24-003388.pdf

Fs Associates LLC, Petitioner V City Of Detroit, Respondent · 24-003388-TT

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in 

Petitioner’s Appearance of Counsel 

FEB 04 2025 

FS Associates LLC v City of Detroit 

ki 

MTT Docket No. 24-003388 

MICHIGA 15, ; 

RIB 

STATE OF MICHIGAN VAL 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

FS Associates LLC, 

Petitioner, 

v 

MTT Docket No. 24-003388 

City of Detroit, 

Respondent. 

/ 

Joshua T. Shillair, Esq., (P72674) 

City of Detroit 

Of Colliers International 

Assessor’s Office 

Representative for Petitioner 

Representative for Respondent 

400 W 4 St, Suite 350 

2 Woodward Ave, Suite 804 

Royal Oak, MI 48067 

CAYMC 

0: 248-226-1632 

Detroit, MI 48226 

C: 517-202-5500 

0:313-224-3011 

F: 248-226-1633 

Joshua.shillair@colliers.com 

/ 

APPEARANCE OF PETITIONER’S COUNSEL 

Now comes Colliers International, by Joshua T. Shillair, Esq., on behalf of Petitioner, FS Associates 

LLC, and making an appearance as Petitioner's counsel. Please send all mail and make all 

correspondence for this appeal with Mr. Shillair as follows: 

Colliers International 

Attn: Joshua T. Shillair, Esq. 

400 W 4t St, Suite 350 

Southfield, MI 48067 

Office: 248-226-1632 

Cell: 517-202-5500 

Fax: 248-226-1633 

Joshua.shillair@colliers.com 

Petitioner’s Co 

Petitioner’s Consent to Counsel’s Appearance 

Signed: 

Dated: 1/29/2025 

Signed: Lhd 

: 

d: 1/29/2025 

Joshua T. Shillair, Esq. for Colliers Intemational 

David L. Steuer 

/

Petitioner’s Motion for Reconsideration & Proof of Service 

FS Associates LLC v City of Detroit 

MTT Docket No. 24-003388 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

ES Associates LL.C, 

Petitioner, 

v 

MTT Docket No. 24-003388 

City of Detroit, 

Respondent. 

Joshua T. Shillair, Esq., (P72674) 

Of Colliers International 

Representative for Petitioner 

400 W 4% St, Suite 350 

Royal Oak, MI 48067 

0: 248-226-1632 

C: 517-202-5500 

F: 248-226-1633 

Joshua.shillair@colliers.com 

City of Detroit 

Assessor’s Office 

Representative for Respondent 

2 Woodward Ave, Suite 804 

CAYMC 

Detroit, MI 48226 

0: 313-224-3011 

assessorscbdcommercial@detroitmi.gov 

dismuked@detroitmi.gov 

PETITIONER’S MOTION FOR RECONSIDERATION 

NOW COMES Petitioner, FS Associates LLC, by and through its Representative Colliers 

International by Joshua T. Shillair, Esq., and states the following in support of its Motion for 

Reconsideration: 

1. 

On January 8, 2025 this Honorable Tribunal issued an Order of Dismissal in this 

immediate appeal, dismissing this immediate appeal for Petitioner’s failure to comply 

with a November 7, 2024 Order of Default and December 5, 2024 Order Extending

Petitioner’s Motion for Reconsideration & Proof of Service 

FS Associates LLC v City of Detroit 

MTT Docket No. 24-003388 

2. 

Neither Petitioner, by and through David L. Steuer, nor Petitioners attorney Lawrence S. 

Jackier received the December 5, 2024 Order Extending Default. See Exhibit A — 

Lawrence S. Jackier Affidavit and Exhibit B — David L. Steuer Affidavit. 

3. 

Petitioner has experienced a history of issues with the Tribunal not delivering orders or 

notices to the correct email and attempted to correct this in the past. See Exhibit C — 

Email Exchange with MTT. 

4. 

Petitioner was not made aware of the December 5, 2024 Order Extending Default and its 

requirements and deadline until receipt of the January 8, 2025 Order of Dismissal. 

Therefore, Petitioner did not have actual or proper notice. 

WHEREFORE, Petitioner requests that this Honorable Tribunal reinstate this immediate appeal 

and provide Petitioner with the opportunity to cure default by transferring the appeal to the 

Entire Tribunal and paying the appropriate fee. 

Respectfully Submitted, 

COLLIERS INTERNATIONAL 

Representative for Petitioner 

| 

Dated: 1/29/2025 

TE Spite Esq. (P72674) 

Vice President 

| Tax Appeal 

| 

| 

400 E 4™ Street, Suite 350

Exhibit A 

Lawrence S. Jackier Affidavit

AFFIDAVIT OF LAWRENCE 8S. JACKIER 

I, Lawrence S. Jackier, being duly sworn, hereby testify and affirm that: 

1. 

The December 

5, 2024 Order extending default for dockets 24-003386 and 24- 

003388 was not received at my email jackier@jackiergould.com 

. 

2. 

The January 8, 2025 Order of Dismissal in both dockets 24-003386 and 24-003388 

was not received at my email jackier@jackiergouid.com 

. 

Dated: January 29, 2025 

A. 

DAWRENCE SAROKIER 

State of Michigan 

) 

County of Culedoundd 3 

On January 4 

, 2025, before me, a Notary Public in and for the County and State 

above written, personally appeared Lawrence S. Jackier, attorney at Jackier Gould, PC. 

Notary Public 

/ 

LYUBOV MARDUKHAYEVA 

County of 

Notary 

of Ba 

niga 

State of 

le 

My Commission Expires: 

Acting in County of 

Acting in State of

Exhibit B 

David L. Steuer Affidavit

AFFIDAVIT OF DAVID L. STEUER 

1, David L. Steuer, being duly sworn, hereby testify and affirm that: 

The December 5, 2024 Order extending default for dockets 24-003386 and 24-003388 was 

not received by me at my email. 

The January 8, 2025 Order of Dismissal in both dockets 24-003386 and 24-003388 was the 

first time 

| became aware of the December 5, 2024 order extending default in both dockets 

Dated january 29, 2025 

no ' 

y2 le 

David L. Steuer 

State of Michigan 

County of _(faddead 

155: 

On Januaryad, 2025 before me, a Notary Public in and for the County and State written, 

personally appeared David L. Steuer. 

Garda Gaon bade 

Notary Public 

County of 

Lh Uap 

State of 

Pacehag bor 

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, 

uny Al i 

My Commission Expires: 

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Wayno County 

Acting 

in County M Ouidocs 

Ly 4y Gorn, Expires 

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Acting in State of Wi dog ir

Exhibit C 

Email Exchange with MTT

0") Outlook 

Fw: MTT Docket 24-003386 & 24-003388 

From David Steuer <David@steuergroup.com> 

Date Tue 1/14/2025 11:51 AM 

To 

 Shillair, Joshua <Joshua.Shillair@colliers.com> 

David Steuer 

248.790.4481 

www. MyFavPlace.com 

Steuer & Associates, Inc. 

30180 Orchard Lake Road Ste 150 

Farmington Hills, MI 48334 

Licensed Broker & Builder 

This message is for the addressee only and is confidential and protected from disclosure. If you are not the 

addressee, any disclosure, copy, distribution or use of the contents of this message is prohibited. Please notify us 

immediately and destroy the original message and all copies. 

From: David Steuer <David@steuergroup.com> 

Sent: Wednesday, October 30, 2024 1:24 PM 

To: LARA-taxtrib <LARA-taxtrib@michigan.gov> 

Cc: Lawrence Jackier <jackier@jackiergould.com>; Jack Folbe <jfolbe@yahoo.com>; Amy Folbe 

<AFolbe@honigman.com>; Jack Folbe (jfolbe@gmail.com) <jfolbe@gmail.com> 

Subject: Re: MTT Docket 24-003386 & 24-003388 

Thanks Erica 

Savannah called me this morning and informed me the violation is being cancelled because it was not 

sent to the address shown on the appeal.

Thank you for your email. Per your conversation that you had with Savannah earlier when she 

called you back, she stated that she would have to send it to be reviewed. You will be receiving 

correspondence once it is reviewed. 

Best, 

Erica M. 

Michigan Tax Tribunal 

MTT Main Line: (517) 335-9760 

Website: www.michigan.gov/taxtrib 

Michigan.gov/ VOTE 

Get personalized voter-information on early voting and other topics at Michigan.gov/Vote. 

From: David Steuer <David @steuergroup.com> 

Sent: Wednesday, October 30, 2024 12:01 PM 

To: LARA-taxtrib <LARA-taxtrib@michigan.gov> 

Subject: Fw: MTT Docket 24-003386 & 24-003388 

CAUTION: This is an External email. Please send suspicious emails to abuse@michigan.gov 

From: David Steuer 

Sent: Tuesday, October 29, 2024 12:41 PM 

To: thetaxtrib@michigan.gov <thetaxtrib@michigan.gov> 

Subject: MTT Docket 24-003386 & 24-003388 

To whom it may concern, 

I just finished a call with Savannah at your office because 

| never received a default notice and 

only received the extension document from a third party today. 

Savannah informed me that the documents were sent to disteuer@yahoo.com which is an 

email address other than what she read 

| put on the initial appeal. 

| have not received emails 

from that address in years.

Even so, 

| told Savannah that we are willing to pay the additional $100 today to resolve this 

matter. 

Please contact me upon your review. 

Thank you for your time and consideration. 

David Steuer 

248.790.4481 

www. MyFavPlace.com 

Steuer & Associates, Inc. 

30180 Orchard Lake Road Ste 150 

Farmington Hills, MI 48334 

Licensed Broker & Builder 

This message is for the addressee only and is confidential and protected from disclosure. If you are not the 

addressee, any disclosure, copy, distribution or use of the contents of this message is prohibited. Please notify us 

immediately and destroy the original message and all copies.

Petitioner’s Motion for Reconsideration & Proof of Service 

ES Associates LLC v City of Detroit 

MTT Docket No. 24-003388 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

FS Associates LLC, 

Petitioner, 

v 

City of Detroit, 

Respondent. 

MICHIGAN TAX TRIBUNAL 

MTT Docket No. 24-003388 

Joshua T. Shillair, Esq., (P72674) 

Of Colliers International 

Representative for Petitioner 

400 W 4" St, Suite 350 

Royal Oak, MI 48067 

0: 248-226-1632 

C: 517-202-5500 

F: 248-226-1633 

Joshua.shillair@colliers.com 

City of Detroit 

Assessor’s Office 

Representative for Respondent 

2 Woodward Ave, Suite 804 

CAYMC 

Detroit, MI 48226 

0: 313-224-3011 

assessorscbdcommercial@detroitmi.gov 

dismuked@detroitmi.gov 

PROOF OF SERVICE 

STATE OF MICHIGAN 

) 

) ss 

COUNTY OF OAKLAND 

) 

Joshua T. Shillair, Esq. states that on 1/29/2025, he submit a copy of Appearance of Petitioner’s 

Counsel, Petitioner Motion for Reconsideration, Filing Fee Check of $25, and this Proof of Service 

for the above captioned appeal to Respondent electronically as addressed above and to the Michigan Tax 

Tribunal via first class mail to Michigan Tax Tribunal, 

70 Box 30232, Lansing, MI 48909. 

Signed: 

Joshua 7/Shillar Esq.

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