Motions to amend pleadings must comply with E.D. Mich. L.R. 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 Fed. R. Civ. P. 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.