Full record / Answer to Petition (Ferndale Avenue Shoppes) (10.06.2026).pdf

Answer to Petition (Ferndale Avenue Shoppes) (10.06.2026).pdf

Ferndale Avenue Shoppes Petitioner Vs. City Of Ferndale Respondent · 26-001387-TT

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS SYSTEM AND RULES 

MICHIGAN TAX TRIBUNAL 

Ferndale Avenue Shoppes, 

 

 

 

Petitioner, 

 

v 

 

CITY OF FERNDALE, 

 

Respondent.

 

 

 

MTT Docket No. 26-001387 

Parcel No. 24-25-27-352-027 

_____________________________________________________________________________/ 

 

Laura M. Hallahan (P42101) 

Representative for Petitioner 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

lhallahan@hallahanlaw.com 

 

 

P. DANIEL CHRIST (P45080) 

HAFELI STARAN & CHRIST, P.C. 

Attorney for Respondent 

2055 Orchard Lake Road 

Sylvan Lake, MI 48320-1746 

(248) 731-3085 

(248) 227-5421 (cell) 

dchrist@hsc-law.com 

_____________________________________________________________________________/ 

 

ANSWER TO PETITION 

 

Respondent City of Ferndale, through its City Attorney, P. Daniel Christ, responds to the 

allegations made in the Petition, as follows: 

1. 

Admitted. 

2. No response required because no allegations are set forth. 

3. Admitted. 

4. Admitted. 

5. Admitted. 

6. Admitted.

Page 2

2

7. Respondent acknowledges Petitioner contends this appeal involves issues related to the 

subject property’s true cash and taxable values but Respondents true case and taxable values for 

the subject property are valid. 

8. Admitted. 

9. Respondent acknowledges Respondent’s Board of Review established values and 

Petitioner’s value contentions and the values in dispute set forth in Petitioner’s attachment. 

10. 

Respondent denies the allegations contained in Paragraph 10, as Respondent’s 

assessed, state equalized and taxable values and the corresponding taxes are valid. 

(a) 

Respondent denies the allegations contained in subparagraph (a), as 

Respondent submits the assessed, state equalized and taxable values do not exceed permitted 

amounts. 

(b) 

Respondent denies the allegations contained in subparagraph (b), as 

Respondent’s assessed, state equalized and taxable values do not exceed the percentage of true 

cash value permitted by law. 

(c) 

Respondent denies the allegations contained in subparagraph (c), as 

Respondent’s assessed, state equalized and taxable values were correctly determined and are based 

upon proper application of proper principles. 

(d) 

Respondent denies the allegations contained in subparagraph (d), as 

Respondent’s assessed, taxable and state equalized values are non-discriminatory and conform to 

uniformity, equal protection and due process requirements. 

(e) 

Taxable values of parcels 24-25-27-352-025 and 24-25-27-352-007 were 

not unlawfully uncapped.

Page 3

3

WHEREFORE, Respondent City of Ferndale requests the Tribunal to dismiss the Petition, 

affirm Respondent’s assessed and taxable values, subject to county and state equalization, and 

award Respondent its costs and attorney fees. 

/s/P. Daniel Christ 

P. DANIEL CHRIST (P45080) 

HAFELI STARAN & CHRIST, P.C. 

Attorneys for Respondent 

2055 Orchard Lake Road 

Sylvan Lake, MI 48320 

(248) 731-3085 

 

Dated: October 6, 2026 

 

 

PROOF OF SERVICE 

 

On the date below, I sent by email a copy of the foregoing Answer to Petition to: 

 

Laura M. Hallahan (P42101) 

Representative for Petitioner 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

lhallahan@hallahanlaw.com 

 

 

 

 

I declare that the statement above is true to the best of my information, knowledge, and belief. 

 

 

/s/P. Daniel Christ 

P. Daniel Christ 

 

Dated: October 6, 2026

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