NotebookLM can be an efficient and collaborative tool as the legal filer checks for proper document and citation formatting—a painstaking task often overlooked. Missing elements can result in a rejected filing or poorly reflect on the writer’s professional competency.
For trial court filings, one can create a “Notebook” and upload MCR 1.109, the Michigan Appellate Opinion Manual, and the draft filing. (Importantly for privacy, “NotebookLM does not use your personal data, including your source uploads, queries, and the responses from the model for training.”)
If the matter will be filed in the appellate courts, also upload MCR 7.212 and perhaps MCR 7.312.
The prompt can be as simple as: “For the [filing name], list all instances where it does not comply with the filing standards of MCR 1.109 or the Michigan Appellate Opinion Manual.”
As an example, below is a portion NotebookLM’s response flags when it reviewed an Answer to Complaint.
• Citation Formatting:
◦ Reporter Abbreviations (1:8): Many citations include periods where they should be omitted (e.g., “N.W.2d” instead of “NW2d”4…, “U.S.” instead of “US”9, “S.Ct.” instead of “S Ct”9, “L.Ed.2d” instead of “L Ed 2d”9, “F. Supp. 3d” instead of “F Supp 3d”17). The manual explicitly states, “Do not use periods in abbreviations of reporter names”125.
◦ Case Name Italicization (1:7.2, 1:2.2): While case names are italicized on first full citation, subsequent short-form citations (e.g., “Sullivan”5, “Fisher case”6) are often presented without italicization, which is inconsistent with the manual’s examples (e.g., “Hays, 300 Mich App at 59″126).
◦ Missing Citation Details: Several citations are incomplete, lacking full citation information, such as In re Huff104.
◦ Incorrect Abbreviation Formatting: “E.D. Mich.” for the district court citation in Somberg v. Cooper17 contains periods that are not present in the manual’s example for district court abbreviations (e.g., “ED Pa”127).
◦ Parallel Citation Order (1:9.2): For U.S. Supreme Court cases, the order of parallel citations is “US; S Ct; L Ed”128. While United States v Alvarez10 follows the order, the consistent use of periods in “S Ct” and “L Ed 2d” is non-compliant with the manual’s general rule on reporter abbreviations125.
◦ Unreported Cases (1:18): The citation of *People v. Williams, No. 346689, 2020 WL 2601567, at 3 (Mich. Ct. App. May 21, 2020) (per curiam)7 uses a Westlaw citation. While common, the manual provides a specific preferred format for unpublished Michigan Court of Appeals opinions that does not include “WL” or “at *” for pinpoint citations (e.g., “unpublished per curiam opinion of the Court of Appeals, issued [month, day, year] (Docket No. ___), p ___”129).
◦ Michigan Statutes (1:21.1): The use of “MCL § 750.539 et seq.”5691 and “M.C.L. 257.742″112 includes the section symbol “§” and periods within “M.C.L.”, respectively. The manual’s standard for citing Michigan Compiled Laws (MCL) explicitly does not include a section symbol (e.g., “MCL 776.20”)130 or periods within the abbreviation130.
◦ Dictionary Citations (1:32): The citation to “Webster’s Dictionary”71 is generic and lacks the required edition or year for proper identification (e.g., “Merriam-Webster’s Collegiate Dictionary (11th ed)”)131. The reference to “Dictionary.com”71 also lacks the required URL and accessed date for an internet source132.
• Quotation Formatting:
◦ Ellipsis Spacing (2:10.1): The ellipsis “…” in “evidence that has been illegally obtained … is inadmissible”40 lacks spaces between the periods, which the manual states “is always wrong”134. This error is repeated46.
◦ Punctuation Before Quotations (2:8.5): In some instances, the punctuation preceding a quotation does not follow the manual’s rules (e.g., “Fisher case said: The appellate court construed…”6 uses a colon before a single sentence quotation, where a comma or no punctuation would typically be used for an interwoven or introductory clause135136).
◦ Unnecessary Brackets for Interwoven Quotes (2:8.5): In “stated that ‘[t]he First Amendment requires…'”9, the brackets around “[t]he” are unnecessary because the preceding “that” allows the quote to be smoothly interwoven without a capital letter change136.
◦ Quotation Marks for Internal Dialogue: The phrase “playing games” is quoted60, but it is unclear if this is a direct quote from another source or simply a term used in a specific sense by the author. If the latter, it’s an acceptable use per 3:5137.
• Grammar and Spelling:
◦ “As Such” Misuse (Appendix 1): The phrase “as such” is repeatedly used to mean “therefore” or “accordingly” (e.g., “as such leaves Disciplinary Counsel to their proofs”4), which is explicitly noted as a misuse in the manual (Appendix 1)138.
◦ “Insure” vs. “Ensure” (Appendix 1): The document uses “wants to insure that the litigants are fully and completely informed”23, where “ensure” (to make certain) would be the correct word rather than “insure” (to protect against loss by insurance policy)139.
◦ “Prior to” Misuse (Appendix 1): The phrase “just a few months prior to this Jan 16, 2024 date”56 should ideally use “before” instead of “prior to”140.
◦ “Where” Misuse (Appendix 1): The phrase “election cases where misdemeanors have been committed”29 uses “where” instead of “in which” or “when,” which is discouraged when referring to circumstances141.
◦ “And/or” Misuse (3:8): The phrase “reach out and/or partner”21 uses a slash, which is explicitly prohibited outside of direct quotations142.
◦ Hyphenation (3:3, Appendix 2): Several compound modifiers are not hyphenated when they should be (e.g., “in person conversation”9 should be “in-person conversation”; “long time Taylor resident”18 should be “longtime Taylor resident”143; “well versed”23 should be “well-versed”144; “decision making”23 should be “decision-making”145; “on camera”48 should likely be “on-camera”).
◦ Apostrophes (3:4): Inconsistencies or errors in possessive forms (e.g., “Board of Canvassers”13 should be “Board of Canvassers'”).
◦ Spelling Errors (3:6): Examples include “motived” for “motivated”19, “agena” for “agenda”20, “Thet” for “The”26, and “hearing aides” for “hearing aids”53.
◦ Statute Naming (3:15): “Michigan Eavesdropping Statute”5 capitalizes “Eavesdropping Statute.” As “eavesdropping statute” is not listed as an official short title in Appendix 7131…, it should be lowercase (“Michigan eavesdropping statute”)172173. “Motor Vehicle Code” and “CJIS Policy Council Act” are correctly capitalized as they are official short titles [753, 756, Appendix 7].
◦ Section Symbol (3:33): The repeated use of “MCL §” includes the section symbol, which is not used for Michigan Compiled Laws citations according to the manual’s examples and rules130175.
NotebookLM can also be helpful in pre-reviewing separate exhibits or appendices to flag for personal identifying information that needs to be redacted or non-conforming transcripts that need to be corrected before filing with the court.