Judge Susan L. Hubbard
Individual Rules, Standing Orders & Policies
Limits & Logistics
Courtesy Copies
Courtesy copies
- 1 copy • Email
Document Filing Requirements26 rules
ISSUES OF LAW: Issues of law to be litigated.
No responses are permitted unless authorized by the court.
The Final Pre-Trial Order must include a concise statement of defendant's defenses and claims.
Court's wording
DEFENDANT’S CLAIMS: a concise statement of defendant’s defenses and claims, including cross-claims and/or claims of third-party plaintiffs, and defenses of cross-defendants and/or third-party defendants, including legal theories.
VERDICT FORM: Include a verdict form listing all possible verdicts.
submit the praecipe with a "placeholder" hearing date on a Thursday at 9:30 am, at least 42 days after the motion filing date.
The Final Pre-Trial Order must include all requested jury instructions, special instructions with legal authority, and plaintiff's counsel must provide copies for jury use.
Court's wording
JURY INSTRUCTIONS: Provide the court with a copy of all requested jury instructions. If any party is requesting a special jury instruction include in the Final Pre-Trial Order a written copy of the special instruction and supporting legal authority. Note: per the Court’s protocol, plaintiff’s counsel is responsible for providing copies of the jury instructions for jury use during deliberation.
PLAINTIFF’S CLAIMS: a concise statement of plaintiff’s claims, including legal theories.
No witnesses shall be listed who have not been included on any written list submitted pursuant to prior court order except for good cause shown.
The Final Pre-Trial Order must include stipulations or admissions of facts in separately numbered paragraphs.
Court's wording
STIPULATIONS OR ADMISSIONS OF FACTS: a recitation of any facts or other matters to which the parties have stipulated or admitted. The parties shall state, in separately numbered paragraphs, all uncontested facts.
The Final Pre-Trial Order must include estimated trial length, jury/non-jury designation, and unanimous verdict requirement.
Court's wording
ESTIMATED LENGTH OF TRIAL: Estimated time for plaintiff’s proofs Estimated time for defendant’s proofs Indicate whether it is a jury or non-jury trial If a jury trial, indicate if a unanimous verdict of not less than 5 jurors.
SIGNATURE LINE: Include signature lines for the judge and all counsel of record.
Final Pre-Trial Order: Must be filed by the due date in the final trial scheduling order and must conform to the requirements as set forth below.
Each party will indicate which witnesses will be called and which witnesses may be called. Generic listing of witnesses such as “all or any employees of the defendant or plaintiff” is not acceptable.
The Final Pre-Trial Order must include an itemized statement of damages with specific requirements for first-party benefits and intervening plaintiffs.
Court's wording
DAMAGES: An itemized statement of damages. Plaintiff shall specify all those claimed damages that can be calculated from objective data. If plaintiff is asserting a claim for first party benefits, the plaintiff shall identify the amount and category or each type of benefit. Intervening plaintiffs must specifically list the amount and breakdown of their claims.
ISSUES OF FACT: Issues of fact remaining to be litigated.
When listing witnesses, parties should identify all expert witnesses and designate whether they are testifying in person or by deposition.
Failure to list witnesses may bar their production at trial.
The parties shall number and with a short identifying description, each exhibit they intend to introduce at trial.
Plaintiff’s attorney must bring 1 copy of the jury instructions to be read at trial.
Praecipes: must be filed for every motion or it will not be scheduled.
The Final Pre-Trial Order must include specific concluding language warning of consequences for non-compliance.
Court's wording
CONCLUDING ORDER LANGUAGE: Include the following language at the end of the Final Pre-Trial Order above the signature line: “This order constitutes a duly entered order of this court, and failure of counsel or a party without counsel to cooperate in the preparation of, to submit, or to comply strictly with all the terms of the joint Final Pre-Trial Order, may result in refusal to let witnesses testify or to admit exhibits, dismissal of claims, striking of answers and affirmative defenses, default and entry of default judgment, or other action, including the assessment of special costs and expenses, including actual attorney fees.”
Only listed exhibits will be considered admissible at trial, except for rebuttal exhibits which could not be reasonably anticipated before trial or except for good cause shown.
All exhibits must be stipulated by the parties or be subject to a motion in limine. Each party maintains its own exhibits and is responsible for numbering.
DEPOSITION TESTIMONY: The names of all witnesses who will testify by deposition must be identified. Failure to do so may bar their production at trial except for good cause shown.
De bene esse depositions must comply with MRE 611; video depositions must be transcribed.
Court's wording
Lay and expert de bene esse depositions are subject to the MRE 611. Failure to comply will result in exclusion of the deposition transcript, requiring the witness to testify in person. All video de bene esse depositions must be transcribed.
Movant must have an evaluation available prior to the hearing date and an Order to Show Cause must be filed.
Filing & Service rules
Electronic Filing Rules
Paper copies of motions and responses are not required to be filed.
No paper copies of motions or responses are required.
Civil cases
Page 1 | Header
The joint Final Pre-Trial Order must be e-filed by 3:30 pm on the Friday before trial.
The joint Final Pre-Trial Order must be e-filed no later than 3:30 pm on the Friday prior to trial.
Civil cases
Page 1 | VII. FINAL PRETRIAL CONFERENCE AND JOINT PRETRIAL ORDER
Summary disposition motions must be submitted through e-filing.
Moving party to submit motion through efiling
Civil cases
Page 1 | IV. SUMMARY DISPOSITION MOTIONS
Parties are not required to file hard copies of motions or responses.
Copies: Parties are not required to file hard copies of the motions or responses with the court.
Civil cases
Page 1 | III. MOTION PRACTICE
Filing Timing and Cure Windows
Responses are due 3 days prior to the hearing date; late responses may be stricken.
Response due dates: As set forth in MCR 2.119(C)(2), 3 days prior to hearing date. Late responses may be stricken.
Civil cases
Page 1 | III. MOTION PRACTICE
Trial depositions must be completed and purged by the Friday before trial, or the witness must testify in person.
Trial depositions must be complete by the Friday preceding trial and purged. Otherwise, the witness will be required to testify in person.
Civil cases
Page 1 | VII. FINAL PRETRIAL CONFERENCE AND JOINT PRETRIAL ORDER
The joint Final Pre-Trial Order must be filed by 3:30 pm on the Friday before trial.
The joint Final Pre-Trial Order must be e-filed no later than 3:30 pm on the Friday prior to trial.
Civil cases
Page 1 | VII. FINAL PRETRIAL CONFERENCE AND JOINT PRETRIAL ORDER
Summary disposition motions must be filed within 30 days after case evaluation accept/reject or end of discovery; late motions require leave.
Filing deadline: According to the Status Conference Scheduling Order, the motion must be filed no later than 30 days after the case evaluation accept/reject date. If there is no case evaluation, then the motion must be filed no later than 30 days after the end of discovery. Late motions will be rejected and motion for leave must be filed.
Civil cases
Page 1 | IV. SUMMARY DISPOSITION MOTIONS
Courtesy Copy Requirements
A copy of the motion should be emailed to sravani.kurra@3rdcc.org, and JudgeHubbard-Court@3rdcc.org.
A copy of the motion should be emailed to sravani.kurra@3rdcc.org, and JudgeHubbard-Court@3rdcc.org.
Civil cases
Page 1 | III. MOTION PRACTICE
Appeal briefs and supporting material must be emailed to the judicial attorney or mailed to the court.
All briefs and supporting material must be emailed to the listed JA; Sravani.kurra@3rdcc.org or mailed to the court.
Civil cases
Page 1 | V. APPEALS
Adjournment & Extension Requirements
Adjournment of summary disposition motions requires court approval.
Adjournment: Only with court approval.
Civil cases
Page 1 | IV. SUMMARY DISPOSITION MOTIONS
The moving party may adjourn a motion once with court permission, and an adjournment praecipe must be filed.
The moving party may adjourn the motion once with the court's permission. An adjournment praecipe must be filed.
Civil cases
Page 1 | III. MOTION PRACTICE
Appeal adjournments require court approval and stipulation of all parties, limited to 2 weeks; oral argument must occur within 6 months of filing.
Adjournment: With approval from the court and stipulation of all parties. The adjournment shall be for no more than 2 weeks. No oral argument will be allowed later than 6 months after the filing date.
Civil cases
Page 1 | V. APPEALS
Subsequent adjournments of case evaluation must be made by motion.
Subsequent adjournments must be made by motion.
Civil cases
Page 1 | I. STATUS CONFERENCE
Adjournments of settlement conferences must be made by motion.
Adjournments must be made by motion.
Civil cases
Page 1 | II. SETTLEMENT CONFERENCE
Chambers Communication Rules
For emergency motions, you must contact the court clerk to schedule a hearing date.
Emergency motion: You must contact the court clerk to schedule a hearing date.
Civil cases
Page 1 | III. MOTION PRACTICE
If a summary disposition case settles or issues are resolved, the moving party must inform the court immediately.
As a courtesy to the court, if the case settles or issues are resolved, the moving party must inform the court immediately.
Civil cases
Page 1 | IV. SUMMARY DISPOSITION MOTIONS