Judge Martha M. Snow
Individual Rules, Standing Orders & Policies
Limits & Logistics
Document Limits
Courtesy Copies
Motion
- 1 copy
- 1 copy • Chambers Drop Off • No Later Than 7 Days Before Hearing
Motion, Summary Disposition Motions
- 1 copy • Within 3 Days of Order Entry
Response
- 1 copy • No Later Than 3 Days Before Hearing
Response, Reply, Summary Disposition Motions
- 1 copy • Within 3 Days of Filing
Adjournments
- Only the moving party may request an adjournment of a Motion. The moving party must contact the Court's Clerk to request a new date. Motions may only be adjourned twice. Thereafter, the motion will be dismissed but may be refiled. After obtaining a new date from the Court Clerk, the moving party must file and serve a Re-Notice of Hearing indicating the new date.
- Only the moving party may adjourn summary disposition oral argument by contacting the Court's Judicial Attorney; adjournment is granted only for good cause and requires a filed and served Re-Notice of Hearing.
- Adjournment of a Settlement Conference requires filing a motion; Judge Snow will not accept a stipulated Order for this purpose.
- +3 more
Request must include
Page & Word Limits2 rules
Additionally, exhibits must be limited to 100 pages. Permission must be obtained from the Court for exhibits exceeding 100 pages.
- Exhibits
- Up to 100 pages
Pursuant to MCR 2.119(A)(2)(a), "the combined length of any motion and brief, or of a response and brief, may not exceed 20 pages double spaced, exclusive of attachments and exhibits."
- Motion and brief
- Up to 20 pages in total
- Response and brief
- Up to 20 pages in total
- Format
- Double-spaced
- Motion
- Brief
- Response
Excluded from page count
- •Attachments
- •Exhibits
Document Format Requirements4 rules
All motions, responses, and replies, along with any corresponding brief and any and all exhibits, must be bound together as one (1) single document. Merely using a binder clip, rubber band, or box is insufficient and will be rejected by the Court. Staples or two prong fasteners are sufficient.
- Binding
- Stapled
- Motion
- Response
- Reply
- Brief
- Exhibits
Formatting
- •Binder clips, rubber bands, or boxes are insufficient and will be rejected
Any and all exhibits attached to a brief must be tabbed. Failure to comply may result in the entire brief being stricken.
The FPTO must be bound together as one (1) single document.
Counsel are required to email the same in Word Document Format to lisa.damphousse@3rdcc.org.
- File type
- Word
Document Filing Requirements25 rules
The moving party must attach a proposed Judgment to the motion as an exhibit.
- Document
- Motion for entry of default judgment
Must include
- •Proposed order
A Notice of Hearing and a Praecipe are required for each motion.
Any order or judgment that disposes of a claim must state whether or not it is a final order closing the case pursuant to MCR 2.602(A)(3).
All pleadings and orders must contain correct captions including the correct Judge's name. Pleadings and orders with incorrect captions will be rejected and the attorney using the incorrect caption will be subject to sanctions.
- Document
- Pleadings and orders
Must include
- •Caption
- •Judge name
A stipulated Order of Consolidation must include all case names and numbers, designate the oldest case as controlling, state the consolidation purpose, direct future pleadings to the controlling case number, and instruct the clerk to add all parties from non-controlling cases.
Court's wording
The stipulated Order of Consolidation must include all case names and case numbers, must indicate the oldest case first as the controlling case, and must state whether the cases are being consolidated for discovery purposes, for trial, or for all purposes. The stipulated Order of Consolidation must also indicate that all future pleadings shall be filed under the controlling case number only. The stipulated Order of Consolidation must also instruct the clerk to add all parties in the non-controlling case(s) as parties within the controlling case.
When filing a motion for summary disposition, the Notice of Hearing shall state that the hearing will be set on a "date to be determined."
Once the moving party receives the Summary Disposition Scheduling Order, the moving party must file and serve a Re-Notice of Hearing for the date provided by the Court in the Summary Disposition Scheduling Order.
A proposed scheduling Order indicating specific depositions to be taken with dates certain scheduled, specific discovery to be completed with deadlines scheduled, and specifically stating any other outstanding issues must be attached to the motion. The proposed Order must also contain a firm facilitation date and a sentence containing a blank space where the clerk will then provide your next Settlement Conference date.
Orders which contain an incorrect caption or the incorrect Judge will not be signed.
The caption on each pleading must contain the contact information of all of the attorneys who have appeared on the case including direct phone numbers and email addresses for each attorney.
- Document
- Pleading
- Placement
- Caption
Judge Snow will not grant this type of relief via stipulated Order. You must file a motion.
A proposed scheduling order indicating specific depositions to be taken with dates certain scheduled, specific discovery to be completed with deadlines scheduled, and specifically stating any other outstanding issues must be attached to the motion.
The consolidation order e-filed in the controlling case must not be final, while the order e-filed in each non-controlling case must state it is a final order closing the case; noncompliance leads to rejection, striking, severance, and sanctions.
Court's wording
The Order of Consolidation that is e-filed in the controlling case number should not be a final Order. However, the Order(s) of Consolidation that is e-filed in the non-controlling case number(s) must indicate that it is a final Order closing the case. Failure to comply will result in the pleadings or orders being rejected, being stricken from the record, or with the cases being severed, and the attorneys will be subject to sanctions.
Motions containing incorrect captions or the wrong Judge may be dismissed.
- Document
- Motion
Include
- •Caption
A proposed order for alternate service must include all three alternate service methods (first-class mail, door tacking, and communication via text/email/Facebook with the exact quoted language) and must not include certified mail with return receipt, restricted delivery.
Court's wording
When submitting a motion for alternate service and an accompanying proposed Order for the same, your proposed Order MUST INCLUDE ALLOF THE FOLLOWING METHODS OF ALTERNATE SERVICE unless Judge Snow specifically orders otherwise: 1) mailing via first class mail to the last known address for the Defendant, 2) tacking on the door at the last known address for the Defendant, and 3) communication of the pleadings via "text, email, and/or Facebook to the Defendant, if known." This quoted language MUST be included in your Order. SERVICE MUST BE ACCOMPLISHED BY EVERY METHOD OF SERVICE ORDERED. Also, DO NOT include service via certified mail with return receipt, restricted delivery on your proposed Order for alternate service.
All counsel of record must sign a stipulated order to dismiss a party.
Proposed Orders should be attached to the motion/response as well as brought to the motion hearing.
- Document
- Motion
Should include
- •Proposed order
The attorney appearing on or handling a motion must be listed first on that party's caption, and no-fault cases must have a primary attorney assigned.
- Placement
- Caption
Court's wording
The attorney who plans to appear on a motion, or the attorney who should be contacted by the court with regard to a motion, must be the first attorney listed on the caption for the respective party. On no-fault cases, a primary attorney must be assigned to each case.
Parties who are dismissed from an action must remain on the caption with a strike-through line over their name to indicate to the Court that they have been dismissed from the case.
- Placement
- Caption
Transcript exhibits must include the entire transcript in mini script form with referenced portions clearly indicated, precise citations in the brief, and cited portions clearly highlighted in the exhibit.
Court's wording
If a transcript is attached as an exhibit, the entire transcript (in mini script form) must be included as an attachment with the referenced portion(s) clearly indicated. Precise citations to the specific portions used to support your argument must be included in your brief, and cited portions of the transcript must be clearly highlighted within the exhibit.
If you are not able to get a stipulation, you must file a Motion for Consolidation into each case number that you are trying to consolidate. The motion must include all of the details explained above. Please also submit a praecipe for each motion filed requesting the same date and time so that the motions are scheduled to be heard together.
Medical documentation exhibits require precise citations in the brief and clearly highlighted cited portions within the exhibit.
Court's wording
If medical documentation is attached as an exhibit, precise citations to the specific portions used to support your argument must be included in your brief, and cited portions of the medical documentation must be clearly highlighted within the exhibit.
When preparing an Order delineating the Court's ruling on your motion, you must clearly indicate the hearing date when oral arguments were held on your motion in the preamble of your Order.
The proposed intervening party must provide the court with the amount of their proposed claim in the body of the motion. The moving party must attach a copy of the Status Conference Scheduling Order, the current scheduling order (if different), and must list all relevant dates (including the case filing date and the Case Evaluation date) in the body of the motion.
When submitting an order following a motion hearing, please indicate in the 'Filer Comments' that the order is being submitted consistent with the Court's ruling and indicate the date of that hearing.
Filing & Service rules
Electronic Filing Rules
Counsel must email the proposed joint jury instructions and verdict form in Word Document Format to lisa.damphousse@3rdcc.org.
Counsel are required to email the same in Word Document Format to lisa.damphousse@3rdcc.org.
Civil cases
Page 1 | Proposed Joint Jury Instructions and Proposed Joint Verdict Form
The Order of Consolidation must be e-filed under every case number included in the consolidation.
The Order of Consolidation must then be e-filed under each case number included within the consolidation.
Civil cases
Page 1 | Motions for Consolidation
Orders must be filed in accordance with the e-filing guidelines published on the Court website.
Orders must be filed in accordance with the e-filing guidelines which can be found on the Court website.
Civil cases
Page 1 | General Motion Practice Procedure
Filing Timing and Cure Windows
Briefs for motions in limine are due one week (7 days) before the hearing date.
Briefs for any motions in limine are due one (1) week in advance of the hearing date.
Civil cases
Page 1 | Motions in Limine
If Case Evaluation is not appropriate, summary disposition motions are due 30 days after the close of discovery; if the case was sent to facilitation instead, they are due 30 days after facilitation.
If a determination has been made that Case Evaluation is not appropriate for your case, then all motions for summary disposition must be filed no later than 30 days after the close of discovery. If the case has been sent to facilitation in lieu of Case Evaluation, then all motions for summary disposition must be filed no later than 30 days after facilitation.
Civil cases
Page 1 | Motions for Summary Disposition Procedure
The praecipe for a summary disposition motion must select a Thursday at 11:00 a.m. at least 60 days from the praecipe submission date.
When filing the praecipe, the moving party shall select a Thursday date, at 11:00 a.m., that is no less than 60 days from the date the praecipe is being submitted.
Civil cases
Page 1 | Motions for Summary Disposition Procedure
Proposed joint jury instructions and the proposed joint verdict form are due by 8:30 a.m. on the Thursday before trial.
Proposed joint jury instructions and proposed joint verdict form are due by 8:30 a.m. on the Thursday before trial.
Civil cases
Page 1 | Proposed Joint Jury Instructions and Proposed Joint Verdict Form
A Response to a motion shall be filed and served, and the Court prefers that a courtesy 'Judge's Copy' also be delivered to Courtroom 1821, no later than three (3) days prior to the hearing date pursuant to MCR 2.119(C)(2)(a-b).If a response to a motion is not timely filed, the Court will treat the motion as unopposed and oral argument may not be permitted.Costs and attorney fees may be awarded as allowed by law.
A Response to a motion shall be filed and served, and the Court prefers that a courtesy 'Judge's Copy' also be delivered to Courtroom 1821, no later than three (3) days prior to the hearing date pursuant to MCR 2.119(C)(2)(a-b).If a response to a motion is not timely filed, the Court will treat the motion as unopposed and oral argument may not be permitted.Costs and attorney fees may be awarded as allowed by law.
Civil cases
Page 1 | General Motion Practice Procedure
The Final Joint Pretrial Order is due at the date and time set for the Final Joint Pretrial Conference.
A Final Joint Pretrial Order is due at the date and time set for your Final Joint Pretrial Conference.
Civil cases
Page 1 | Final Joint Pretrial Order
Motions for summary disposition must be filed no later than 30 days after Case Evaluation.
All motions for summary disposition must be filed no later than 30 days after Case Evaluation.
Civil cases
Page 1 | Motions for Summary Disposition Procedure
Motions pursuant to MCL 500.3112 are not permitted before disbursement of settlement funds.
Pursuant to the ruling of the Michigan Supreme Court in Covenant Medical Center, Inc. vs. State Farm Mutual Automobile Insurance Company, 500 Mich. 191(2017), Judge Snow no longer permits this type of motion prior to a disbursement of settlement funds.
Civil cases
Page 1 | Motions pursuant to MCL 500.3112
A praecipe for a motion for reconsideration must select the next business day at 9:00 a.m. as the hearing date.
The moving party must file a praecipe and select the next business day at 9:00 a.m. as the hearing date in order to bring the motion to the Court's attention.
Civil cases
Page 1 | Motions for Reconsideration
Summary Disposition Scheduling Orders are issued only after the motion has been e-filed and the Praecipe has been accepted.
Summary Disposition Scheduling Orders will only be issued after the motion has been e-filed and the Praecipe has been accepted.
Civil cases
Page 1 | Motions for Summary Disposition Procedure
Orders e-filed on the day the motion was heard are considered presented to the Court under MCR 2.602(B)(1); all other orders must be submitted as otherwise permitted in MCR 2.602.
Orders submitted through e-filing on the day the motion was heard will be considered as having been presented to the Court pursuant to MCR 2.602(B)(1).All other orders must be submitted as otherwise permitted in MCR 2.602.
Civil cases
Page 1 | General Motion Practice Procedure
Service and Proof of Service Rules
Any motion filed shall be served, and the Court prefers that a courtesy 'Judge's Copy' also be delivered to Courtroom 1821, no later than seven (7) days prior to the hearing date pursuant to MCR 2.119(C)(1)(a-b).
Any motion filed shall be served, and the Court prefers that a courtesy 'Judge's Copy' also be delivered to Courtroom 1821, no later than seven (7) days prior to the hearing date pursuant to MCR 2.119(C)(1)(a-b).
Civil cases
Page 1 | General Motion Practice Procedure
Service must be accomplished by every method of service ordered by the Court.
SERVICE MUST BE ACCOMPLISHED BY EVERY METHOD OF SERVICE ORDERED.
Civil cases
Page 1 | Motions for Alternate Service
A motion for alternate service is appropriate only after personal service, certified mail with return receipt restricted delivery, and a postal address verification check have all been attempted/completed.
A motion for alternate service is only appropriate after all three (3) of the following have been completed: 1) personal service has been attempted, 2) service via certified mail with return receipt, restricted delivery has been attempted, and 3) a postal address verification check with the post office has been completed.
Civil cases
Page 1 | Motions for Alternate Service
The Status Conference Scheduling Order is served electronically on counsel of record, and Plaintiff's counsel is responsible for ensuring service on the Defendant.
The Court shall issue a Status Conference Scheduling Order which shall be signed, filed, and served electronically upon counsel of record. However, it is the responsibility of Plaintiff's counsel to ensure service upon the Defendant.
Civil cases
Page 1 | Status Conference Procedure
Courtesy Copy Requirements
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.
A courtesy 'Judge's Copy' of all response(s) and reply briefs shall be delivered to Courtroom 1821 within three (3) days of the date that it is filed. Failure to comply may result in the response or the reply being stricken.
Civil cases
Page 1 | Motions for Summary Disposition Procedure
The moving party shall deliver a courtesy 'Judge's Copy' of the motion to Courtroom 1821 within three (3) days of the date of entry of the Order. Failure to comply may result in a dismissal of the motion.
The moving party shall deliver a courtesy 'Judge's Copy' of the motion to Courtroom 1821 within three (3) days of the date of entry of the Order. Failure to comply may result in a dismissal of the motion.
Civil cases
Page 1 | Motions for Summary Disposition Procedure
A Judge's Copy of a motion for reconsideration must be provided directly to the courtroom.
The moving party shall also provide a 'Judge's Copy' of the motion directly to the courtroom.
Civil cases
Page 1 | Motions for Reconsideration
The Court prefers that a courtesy Judge's Copy of each motion be delivered to Courtroom 1821 no later than 7 days before the hearing date.
Any motion filed shall be served, and the Court prefers that a courtesy 'Judge's Copy' also be delivered to Courtroom 1821, no later than seven (7) days prior to the hearing date pursuant to MCR 2.119(C)(1)(a-b).
Civil cases
Page 1 | General Motion Practice Procedure
The Court prefers that a courtesy Judge's Copy of each response be delivered to Courtroom 1821 no later than 3 days before the hearing date.
A Response to a motion shall be filed and served, and the Court prefers that a courtesy 'Judge's Copy' also be delivered to Courtroom 1821, no later than three (3) days prior to the hearing date pursuant to MCR 2.119(C)(2)(a-b).
Civil cases
Page 1 | General Motion Practice Procedure
Adjournment & Extension Requirements
Only the moving party may adjourn summary disposition oral argument by contacting the Court's Judicial Attorney; adjournment is granted only for good cause and requires a filed and served Re-Notice of Hearing.
Only the moving party may request an adjournment of oral argument on a motion for summary disposition. The moving party must contact the Court's Judicial Attorney to request a new date. Motions for summary disposition will only be adjourned for good cause. After obtaining a new date from the Judicial Attorney, the moving party must file and serve a Re-Notice of Hearing indicating the new date for oral argument.
Civil cases
Page 1 | Motions for Summary Disposition Procedure
Adjournment of a Settlement Conference requires filing a motion; Judge Snow will not accept a stipulated Order for this purpose.
If you would like to request an adjournment of your Settlement Conference, you must file a motion. Judge Snow will not accept a stipulated Order for this purpose.
Civil cases
Page 1 | Settlement Conference Procedure
Scheduled trial dates will not be adjourned without a motion and a showing of good cause.
Trial dates, once scheduled, will not be adjourned without a motion and a showing of good cause.
Civil cases
Page 1 | Settlement Conference Procedure
A motion to extend a Status Conference Scheduling Order must show good cause, address outstanding discovery issues, attach the scheduling order(s), list all relevant dates including the filing and Case Evaluation dates, and all counsel must be present.
A motion is required to extend a Status Conference Scheduling Order. That motion must address all outstanding discovery issues or any other matters that prevent the parties from completing the case within the given deadlines. The motion must also show good cause for the adjournment. The party seeking the adjournment of the scheduling order must attach a copy of the Status Conference Scheduling Order, the current scheduling order (if different), and must list all relevant dates (including the case filing date and the Case Evaluation date) in the body of the motion. ALL COUNSEL MUST BE PRESENT FOR THIS TYPE OF MOTION.
Civil cases
Page 1 | Motions to Adjourn Status Conference Scheduling Orders
Extending a Status Conference Scheduling Order requires a motion showing good cause, addressing outstanding discovery issues, attaching the scheduling order, and listing all relevant dates including the case filing date.
A motion is required to extend a Status Conference Scheduling Order. That motion must address all outstanding discovery issues or any other matters that prevent the parties from completing the case within the given deadlines. The motion must also show good cause for the adjournment. The party seeking the adjournment of the scheduling order must attach a copy of the Status Conference Scheduling Order and must list all relevant dates (including the case filing date) in the body of the motion.
Civil cases
Page 1 | Status Conference Procedure
Only the moving party may request an adjournment of a Motion. The moving party must contact the Court's Clerk to request a new date. Motions may only be adjourned twice. Thereafter, the motion will be dismissed but may be refiled. After obtaining a new date from the Court Clerk, the moving party must file and serve a Re-Notice of Hearing indicating the new date.
Only the moving party may request an adjournment of a Motion. The moving party must contact the Court's Clerk to request a new date. Motions may only be adjourned twice. Thereafter, the motion will be dismissed but may be refiled. After obtaining a new date from the Court Clerk, the moving party must file and serve a Re-Notice of Hearing indicating the new date.
Civil cases
Page 1 | General Motion Practice Procedure