Motion Practice

Print Guideline

  1. Page Extensions : Page extensions are not routinely granted. The Court generally adheres to the page limits provided in E.D. Mich. LR 7.1.

  2. Time Extensions : The Court, along with counsel for the parties, is responsible for advancing cases toward prompt and just resolutions. To that end, the Court seeks to set reasonable but firm deadlines. Motions and stipulations for extension will not be granted as a matter of course. Parties seeking an extension should explain with specificity the unanticipated or unforeseen circumstances necessitating the extension and should set forth a timetable for the completion of the tasks for which the extension is sought.

  3. Briefing Schedule : The Court does not issue a briefing schedule. The Court enforces the response and reply due dates in E.D. Mich. LR 7.1(e) and Fed. R. Civ. P. 6 even when a motion hearing is set far in advance.

  4. Content : Parties are to support the statement of material facts with citations to pleadings, interrogatories, admissions, depositions, affidavits, or documentary exhibits. Counsel should submit the cited pages of deposition transcripts along with the pages immediately adjacent to the cited material. If more than five pages are cited, or if the deposition is particularly relevant for adjudication, the entire deposition transcript should be included. When applicable, specific references in cited material should be underlined or highlighted. Parties should focus their analyses on well-chosen legal authority rather than boilerplate recitations. If unpublished opinions or opinions published only in specialty reporters are cited, copies of these cases must be submitted with the briefs.

  5. Non-Dispositive Motions : If non-dispositive motion papers (including any responses and replies) include exhibits totaling more than 50 pages, a courtesy copy should be submitted directly to judge's chambers of those papers. See formatting instructions below at 8.

  6. Dispositive Motions : The Court Clerk will send out a notice of the hearing date. Oral argument is scheduled approximately 10 weeks from the date of filing. A courtesy copy of all dispositive motion papers, as defined in E.D. Mich. LR 7.1(d)(1)(A), (including responses and replies) and all accompanying exhibits must be submitted directly to the Judge’s chambers. See formatting instructions below at 8.

  7. Separate Motion and Brief : Pursuant to E.D. Mich. LR 7.1(d)(1), motions and responses should be accompanied by a separate brief. Detailed legal argumentation and factual summaries should be reserved for the brief and should not be included in the text of the motion or response. Motions may not be included within or appended to a response or reply, and under no circumstances may a motion be included within the text or footnotes of another motion.

  8. Courtesy Copy Formatting :

    Courtesy copies should be provided with the .pdf header printed across the top of the page. Exhibits must have labels attached that extend beyond the right hand side of the paper. Motion papers must be bound along the left margin (“Book-style”) with binding combs, zip-band binding spines or wire binding spines. Courtesy copies that do not comply with formatting requirements, including exhibit tabs and book-style binding, will be returned for reformatting before they will be considered.

    The courtesy copy must be sent to chambers the same day the document is e-filed, unless it relates to a court proceeding scheduled within the following five days or otherwise requires the immediate attention of the Court, in which case the chambers copy must be hand-delivered in chamber no later than the morning of the next business day after the document is e-filed.