Judge Charlene M. Elder
Individual Rules, Standing Orders & Policies
- Rules last changed:
Limits & Logistics
Document Limits
Courtesy Copies
Courtesy copies
- Email • Upon Filing
Jury Verdict Form
- 2 copies • Hand Delivery • Before Trial
Motion
- Email • Upon Filing
Reconsideration Motions
Adjournments
- To adjourn a motion, email the Court and copy opposing counsel rather than simply submitting a new notice of hearing.
- Adjournments of discovery dates or case tracks require a motion, except stipulated Track 1-to-Track 2 orders.
- A trial date may be adjourned only by motion and upon a showing of good cause.
- +2 more
Request must include
- Settlement-conference adjournment requests should be made by email at least one week in advance and require concurrence of all parties.
Communication
Chambers
Page & Word Limits2 rules
Checked against the court's document on Oct 3, 2026Mandatory
Attorneys need court approval for motions with briefs or responses with briefs over 20 pages; reply briefs are limited to five pages.
Attorneys must obtain Court approval to file any motion and brief or response and brief over 20 pages. Reply briefs are limited to 5 pages.
20 pages
Applies to: Attorney
Reply Brief
5 pages
Applies to: Attorney
Checked against the court's document on Oct 3, 2026Mandatory
Exhibits accompanying motions, responses, or replies are limited to 100 pages; exceeding that limit requires court permission by motion.
Exhibits are limited to 100 pages for MOTIONS, RESPONSES, AND REPLIES. Court permission (by filing a motion) must be obtained for exhibits exceeding 100 pages.
Motion
100 pages
Response
100 pages
Reply
100 pages
Document Format Requirements1 rule
Checked and corrected to match the court's document on Oct 3, 2026Mandatory
Counsel must email joint jury instructions as a Word document 48 hours before the final pretrial conference, with separate specified indexes and each instruction on its own page in 14-point font, tailored to the case and gender.
48 hours prior to the Final Pretrial Conference, Counsel shall email a Word Document copy of the joint jury instructions to the Judicial Attorney at Victoria.Lencione@3rdcc.org . The instructions shall include separate indexes titled “Preliminary Jury Instructions” and “Final Jury Instructions,” each index listing the JI number and title. Each instruction shall be on its own separate page, in size 14 font, case specific, and gender specific.
DOCX
Document Filing Requirements10 rules
Checked against the court's document on Oct 3, 2026Mandatory
The proposed JFPO must include the specified trial, claim, fact, law, damages, evidence, witness, and exhibit information in the stated order.
The proposed JFPO shall contain, under appropriate captions in the order indicated, the following:TRIAL DATE and TIME. PLAINTIFF’S CLAIMS: A concise statement of Plaintiff's claim, including third party plaintiff, claims and defenses including their legal theories upon which each claim or defense is based. DEFENDANT’S CLAIMS: A concise statement of Defendant's defenses and cross-claims, including claims of third-party Plaintiff(s), and defenses of third-party Defendant(s), including legal theories. STIPULATION OR ADMISSION OF FACTS: A recitation of any facts or other matters to which the parties have stipulated. ISSUES OF FACT: Issues of fact remaining to be litigated. ISSUES OF LAW: Issues of law to be litigated. DAMAGES: An itemized statement of special damages with authority to support. Further, Counsel will be requested to stipulate to those items not in dispute. EVIDENCE PROBLEMS LIKELY TO ARISE AT TRIAL: Include any remaining objections to exhibits and use of depositions. All motions in limine of which counsel or a party without counsel should reasonably be aware of at the time of preparation of the pre-trial order shall be listed in the joint final pre-trial order. WITNESSES AND EXHIBIT LISTS: indicate which witnesses will be called and which witnesses may be called. Failure to list witnesses may bar their production at trial. No witnesses shall be listed who have not been included on a prior witness list submitted pursuant to prior order of the Court except for good cause shown. Exhibits to be submitted for admission at trial shall be listed. Failure to list an exhibit on the JTPO without good cause will be excluded from trial.
Document Type
Joint Final Pretrial Order
Checked against the court's document on Oct 3, 2026Mandatory
After praecipe acceptance, serve and file a notice of hearing stating the correct date and whether oral argument will occur.
After the praecipe has been accepted, please serve and file a notice of hearing reflecting the correct date and whether the motion is to be heard with or without oral argument
Document Type
Notice Of Hearing
Checked against the court's document on Oct 3, 2026Mandatory
A motion to consolidate must be filed in both cases to be consolidated.
Please file motions to consolidate in BOTH cases you are trying to consolidate together.
Document Type
Motion To Consolidate
Checked against the court's document on Oct 3, 2026Mandatory
Pleadings must list Judge Elder as the judge or they will be rejected.
Counsel shall make sure Judge Elder is listed as the judge on all pleadings. Pleadings with prior judges listed will be rejected
Document Type
Pleading
Checked against the court's document on Oct 3, 2026Important
Do not file a proposed order as a separate filing with a motion; it may be attached as a proposed exhibit.
Please do not file proposed orders contemporaneously with your motion as a separate filing. You may attach the order as a proposed exhibit, but do not file it separately.
Document Type
Motion
Not confirmed. Read the court's wording below.Mandatory?
Must include a copy of the scheduling order and list all relevant dates (including the filing date) in the body of the Motion.
Summary: A motion to adjourn must include the scheduling order and list all relevant dates, including the filing date, in its body.
Document Type
Motion To Adjourn
Not confirmed. Read the court's wording below.Mandatory?
By 12:00pm the Thursday before trial, Counsel shall deliver a hard copy of the proposed voir dire questions to the courtroom and email a Word Document copy to the judicial attorney. Also email a copy to the judicial attorney.
Summary: By noon on the Thursday before trial, counsel must deliver hard copies of proposed voir dire questions to the courtroom and email a Word document copy to the Judicial Attorney.
Document Type
Voir Dire Questions
Not confirmed. Read the court's wording below.Mandatory?
Motions must include any relevant documents and an Affidavit of a person with knowledge of the facts and circumstances surrounding the relief requested.
Summary: A motion for default judgment must include relevant documents and an affidavit from a person with knowledge of the supporting facts and circumstances.
Document Type
Motion For Default Judgment
Not confirmed. Read the court's wording below.Mandatory?
ANY MOTION FOR SUMMARY DISPOSITION FILED OUTSIDE THESE TIMELINES WILL REQUIRE A MOTION FOR LEAVE TO BE FILED
Summary: A summary-disposition motion filed outside the applicable deadline requires a motion for leave.
Document Type
Motion For Summary Disposition
Not confirmed. Read the court's wording below.Mandatory?
Stipulations to opt out of case evaluation to facilitate are allowed ONLY with the consent of all parties and must contain the name of the facilitator AND a date for facilitation.
Summary: A stipulation opting out of case evaluation to facilitate requires all parties’ consent and must identify the facilitator and facilitation date.
Document Type
Stipulation
Filing & Service rules
Electronic Filing Rules
Motions in limine and responses must be e-filed by the trial-scheduling-order deadline; the Court schedules them for hearing before trial, and late filings will not be entertained.
Motions in Limine and responses shall be e-filed no later than the date in the Court's trial scheduling order, and will be heard on a date to be scheduled by the Court prior to trial, generally on the date of the Final Pretrial Conference. No late filed motions in limine will be entertained.
Checked against the court's document on Oct 3, 2026 · Civil cases
Page 1 | OTHER TRIAL ISSUES—Motions in Limine
Email copies of motions, responses, pretrial orders, and similar documents to the Court; do not mail hard copies of motions.
THIS IS A COMPLETELY ELECTRONIC COURTROOM. Email a copy of all Motions, Responses, Pre-Trial Orders, etc. to JudgeElder-Court@3rdcc.org. Please do not mail hard copies of motions to the Courtroom.
Checked against the court's document on Oct 3, 2026 · Civil cases
Page 1 | GENERAL PROTOCOL
Counsel must e-file the Joint Pre-Trial Order and email a copy to the Judicial Attorney.
Counsel shall e-file the Joint Pre-Trial Order. Also email a copy to the Judicial Attorney @ Victoria.Lencione@3rdcc.org
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | TRIAL
Filing Timing and Cure Windows
For cases with a discovery cutoff on or after January 1, 2025, dispositive motions must be filed within 60 days after discovery closes or are waived.
For any case with a discovery cut-off date of 1/1/2025 or after: All dispositive motions must be filed within 60 days after the close of discovery or are waived.
Checked against the court's document on Oct 3, 2026 · Civil cases
Page 1 | MOTIONS FOR SUMMARY DISPOSITION
For cases with a discovery cutoff on or before December 31, 2024, dispositive motions must be filed within 90 days after discovery closes unless an order specifies a different period.
For any case with a discovery cut-off date of 12/31/2024 or before: All dispositive motions must be filed within 90 days after the close of discovery UNLESS a different time period has been specified in an order
Checked against the court's document on Oct 3, 2026 · Civil cases
Page 1 | MOTIONS FOR SUMMARY DISPOSITION
Responses and replies are due by 4:30 p.m. on their due dates.
All due dates for responses or replies are due by close of business (4:30 PM) on the due date.
Checked against the court's document on Oct 3, 2026 · Civil cases
Page 1 | OTHER MOTION PRACTICE INFORMATION
Responses are due three days before the scheduled hearing date.
Responses are due 3 days ahead of scheduled hearing date
Checked against the court's document on Oct 3, 2026 · Civil cases
Page 1 | OTHER MOTION PRACTICE INFORMATION
Submit a praecipe with a proposed date after the motion is accepted; the clerk may assign the next available date if that date is full.
After the motion has been accepted by the clerk’s office, submit a praecipe with your proposed date. If that date has reached capacity, the Court clerk will change the date to our next available motion date.
Checked against the court's document on Oct 3, 2026 · Civil cases
Page 1 | MOTION PRACTICE: GENERAL
Generally, summary-disposition responses are due two weeks before the hearing and replies one week before it.
In general, the Court requires that all RESPONSES be due 2 weeks prior to the MSD hearing and all REPLIES be due 1 week prior to the MSD hearing.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | MOTIONS FOR SUMMARY DISPOSITION
A praecipe is required for rehearing or reconsideration motions; provide any Friday date 30 days in the future so the clerk can set a control date.
You must submit a Praecipe however so that the Clerk can set a control date. Give your Praecipe any Friday date, 30 days in future.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | OTHER MOTION PRACTICE INFORMATION
The moving party must submit a praecipe and notice of hearing with the firm date within three days after entry of the scheduling order.
The scheduling order will also direct the moving party to submit a praecipe and notice of hearing with the firm date within 3 days of entry of the scheduling order.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | MOTIONS FOR SUMMARY DISPOSITION
The joint final pretrial order is due five weeks before trial.
JOINT final pretrial order: Due 5 weeks before trial
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | TRIAL
Service and Proof of Service Rules
After praecipe acceptance, serve and file a notice of hearing with the correct date, time, and Zoom information, and file proof of service on the defaulted defendant.
After the praecipe has been accepted, please serve and file a notice of hearing reflecting the correct date and time and this Court's zoom information and file proof of service reflecting service of the notice of hearing on the defaulted Defendant.
Checked and corrected to match the court's document on Oct 3, 2026 · Civil cases
Page 1 | OTHER MOTION PRACTICE INFORMATION
Courtesy Copy Requirements
After filing a summary-disposition motion, email a Judge’s Copy to the Court with all counsel copied.
After the MSD is filed, please email a Judge’s Copy of the motion for summary disposition to JudgeElder-Court@3rdcc.orgwith all counsel copied.
Checked and corrected to match the court's document on Oct 3, 2026 · Civil cases
Page 1 | MOTIONS FOR SUMMARY DISPOSITION
Email a Judge Copy of all responses to the Court and copy the other side.
Email a Judge Copy of All Responses to JudgeElder-Court@3rdcc.orgwith the other side copied.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | OTHER MOTION PRACTICE INFORMATION
After clerk acceptance, send a Judge’s Copy of every motion by email and copy opposing counsel.
As stated above, this is a paperless courtroom. Upon acceptance by the clerk’s office, please submit a Judge’s Copy of the motion to JudgeElder-Court@3rdcc.org, copying opposing counsel. ALL MOTIONS REQUIRE JUDGE'S COPIES TO BE SENT TO THIS EMAIL ADDRESS.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | MOTION PRACTICE: GENERAL
For rehearing or reconsideration motions, notify the clerk and email a Judge’s Copy to the Court because the Court otherwise receives no notice of filing.
Provide a Judge's Copy to JudgeElder-Court@3rdcc.org for review. The Court does not receive notice that this type of motion is filed unless the attorney notifies the clerk and provides a Judge's Copy.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | OTHER MOTION PRACTICE INFORMATION
Counsel must stipulate to a joint verdict form before trial and deliver two hard copies and email a Word document copy by the Thursday before trial.
Counsel shall stipulate to a joint jury verdict form in advance of trial and, by the Thursday before trial, deliver two hard copies to the courtroom and email a Word Document copy to the judicial attorney.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | OTHER TRIAL ISSUES—Jury Verdict Form
Filing Bundling Requirements
The JFPO must be a single joint document; separate proposals by each side will not be accepted.
The JFPO must be one document. THE COURT WILL NOT ACCEPT SEPARATE DOCUMENTS PROPOSED BY EACH SIDE.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | TRIAL
Pre-Motion Conference Requirements
All summary-disposition motions are heard with oral argument.
All Motions for Summary Disposition shall be heard WITH oral argument.
Checked and corrected to match the court's document on Oct 3, 2026 · Civil cases
Page 1 | MOTIONS FOR SUMMARY DISPOSITION
Non-dispositive motions may not have reply or supplemental briefs unless the Court grants leave.
For non-dispositive motions, pursuant to MCR 2.119(A)(2)(b), no reply briefs or supplemental briefs are allowed without leave of the Court.
Checked and corrected to match the court's document on Oct 3, 2026 · Civil cases
Page 1 | OTHER MOTION PRACTICE INFORMATION
Responses to rehearing or reconsideration motions are not permitted unless the Court specifically allows them.
Pursuant to MCR 2.119(F)(2), no responses are permitted unless the Court specifically allows them.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | OTHER MOTION PRACTICE INFORMATION
The Court will set a firm hearing date and response deadlines in a scheduling order.
The Court will issue a scheduling order with a firm date and deadlines for responses to be filed.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | MOTIONS FOR SUMMARY DISPOSITION
Adjournment & Extension Requirements
Adjournments of discovery dates or case tracks require a motion, except stipulated Track 1-to-Track 2 orders.
All adjournments of discovery dates and/or track (other than stipulated orders to adjourn from Track 1 to Track 2) must be by way of motion.
Checked against the court's document on Oct 3, 2026 · Civil cases
Page 1 | GENERAL OPERATIONS
A trial date may be adjourned only by motion and upon a showing of good cause.
Trial dates, once set, will not be adjourned without a motion and a showing of good cause
Checked against the court's document on Oct 3, 2026 · Civil cases
Page 1 | GENERAL OPERATIONS
To adjourn a motion, email the Court and copy opposing counsel rather than simply submitting a new notice of hearing.
If you wish to adjourn your motion, please email the Court (see above) and copy opposing counsel to let us know. Please do not just submit a new notice of hearing.
Checked against the court's document on Oct 3, 2026 · Civil cases
Page 1 | Motion filing information
Parties may stipulate to one motion adjournment; if they cannot proceed on the rescheduled date, the motion is dismissed but may be refiled, and adjournment requests must be made to the courtroom.
Parties are able to stipulate to one adjournment. If the parties are unable to proceed with the Motion after the adjourned date, then the Motion will be dismissed and may be refiled at a later date. Please contact the courtroom for adjournment requests, do not just file a new notice of hearing.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | OTHER MOTION PRACTICE INFORMATION
Settlement-conference adjournment requests should be made by email at least one week in advance and require concurrence of all parties.
Adjournment of settlement conference: Requests should be made at least 1 week in advance* Parties should contact the Court by email at least 1 week in advance. All of the parties must concur with the request for the adjournment
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | GENERAL OPERATIONS
Current Track One cases may move to Track Two by mutual stipulation, with the dispositive-motion cutoff stated as 60 days after discovery closes; other adjournments require a motion.
All current Track One cases may be adjourned to Track Two by mutual stipulation. Please include in your order to adjourn from Track 1 --> Track 2 the dispositive motion cut off date, which will be 60 days after the close of discovery. All other requests for adjournments may only be adjourned by way of motion.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | STIPULATIONS
Chambers Communication Rules
Use the general court email only for the listed purposes and copy counsel for all parties.
Please use this email only for the following purposes – Please copy counsel for all parties on emails to this address - Judge’s copies of motions and responses - Email notification that a motion has been resolved - Email notification a motion or other hearing needs to be adjourned - Email notification that a case has settled - Interpreter requests (see below)
Checked against the court's document on Oct 3, 2026 · Civil cases
Page 1 | GENERAL INFORMATION
Settlement and motion-withdrawal notices require a confirmation email to the Court with all parties copied; a phone call does not replace the email.
If you are informing the Court that a case has settled or a motion has been withdrawn, a confirmation email to JudgeElder-Court@3rdcc.org with all parties copied is required. Please do not call the Courtroom, as we will still ask for a confirming email.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | GENERAL PROTOCOL
All communications must include the hearing date and case number in the subject line.
Include date of hearing and case number in the subject line of all communication.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | GENERAL PROTOCOL
Interpreter requests must be emailed at least 14 days before the hearing and include the specified case and language information.
If a party needs an interpreter for a hearing or trial, please contact the court at JudgeElder-Court@3rdcc.orgat least 14 days before the hearing with the case name, case number, party requesting the interpreter, and language requested.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | GENERAL INFORMATION
Opposing counsel must be copied on all communications with the Court.
Copy opposing counsel on all communication with the Court.
Not confirmed. Read the court's wording below. · Civil cases
Page 1 | GENERAL PROTOCOL