Limits & Logistics
Document Limits
Communication
Chambers
Chambers
Page & Word Limits1 rule
Page limits according to the court rules are strictly enforced.
Document Filing Requirements19 rules
ISSUES OF LAW: Issues of law to be litigated.
VERDICT FORM: Include a verdict form listing all possible verdicts.
The joint final pretrial order must include itemized damages; plaintiffs must specify objectively calculable damages and applicable benefit amounts and categories, and intervening plaintiffs must itemize their claims.
Court's wording
DAMAGES: An itemized statement of damages. Plaintiff shall specify all those claimed damages that can be calculated from objective data. If plaintiff is asserting a claim for first party benefits, the plaintiff shall identify the amount and category or each type of benefit. Intervening plaintiffs must specifically list the amount and breakdown of their claims.
PLAINTIFF’S CLAIMS: a concise statement of plaintiff’s claims, including legal theories.
The specified concluding language must appear at the end of the final pretrial order above the signature line.
Court's wording
CONCLUDING ORDER LANGUAGE: Include the following language at the end of the Final Pre-Trial Order above the signature line: “This order constitutes a duly entered order of this court, and failure of counsel or a party without counsel to cooperate in the preparation of, to submit, or to comply strictly with all the terms of the joint Final Pre-Trial Order, may result in refusal to let witnesses testify or to admit exhibits, dismissal of claims, striking of answers and affirmative defenses, default and entry of default judgment, or other action, including the assessment of special costs and expenses, including actual attorney fees.”
ESTIMATED LENGTH OF TRIAL: Estimated time for plaintiff’s proofs Estimated time for defendant’s proofs Indicate whether it is a jury or non-jury trial If a jury trial, indicate if a unanimous verdict of not less than 5 jurors.
DEFENDANT’S CLAIMS: a concise statement of defendant’s defenses and claims, including cross-claims and/or claims of third-party plaintiffs, and defenses of cross-defendants and/or third-party defendants, including legal theories.
Praecipes: must be filed for every motion or it will not be scheduled.
JURY INSTRUCTIONS: Provide the court with a copy of all requested jury instructions. If any party is requesting a special jury instruction include in the Final Pre-Trial Order a written copy of the special instruction and supporting legal authority.
ISSUES OF FACT: Issues of fact remaining to be litigated.
Each party must identify witnesses who will or may be called; generic listings are unacceptable, and previously undisclosed witnesses may be listed only for good cause.
Court's wording
EXHIBIT AND WITNESS LISTS: Each party will indicate which witnesses will be called and which witnesses may be called. Generic listing of witnesses such as “all or any employees of the defendant or plaintiff” is not acceptable. Failure to list witnesses may bar their production at trial. No witnesses shall be listed who have not been included on any written list submitted pursuant to prior court order except for good cause shown.
DEPOSITION TESTIMONY: The names of all witnesses who will testify by deposition must be identified. Failure to do so may bar their production at trial except for good cause shown.
STIPULATIONS OR ADMISSIONS OF FACTS: a recitation of any facts or other matters to which the parties have stipulated or admitted. The parties shall state, in separately numbered paragraphs, all uncontested facts.
Final Pre-Trial Order: Must be filed by the due date in the final trial scheduling order and must conform to the requirements as set forth below.
An adjournment praecipe must be filed.
SIGNATURE LINE: Include signature lines for the judge and all counsel of record.
- Placement
- Signature block
The parties must number and briefly describe each intended trial exhibit; only listed exhibits are admissible, subject to the stated exceptions.
Court's wording
The parties shall number and with a short identifying description, each exhibit they intend to introduce at trial. Only listed exhibits will be considered admissible at trial, except for rebuttal exhibits which could not be reasonably anticipated before trial or except for good cause shown.
Jury Instructions: Plaintiff’s attorney must bring 1 copy of the jury instructions to be read at trial.
When listing witnesses, parties should identify all expert witnesses and designate whether they are testifying in person or by deposition.
Filing & Service rules
Electronic Filing Rules
Appeal briefs and supporting materials must be emailed to the listed judicial attorney or mailed to the court.
Additional requirements: All briefs and supporting material must be emailed to the listed JA; Sravani.kurra@3rdcc.org or mailed to the court.
Civil cases
Page 1 | V. APPEALS
The joint final pretrial order must be e-filed by 3:30 p.m. on the Friday before trial.
The joint Final Pre-Trial Order must be e-filed no later than 3:30 pm on the Friday prior to trial.
Civil cases
Page 1 | VII. FINAL PRETRIAL CONFERENCE AND JOINT PRETRIAL ORDER
The moving party must e-file the motion and submit a praecipe with a placeholder Thursday hearing date at least 42 days after filing.
Moving party to submit motion through efiling and submit the praecipe with a "placeholder" hearing date on a Thursday at 9:30 am, at least 42 days after the motion filing date.
Civil cases
Page 1 | IV. SUMMARY DISPOSITION MOTIONS
Filing Timing and Cure Windows
The joint final pretrial order is due by 3:30 p.m. on the Friday before trial.
The joint Final Pre-Trial Order must be e-filed no later than 3:30 pm on the Friday prior to trial.
Civil cases
Page 1 | VII. FINAL PRETRIAL CONFERENCE AND JOINT PRETRIAL ORDER
The moving party must submit a praecipe with a placeholder Thursday hearing date at least 42 days after the motion filing date.
Moving party to submit motion through efiling and submit the praecipe with a "placeholder" hearing date on a Thursday at 9:30 am, at least 42 days after the motion filing date.
Civil cases
Page 1 | IV. SUMMARY DISPOSITION MOTIONS
Responses are due three days before the hearing date, as provided in MCR 2.119(C)(2).
Response due dates: As set forth in MCR 2.119(C)(2), 3 days prior to hearing date.
Civil cases
Page 1 | III. MOTION PRACTICE
Late motions will be rejected and motion for leave must be filed. Otherwise, a motion for leave is required.
Late motions will be rejected and motion for leave must be filed. Otherwise, a motion for leave is required.
Civil cases
Page 1 | IV. SUMMARY DISPOSITION MOTIONS
Objections to an expert’s qualifications or testimony must be raised before trial by motion in limine.
Any objections to the qualifications or testimony of any expert shall be raised before trial by motion in limine.
Civil cases
Page 1 | VII. FINAL PRETRIAL CONFERENCE AND JOINT PRETRIAL ORDER
Filing deadline: According to the Status Conference Scheduling Order, the motion must be filed no later than 30 days after the case evaluation accept/reject date. If there is no case evaluation, then the motion must be filed no later than 30 days after the end of discovery.
Filing deadline: According to the Status Conference Scheduling Order, the motion must be filed no later than 30 days after the case evaluation accept/reject date. If there is no case evaluation, then the motion must be filed no later than 30 days after the end of discovery.
Civil cases
Page 1 | IV. SUMMARY DISPOSITION MOTIONS
The court may strike late responses.
Late responses may be stricken.
Civil cases
Page 1 | III. MOTION PRACTICE
Courtesy Copy Requirements
Parties are not required to file hard copies of motions or responses with the court.
Parties are not required to file hard copies of the motions or responses with the court.
Civil cases
Page 1 | III. MOTION PRACTICE
Paper copies of motions and responses are not required.
No paper copies of motions or responses are required.
Civil cases
Page 1
Pre-Motion Conference Requirements
Responses to motions for reconsideration are not permitted unless the court authorizes them.
No responses are permitted unless authorized by the court.
Civil cases
Page 1 | III. MOTION PRACTICE
Adjournment & Extension Requirements
Summary-disposition-motion adjournments require court approval.
Adjournment: Only with court approval.
Civil cases
Page 1 | IV. SUMMARY DISPOSITION MOTIONS
Subsequent adjournments must be requested by motion.
Subsequent adjournments must be made by motion.
Civil cases
Page 1 | I. STATUS CONFERENCE
Settlement-conference adjournments must be requested by motion.
Adjournments must be made by motion.
Civil cases
Page 1 | II. SETTLEMENT CONFERENCE
An appeal adjournment requires court approval and all parties’ stipulation and may be no longer than two weeks.
Adjournment: With approval from the court and stipulation of all parties. The adjournment shall be for no more than 2 weeks.
Civil cases
Page 1 | V. APPEALS
Parties may stipulate to extend discovery through the case-evaluation-summary due date or to adjourn to Track 2.
Parties may stipulate to conduct discovery up to the due date for case evaluation summaries. Parties may also stipulate to adjourn to Track 2.
Civil cases
Page 1 | I. STATUS CONFERENCE
The moving party may adjourn a motion once, with the court’s permission.
The moving party may adjourn the motion once with the court's permission.
Civil cases
Page 1 | III. MOTION PRACTICE
Chambers Communication Rules
For an emergency motion, contact the court clerk to schedule a hearing date.
Emergency motion: You must contact the court clerk to schedule a hearing date.
Civil cases
Page 1 | III. MOTION PRACTICE
If the case settles or issues are resolved, the moving party must inform the court immediately.
As a courtesy to the court, if the case settles or issues are resolved, the moving party must inform the court immediately.
Civil cases
Page 1 | IV. SUMMARY DISPOSITION MOTIONS
Summary disposition motions are heard in person unless an alternative is requested under MCR 2.408(A)(1) by contacting the courtroom.
All SD Motions are heard IN PERSON unless otherwise requested pursuant to MCR 2.408(A)(1) by contacting the courtroom.
Civil cases
Page 1 | IV. SUMMARY DISPOSITION MOTIONS
A copy of a motion for reconsideration should be emailed to the listed judicial attorney and court addresses.
A copy of the motion should be emailed to sravani.kurra@3rdcc.org, and JudgeHubbard-Court@3rdcc.org.
Civil cases
Page 1 | III. MOTION PRACTICE