Pretrial Investigation
The pretrial investigation process typically involves the review of background documentation, development of legal strategy, and drafting or responding to preliminary documentation such as demand letters and sample complaints.
| Pretrial Investigation & Demands | Fee Guideline |
| Review Background Documentation & Materials | $ 300 - $1,500 |
| Draft & Send or Review & Respond to Demand Letter | $250 - $1,500 |
| Draft Sample Complaint | $1,500 - $3,000 |
| Draft & Send Demand Letter with Sample Complaint | $1,500 - $3,000 |
| Conduct Legal Research | $250 - $2,500 |
| Conduct Legal Research & Draft Legal Memorandum | $250 - $2,500 |
Initial Pleadings
Initial pleadings include the summons(es), complaints, notice of appearances, complaint or answer to the complaint or counter/cross-claims, affirmative defenses, preliminary witness lists, preliminary exhibit lists, scheduling conferences, etc.
| Initial Pleadings | Fee Guidelines |
| Preparation & Issuance of Summons (per Defendant) | $ 125 |
| Draft & File Complaint | $1,500 - $3,000 |
| Draft & File Notice of Appearance | $ 250 |
| Draft & File Answer to Complaint or Counter/Cross-Claims | $1,500 - $3,000 |
| Draft & File Affirmative & Other Defenses | $ 500 |
| Review Answer to Complaint | $ 300 - $1,500 |
| Draft & File Answer to Counterclaims and/or Crossclaims | $1,500 - $3,000 |
| Draft & File Preliminary Witness List | $ 300 - $1,500 |
| Draft & File Preliminary Exhibit List | $ 300 - $1,500 |
| Draft or Review & Revise Proposed Scheduling Order | $ 300 - $ 500 |
| Calendar Scheduling Order Dates Internally | $ 500 |
| Attend Pre-Trial Scheduling Conference (via Zoom) | $ 300 - $ 500 |
Discovery
The discovery process involves the use of initial disclosures, interrogatories (ROGs), requests for production of documents (RPDs), requests for admissions (RFAs), depositions, and subpoenas to learn the facts about a particular case.
| Discovery | Fee Guidelines |
| Draft & Serve Initial Disclosures | $300 |
| Review Opposing Party’s Initial Disclosures | $300 |
| Prepare Discovery Requests or Responses (ROGs, RPDs & RFAs) | $1,500 - $4,500 |
| - Interrogatories (ROGs) | $300 - $1,500 |
| - Requests for Production of Documents (RPDs) | $300 - $1,500 |
| - Requests for Admissions (RFAs) | $300 - $1,500 |
| Review Discovery Responses to Our Discovery Requests | $300 - $1,500 |
| Prepare & File Notice of Deposition (per deponent) | $250 |
| Prepare for Deposition | $300 - $1,500 |
| Take or Defend Witness Deposition | $300 - $3,500 |
| Preparation and Filing of Subpoena (per 3rd party) | $300 - $1,000 |
Motion Practice
Motion practice involves the filing or defense of various motions wherein a party is asking the court to order a party to do or not to something.
| Motion Practice | Fee Guidelines |
| Draft & File Motion, Brief or Response | $1,500 - $10,000 |
| - Change of Venue | $1,500 - $5,000 |
| - Compel Discovery | $1,500 - $3,000 |
| - Correct or Strike Pleadings | $1,500 - $5,000 |
| - Directed Verdict | $1,500 - $5,000 |
| - Disqualification | $1,500 - $3,000 |
| - In Limine | $1,500 - $5,000 |
| - Judgment Notwithstanding Verdict (JNOV) | $3,000 - $10,000 |
| - More Definite Statement | $1,500 - $5,000 |
| - Protective Order | $1,500 - $5,000 |
| - Reconsideration | $3,000 - $10,000 |
| - Relief from Judgment | $3,000 - $10,000 |
| - Summary Disposition (MSD) | $3,000 - $10,000 |
| - Quash | $1,500 - $5,000 |
| Preparation for & Attendance at Hearing on Motion | $300 - $3,000 |
| Draft Affidavit in Support of Motion (per affiant) | $300 - $1,500 |
Trial Preparation & Trial
| Trial Preparation & Trial | Fee Guidelines |
| Draft & File Final Trial Exhibit & Witness Lists | $1,000 - $5,000 |
| Draft & File Jury Instructions (Jury cases only) | $1,500 - $5,000 |
| Draft & File Trial Brief | $1,500 - $5,000 |
| Compile Trial Exhibit Binder | $1,500 - $5,000 |
| Prepare Trial Opening Statement and/or Closing Argument | $1,500 - $5,000 |
| Prepare Trial Witness Examinations (per witness) | $1,500 - $5,000 |
| Trial Attendance (per day) | $300 - $5,000 |
Appeals
| Appeals | Fee Guidelines |
| Draft & File Notice of Claim of Appeal | $1,500 - $3,000 |
| Draft & File Brief or Response Brief on Appeal | $6,000 - $15,000 |
| Prepare for & Attend Oral Argument | $3,000 - $6,000 |
Court Costs
These costs are mandatory as required for the State of Michigan and are not determined by the Firm.
| Court Costs | Fees |
| Appeals from District Court to Circuit Court | $25 |
| Appeals from Circuit Court to Court of Appeals | $375 |
| Circuit Court – Civil Filing Fees (Summons & Complaint) | $150 |
| District Court – Civil Filing Fees (Summons & Complaint) | $25-$150 |
| Electronic Filing System Fee for Civil Actions | $25 |
| Jury Demand Fee | $85 |
| Appeal Motion Fees | $100 per |
| Circuit & District Court Motion Fees | $20 per |
| Deposition, Hearing & Trial Transcripts | $3-7 pp |
| Courier | Varies |
| Postage | Varies |
*Flat Fee Guidelines Disclaimer
Any flat fees, fee ranges, or pricing schedules provided for litigation or alternative dispute resolution services are intended as general guidelines only and are not guarantees of the total cost of representation. Actual fees may be higher or lower than the stated guidelines depending on the specific circumstances of the matter, including but not limited to the simplicity or complexity of the issues involved, the amount in controversy, procedural posture, opposing party conduct, court or arbitrator requirements, and the urgency or time sensitivity of the services requested. Fees will ultimately be determined based on the scope of work agreed upon and the professional judgment required to represent the Client’s interests effectively.
