pursuant to MCR 2.119(A)(2)(a), "the combined length of any motion and brief, or of a response and brief, may not exceed 20 pages double spaced, exclusive of attachments and exhibits."
- Motion and brief or response and brief
- Up to 20 pages in total
- Format
- Double-spaced
Excluded from page count
- •Attachments
- •Exhibits
Additionally, exhibits must be limited to 100 pages.
- Exhibits
- Up to 100 pages
Document Format Requirements3 rules
Any and all exhibits attached to a brief must be tabbed.
Counsel are required to email the same in Word Document Format to lisa.damphousse@3rdcc.org.
- File type
- Word
Merely using a binder clip, rubber band, or box is insufficient and will be rejected by the Court. Staples or two prong fasteners are sufficient.
Document Filing Requirements21 rules
Any order or judgment that disposes of a claim must state whether or not it is a final order closing the case pursuant to MCR 2.602(A)(3).
All counsel of record must sign a stipulated order to dismiss a party.
A transcript exhibit must include the full transcript in mini-script form, identify referenced portions, provide precise supporting citations in the brief, and highlight cited portions in the exhibit.
Court's wording
If a transcript is attached as an exhibit, the entire transcript (in mini script form) must be included as an attachment with the referenced portion(s) clearly indicated. Precise citations to the specific portions used to support your argument must be included in your brief, and cited portions of the transcript must be clearly highlighted within the exhibit.
When preparing an Order delineating the Court’s ruling on your motion, you must clearly indicate the hearing date when oral arguments were held on your motion in the preamble of your Order.
Please also submit a praecipe for each motion filed requesting the same date and time so that the motions are scheduled to be heard together.
An Order of Consolidation must identify all cases, designate the oldest as controlling, state the consolidation’s purpose, direct future pleadings to the controlling case number, and instruct the Clerk to add parties from non-controlling cases to the controlling case.
Court's wording
The stipulated Order of Consolidation must include all case names and case numbers, must indicate the oldest case first as the controlling case, and must state whether the cases are being consolidated for discovery purposes, for trial, or for all purposes. The stipulated Order of Consolidation must also indicate that all future pleadings shall be filed under the controlling case number only. The stipulated Order of Consolidation must also instruct the clerk to add all parties in the non-controlling case(s) as parties within the controlling case.
Each pleading’s caption must list contact details for every appearing attorney, put the motion attorney or court contact first for that party, and assign a primary attorney in no-fault cases.
- Document
- Pleading
- Placement
- Caption
Court's wording
The caption on each pleading must contain the contact information of all of the attorneys who have appeared on the case including direct phone numbers and email addresses for each attorney. The attorney who plans to appear on a motion, or the attorney who should be contacted by the court with regard to a motion, must be the first attorney listed on the caption for the respective party. On no-fault cases, a primary attorney must be assigned to each case.
Permission must be obtained from the Court for exhibits exceeding 100 pages.
Plaintiff’s counsel must convene all counsel to collaborate on a concise FPTO, prepare it, and submit it to the Court for approval and adoption at the Final Pretrial Conference.
Court's wording
Counsel for Plaintiff must assume the responsibility for convening a meeting of all counsel to confer and collaborate in formulating a short and concise Final Joint Pretrial Order (hereinafter referred to as ‘FPTO’) which is to be prepared by Plaintiff’s counsel and submitted to the Court for approval and adoption at the Final Pretrial Conference.
Unless Judge Snow orders otherwise, an alternate-service proposed order must include all three specified service methods and the quoted language, and must not include certified mail with return receipt and restricted delivery.
Court's wording
When submitting a motion for alternate service and an accompanying proposed Order for the same, your proposed Order MUST INCLUDE ALLOF THE FOLLOWING METHODS OF ALTERNATE SERVICE unless Judge Snow specifically orders otherwise: 1) mailing via first class mail to the last known address for the Defendant, 2) tacking on the door at the last known address for the Defendant, and 3) communication of the pleadings via "text, email, and/or Facebook to the Defendant, if known." This quoted language MUST be included in your Order. SERVICE MUST BE ACCOMPLISHED BY EVERY METHOD OF SERVICE ORDERED. Also, DO NOT include service via certified mail with return receipt, restricted delivery on your proposed Order for alternate service.
A Notice of Hearing and a Praecipe are required for each motion.
A motion to intervene must state the proposed intervenor’s claim amount, attach the applicable scheduling orders, and list all relevant dates, including the case filing and Case Evaluation dates.
Court's wording
Motions to Intervene: The proposed intervening party must provide the court with the amount of their proposed claim in the body of the motion. The moving party must attach a copy of the Status Conference Scheduling Order, the current scheduling order (if different), and must list all relevant dates (including the case filing date and the Case Evaluation date) in the body of the motion.
Once the moving party receives the Summary Disposition Scheduling Order, the moving party must file and serve a Re-Notice of Hearing for the date provided by the Court in the Summary Disposition Scheduling Order.
When filing a motion for summary disposition, the Notice of Hearing shall state that the hearing will be set on a “date to be determined.”
Motions for Entry of a Default Judgment: The moving party must attach a proposed Judgment to the motion as an exhibit.
The Order of Consolidation that is e-filed in the controlling case number should not be a final Order. However, the Order(s) of Consolidation that is e-filed in the non-controlling case number(s) must indicate that it is a final Order closing the case.
Parties who are dismissed from an action must remain on the caption with a strike-through line over their name to indicate to the Court that they have been dismissed from the case.
- Placement
- Caption
All pleadings and orders must contain correct captions including the correct Judge’s name. Pleadings and orders with incorrect captions will be rejected and the attorney using the incorrect caption will be subject to sanctions.
- Document
- Pleading and order
- Placement
- Caption
When medical documentation is an exhibit, the brief must cite the specific supporting portions and those portions must be highlighted in the exhibit.
Court's wording
If medical documentation is attached as an exhibit, precise citations to the specific portions used to support your argument must be included in your brief, and cited portions of the medical documentation must be clearly highlighted within the exhibit.
Proposed Orders should be attached to the motion/response as well as brought to the motion hearing.
- Document
- Motion or response
Should include
- •Proposed order
Filer Comments:When submitting an order following a motion hearing, please indicate in the ‘Filer Comments’ that the order is being submitted consistent with the Court’s ruling and indicate the date of that hearing.
Filing & Service rules
Electronic Filing Rules
A Summary Disposition Scheduling Order will be issued only after the motion is e-filed and the Praecipe is accepted.
Summary Disposition Scheduling Orders will only be issued after the motion has been e-filed and the Praecipe has been accepted.
Civil cases
Page 1 | Motions for Summary Disposition Procedure
Counsel must email the proposed joint jury instructions and verdict form in Word document format to lisa.damphousse@3rdcc.org.
Counsel are required to email the same in Word Document Format to lisa.damphousse@3rdcc.org.
Civil cases
Page 1 | Trial Procedures — Proposed Joint Jury Instructions and Proposed Joint Verdict Form
The Order of Consolidation must be e-filed under every case number included in the consolidation.
The Order of Consolidation must then be e-filed under each case number included within the consolidation.
Civil cases
Page 1 | General Motion Practice Procedure — Motions for Consolidation
Orders must be filed in accordance with the Court’s e-filing guidelines.
Orders must be filed in accordance with the e-filing guidelines which can be found on the Court website.
Civil cases
Page 1 | General Motion Practice Procedure
Filing Timing and Cure Windows
All motions for summary disposition must be filed no later than 30 days after Case Evaluation.
All motions for summary disposition must be filed no later than 30 days after Case Evaluation.
Civil cases
Page 1 | Motions for Summary Disposition Procedure
The Final Joint Pretrial Order is due at the date and time of the Final Joint Pretrial Conference.
A Final Joint Pretrial Order is due at the date and time set for your Final Joint Pretrial Conference.
Civil cases
Page 1 | Trial Procedures — Final Joint Pretrial Order
Proposed joint jury instructions and the proposed joint verdict form are due by 8:30 a.m. on the Thursday before trial.
Proposed joint jury instructions and proposed joint verdict form are due by 8:30 a.m. on the Thursday before trial.
Civil cases
Page 1 | Trial Procedures — Proposed Joint Jury Instructions and Proposed Joint Verdict Form
For a motion for reconsideration, the moving party must file a Praecipe selecting the next business day at 9:00 a.m. as the hearing date.
The moving party must file a praecipe and select the next business day at 9:00 a.m. as the hearing date in order to bring the motion to the Court’s attention.
Civil cases
Page 1 | General Motion Practice Procedure — Motions for Reconsideration
If facilitation occurs instead of Case Evaluation, motions for summary disposition must be filed within 30 days after facilitation.
If the case has been sent to facilitation in lieu of Case Evaluation, then all motions for summary disposition must be filed no later than 30 days after facilitation.
Civil cases
Page 1 | Motions for Summary Disposition Procedure
If Case Evaluation is determined to be inappropriate, motions for summary disposition must be filed within 30 days after discovery closes.
If a determination has been made that Case Evaluation is not appropriate for your case, then all motions for summary disposition must be filed no later than 30 days after the close of discovery.
Civil cases
Page 1 | Motions for Summary Disposition Procedure
Briefs for motions in limine are due one week before the hearing.
Briefs for any motions in limine are due one (1) week in advance of the hearing date.
Civil cases
Page 1 | Trial Procedures — Motions in Limine
The moving party must select a Thursday hearing date at 11:00 a.m. that is at least 60 days after submitting the Praecipe.
When filing the praecipe, the moving party shall select a Thursday date, at 11:00 a.m., that is no less than 60 days from the date the praecipe is being submitted.
Civil cases
Page 1 | Motions for Summary Disposition Procedure
An order submitted through e-filing on the day of the motion hearing is considered presented to the Court that day.
Orders submitted through e-filing on the day the motion was heard will be considered as having been presented to the Court pursuant to MCR 2.602(B)(1).
Civil cases
Page 1 | General Motion Practice Procedure
An untimely response will result in the motion being treated as unopposed, and oral argument may not be permitted.
If a response to a motion is not timely filed, the Court will treat the motion as unopposed and oral argument may not be permitted.
Civil cases
Page 1 | General Motion Practice Procedure
Service and Proof of Service Rules
A motion for alternate service is appropriate only after attempted personal service, attempted certified mail with return receipt and restricted delivery, and a postal address verification check.
A motion for alternate service is only appropriate after all three (3) of the following have been completed: 1) personal service has been attempted, 2) service via certified mail with return receipt, restricted delivery has been attempted, and 3) a postal address verification check with the post office has been completed.
Civil cases
Page 1 | General Motion Practice Procedure — Motions for Alternate Service
Every method of service ordered must be completed.
SERVICE MUST BE ACCOMPLISHED BY EVERY METHOD OF SERVICE ORDERED.
Civil cases
Page 1 | General Motion Practice Procedure — Motions for Alternate Service
The Court will serve the Status Conference Scheduling Order electronically on counsel, and Plaintiff’s counsel must ensure service on the Defendant.
The Court shall issue a Status Conference Scheduling Order which shall be signed, filed, and served electronically upon counsel of record. However, it is the responsibility of Plaintiff’s counsel to ensure service upon the Defendant.
Civil cases
Page 1 | Status Conference Procedure
A filed motion must be served; the Court prefers a courtesy copy be delivered to Courtroom 1821 no later than seven days before the hearing.
Any motion filed shall be served, and the Court prefers that a courtesy ‘Judge’s Copy’ also be delivered to Courtroom 1821, no later than seven (7) days prior to the hearing date pursuant to MCR 2.119(C)(1)(a-b).
Civil cases
Page 1 | General Motion Practice Procedure
A response to a motion must be filed and served, and the Court prefers its courtesy copy be delivered to Courtroom 1821 no later than three days before the hearing.
A Response to a motion shall be filed and served, and the Court prefers that a courtesy ‘Judge’s Copy’ also be delivered to Courtroom 1821, no later than three (3) days prior to the hearing date pursuant to MCR 2.119(C)(2)(a-b).
Civil cases
Page 1 | General Motion Practice Procedure
Courtesy Copy Requirements
The moving party must provide a Judge’s Copy of a motion for reconsideration directly to the courtroom.
The moving party shall also provide a 'Judge's Copy' of the motion directly to the courtroom.
Civil cases
Page 1 | General Motion Practice Procedure — Motions for Reconsideration
The moving party must deliver a courtesy copy of the motion to Courtroom 1821 within three days after entry of the Order.
The moving party shall deliver a courtesy ‘Judge’s Copy’ of the motion to Courtroom 1821 within three (3) days of the date of entry of the Order.
Civil cases
Page 1 | Motions for Summary Disposition Procedure
Courtesy copies of responses and reply briefs must be delivered to Courtroom 1821 within three days after filing.
A courtesy ‘Judge’s Copy’ of all response(s) and reply briefs shall be delivered to Courtroom 1821 within three (3) days of the date that it is filed.
Civil cases
Page 1 | Motions for Summary Disposition Procedure
The Court prefers that a motion’s courtesy copy be delivered to Courtroom 1821 no later than seven days before the hearing.
Any motion filed shall be served, and the Court prefers that a courtesy ‘Judge’s Copy’ also be delivered to Courtroom 1821, no later than seven (7) days prior to the hearing date pursuant to MCR 2.119(C)(1)(a-b).
Civil cases
Page 1 | General Motion Practice Procedure
The Court prefers that a response’s courtesy copy be delivered to Courtroom 1821 no later than three days before the hearing.
A Response to a motion shall be filed and served, and the Court prefers that a courtesy ‘Judge’s Copy’ also be delivered to Courtroom 1821, no later than three (3) days prior to the hearing date pursuant to MCR 2.119(C)(2)(a-b).
Civil cases
Page 1 | General Motion Practice Procedure
Filing Bundling Requirements
Motions, responses, replies, their briefs, and all exhibits must be submitted together as one document.
All motions, responses, and replies, along with any corresponding brief and any and all exhibits, must be bound together as one (1) single document.
Civil cases
Page 1 | Motions for Summary Disposition Procedure
The FPTO must be bound together as one document.
The FPTO must be bound together as one (1) single document.
Civil cases
Page 1 | Trial Procedures — Final Joint Pretrial Order
Pre-Motion Conference Requirements
The Court expects attorneys to work cooperatively to resolve discovery disputes without a court hearing.
The Court expects that all attorneys will work cooperatively with each other to resolve discovery disputes without the necessity of a court hearing.
Civil cases
Page 1 | General Motion Practice Procedure — Motions to Compel
Unopposed motions to compel may result in sanctions.
Unopposed motions to compel may result in sanctions pursuant to MCR 2.313.
Civil cases
Page 1 | General Motion Practice Procedure — Motions to Compel
For reconsideration motions, attendance and a response are not required or permitted unless the Court specifically requests a response or hearing.
Pursuant to MCR 2.119(F)(2), attendance at the hearing date is not required nor is a response permitted unless the Court specifically contacts the parties requesting a response and/or a hearing.
Civil cases
Page 1 | General Motion Practice Procedure — Motions for Reconsideration
Motions in limine are generally heard at 1:00 p.m. on the Thursday before trial, but Judge Snow may hear them earlier depending on how many are filed.
Generally, the Court will hear motions in limine on the Thursday before trial at 1:00 p.m. At Judge Snow's discretion, motions in limine may be heard earlier depending upon the number of motions in limine filed.
Civil cases
Page 1 | Trial Procedures — Motions in Limine
Adjournment & Extension Requirements
A motion to extend a Status Conference Scheduling Order must show good cause, address outstanding barriers, attach the current scheduling orders and a detailed proposed schedule, list the specified dates, and have all counsel present.
A motion is required to extend a Status Conference Scheduling Order. That motion must address all outstanding discovery issues or any other matters that prevent the parties from completing the case within the given deadlines. The motion must also show good cause for the adjournment. The party seeking the adjournment of the scheduling order must attach a copy of the Status Conference Scheduling Order, the current scheduling order (if different), and must list all relevant dates (including the case filing date and the Case Evaluation date) in the body of the motion. ALL COUNSEL MUST BE PRESENT FOR THIS TYPE OF MOTION. A proposed scheduling Order indicating specific depositions to be taken with dates certain scheduled, specific discovery to be completed with deadlines scheduled, and specifically stating any other outstanding issues must be attached to the motion. The proposed Order must also contain a firm facilitation date and a sentence containing a blank space where the clerk will then provide your next Settlement Conference date.
Civil cases
Page 1 | Motions to Adjourn Status Conference Scheduling Orders
Only the moving party may request an adjournment of a Motion. The moving party must contact the Court’s Clerk to request a new date. Motions may only be adjourned twice. Thereafter, the motion will be dismissed but may be refiled. After obtaining a new date from the Court Clerk, the moving party must file and serve a Re-Notice of Hearing indicating the new date.
Only the moving party may request an adjournment of a Motion. The moving party must contact the Court’s Clerk to request a new date. Motions may only be adjourned twice. Thereafter, the motion will be dismissed but may be refiled. After obtaining a new date from the Court Clerk, the moving party must file and serve a Re-Notice of Hearing indicating the new date.
Civil cases
Page 1 | General Motion Practice Procedure
A motion to extend a Status Conference Scheduling Order must show good cause, address impediments to completing the case on time, include the specified dates and scheduling order, and attach a proposed order detailing remaining discovery and issues.
A motion is required to extend a Status Conference Scheduling Order. That motion must address all outstanding discovery issues or any other matters that prevent the parties from completing the case within the given deadlines. The motion must also show good cause for the adjournment. The party seeking the adjournment of the scheduling order must attach a copy of the Status Conference Scheduling Order and must list all relevant dates (including the case filing date) in the body of the motion. A proposed scheduling order indicating specific depositions to be taken with dates certain scheduled, specific discovery to be completed with deadlines scheduled, and specifically stating any other outstanding issues must be attached to the motion.
Civil cases
Page 1 | Status Conference Procedure
Only the moving party may seek an adjournment of summary-disposition oral argument; the party must contact the Judicial Attorney, show good cause, and file and serve a Re-Notice of Hearing after receiving a new date.
Only the moving party may request an adjournment of oral argument on a motion for summary disposition. The moving party must contact the Court’s Judicial Attorney to request a new date. Motions for summary disposition will only be adjourned for good cause. After obtaining a new date from the Judicial Attorney, the moving party must file and serve a Re-Notice of Hearing indicating the new date for oral argument.
Civil cases
Page 1 | Motions for Summary Disposition Procedure
A Settlement Conference adjournment must be requested by motion; a stipulated order will not be accepted.
If you would like to request an adjournment of your Settlement Conference, you must file a motion. Judge Snow will not accept a stipulated Order for this purpose.
Civil cases
Page 1 | Settlement Conference Procedure
A scheduled trial date may be adjourned only by motion and upon a showing of good cause.
Trial dates, once scheduled, will not be adjourned without a motion and a showing of good cause.
Civil cases
Page 1 | Settlement Conference Procedure
Chambers Communication Rules
Only the moving party may request an adjournment of a Motion. The moving party must contact the Court’s Clerk to request a new date. Motions may only be adjourned twice. Thereafter, the motion will be dismissed but may be refiled. After obtaining a new date from the Court Clerk, the moving party must file and serve a Re-Notice of Hearing indicating the new date.
Only the moving party may request an adjournment of a Motion. The moving party must contact the Court’s Clerk to request a new date. Motions may only be adjourned twice. Thereafter, the motion will be dismissed but may be refiled. After obtaining a new date from the Court Clerk, the moving party must file and serve a Re-Notice of Hearing indicating the new date.
Civil cases
Page 1 | General Motion Practice Procedure
If scheduling conflicts arise, the parties may arrange with the Court Clerk to hold a motion hearing on a day other than Friday.
If scheduling conflicts arise, the parties may arrange with the Court Clerk to schedule a motion hearing on a day other than a Friday.
Civil cases
Page 1 | General Motion Practice Procedure