Model Pleadings
The pleadings on this page were filed in Court as indicated and serve as models for form only.
State Trial Court Pleadings
- 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)
Interlocutory Appeals
Interlocutory appeals may be filed in the circuit court or in the Court of Appeals. SADO's Defender Interlocutory Appeals Book (2023) provides thorough information about how to navigate the appellate process, and provides samples and advice to attorneys who are new to these appeals.
Practitioners 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 the application for leave to appeal.
Michigan Court of Appeals
- 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)
