Third Judicial Circuit Court of Michigan Filing Rules

The Final Pre-Trial Order must list issues of law to be litigated.

A stipulated order dismissing a party must be signed by all counsel of record.

A written motion is required to amend the Joint Final Pre-Trial Order.

Motions and orders for substitution of counsel must contain the specified language preserving previously scheduled dates.

The stipulated order must include the discovery completion deadline, ADR completion date, and facilitator or mediator’s name.

Motion call is held on Fridays at 9:00 a.m.

If appellate scheduling order is not received within 10 business days from filing the appeal, contact the Court's office.

All motions in limine must be filed and heard no later than three weeks before trial.

Summary disposition motions must be filed within 18 months of the complaint; later filings require a motion for leave, and no hearing within 30 days of trial.

Motions pursuant to MCL 500.3112 are not permitted before disbursement of settlement funds.

Adjournment of Track III must be by motion and cannot be combined with any other motion.

Requests for extension of the appellate briefing schedule are determined on a case-by-case basis.

A trial date may be adjourned only by motion and upon a showing of good cause.

Adjournment of case evaluation requires a motion.

The moving party may request an adjournment through the law clerk, who will determine the next available date.

If the case settles or issues are resolved, the moving party must inform the court immediately.

Email is the preferred communication method and must include all parties, the case name and number in the subject, and the contact person's cellphone number.

Requests for informal email or phone communication with the judge must be coordinated through the judicial attorney or law clerk.

To request a hearing date, email or call the Courtroom after filing the motion; motions are usually heard on Mondays or Thursdays and scheduling is 2-3 months ahead.

Email is the preferred method for all inquiries to the court.

After clerk approval, email a Judge’s Copy of the motion; its exhibits may total no more than 20 pages, must be necessary and highlighted, and full exhibits remain attached to the filed motion.

Judge's copies of motions, responses, and replies must be mailed or dropped off with labeled exhibits; all copies must be bound; failure will result in non-consideration.

Parties must provide courtesy Judge's Copies of the summary disposition motion, responses, and reply briefs to Judge Sullivan's courtroom.

Email a Judge Copy of all responses to the Court and copy the other side.

Courtesy Judge's Copies of all responses and reply briefs must be delivered to Courtroom 1821 within 3 days of filing, or they may be stricken.

Submit the praecipe through the Court website after the filing is entered.

Emergency motions may be filed electronically.

Paper copies of motions and responses are not required to be filed.

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.

The notice of hearing and praecipe must be e-filed separately.

Pro se parties without MiFile email must be served by mail at least 10 days before hearing, with proof of service e-filed at least 7 days prior.

Counsel must accept email service; service is effective upon transmission unless the sender knows the email was not received.

Every filed motion must be served no later than 7 days before the hearing date pursuant to MCR 2.119(C)(1)(a-b).

Responses, briefs, and replies must be filed and served as required by MCR 2.116(G)(1)(a).

The party serving an order for alternate service must verify the postal address.

All judge's copies must be bound.

Electronically produced documents must presumptively be produced in native format with load files preserving all metadata.

Proposed joint jury instructions and the proposed joint verdict form must be submitted in Word Document Format.

Exhibits must be labeled and sent as individual PDFs or photos; multiple exhibits must not be combined into one document.

Exhibits must be tabbed to be accepted by the court.

Exhibits on the emailed Judge Copy for summary disposition motions are limited to 20 pages total and must be highlighted.

Reply briefs for summary disposition motions are limited to five pages.

Exhibits are limited to 100 pages; court permission is required for exhibits exceeding 100 pages.

Attorneys need court approval for motions with briefs or responses with briefs over 20 pages; reply briefs are limited to five pages.

Motions and briefs for summary disposition cannot exceed 25 pages; exceeding the limit requires leave from the court.

If case evaluation is not accepted, counsel and self-represented litigants must appear by Zoom for a first settlement conference 42 days after case evaluation.

Responses to rehearing or reconsideration motions are not permitted unless the Court specifically allows them.

Motions concerning expert credentials or Daubert issues are treated as summary-disposition motions and must follow that motion’s scheduling and procedural requirements.

Parties who miss the court-rule time limits for opting out of case evaluation must file a motion.

Cases are referred to non-binding mediation before evidentiary hearings or trials; a telephone case management conference may be held if stipulated.

When materials are designated Confidential on the record, the court reporter must note it on the cover page, list pages/lines/exhibits, bind the transcript in separate portions, and unauthorized persons must be excluded during discussion of Confidential information.

Subsequent motions must be filed separately and the appropriate fee paid.

Pro hac vice admission requires verification from the State Bar of Michigan that all fees are paid and requirements met before the hearing.

The JFPO must be a single joint document; separate proposals by each side will not be accepted.