Motions to amend pleadings must comply with E.D. Mich. LR 15.1. Specifically, the moving party is required to reproduce the entire proposed amended pleading and may not incorporate any prior pleading by reference.

The moving party must file the entire proposed amended pleading as an attachment to any motion under Federal Rule of Civil Procedure 15. The attachment must in some way identify the revisions to the pleading. For example, proposed changes can be highlighted, underlined, or filed in a tracked-changes format.