The filing prerequisite is nonjurisdictional but mandatory when timely invoked; no pandemic or futility exception applied, and a premature motion is dismissed without prejudice.
Material limitation
Binding only in the Sixth Circuit and only for the bounded procedural postures in the linked claims. Official published opinion reviewed. Waiver and forfeiture remain possible; pandemic-specific discussion is not adopted as a merits rule. A comprehensive commercial citator was not run.