Model Pleadings


The pleadings on this page were filed in Court as indicated and serve here as models for form only.   


State Trial Court Pleadings (filed during appeal process)

Motion to Compel Production of Trial Counsel's File (and Order granting motion)

Motion for New Trial with Brief in Support

Motion to Withdraw Guilty Plea with Brief in Support

Motion to Correct Invalid Sentence with Brief in Support

Motion to Reduce Jail Sentence (1/4 reduction)


Michigan Court of Appeals

Interlocutory Appeal  Note: Practitioners might also want to review this Checklist for Interlocutory Appeals, as well as MCL §600.308 (from the Michigan Legislature's website) and MCR 6.005(H), 7.203, 7.205 and 7.206(6) (from the Michigan Court's website).  You may also need to file a motion to stay in the trial court and/or a motion to stay in the Court of Appeals, together with a motion for immediate consideration of your application for leave to appeal.  

Defendant-Appellant's Motion to Exceed (50) Page Limit to be filed at least 21 days before brief is due

Defendant-Appellant's Brief on Appeal

Defendant-Appellant's Motion for Permission to Order Late Transcript

Defendant-Appellant's Reply Brief

Defendant-Appellant's Motion to Remand with Brief in Support

Defendant-Appellant's Motion to Expedite Appeal

Defendant-Appellee's Brief on Appeal

Defendant-Appellant's Motion for Peremptory Reversal

Defendant-Appellant's Application for Leave to Appeal in case with no appeal of right (guilty plea)

Defendant-Appellant's Application for Leave to Appeal where parole was reversed by Circuit Court

Response to Prosecutor's Delayed Application for Leave to Appeal


Michigan Supreme Court

Application for Leave to Appeal

Response in Opposition to Prosecutor's Application for Leave to Appeal

Appellant's Brief on Appeal

Appellee's Brief on Appeal


Federal Court Pleadings

Petition for Writ of Habeas Corpus and Memorandum of Law in Support (United States District Court)

Appellant's Brief on Appeal (United States Court of Appeals for the Sixth Circuit)

Appellee's Brief on Appeal (United States Court of Appeals for the Sixth Circuit)

Petition for Certiorari (United States Supreme Court)

Brief in Opposition to Petition for Certiorari (United States Supreme Court)

Respondent's Brief on Appeal (Merits case, United States Supreme Court)