Joint Motion to Transfer_AMS Hubbard_FINAL.pdf

Ams Hubbard LLC, Petitioner V City Of Dearborn, Respondent · 24-003480-TT

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

AMS HUBBARD LLC, 

 

 

 

Petitioner, 

 

v 

 

CITY OF DEARBORN, 

 

 

 

Respondent. 

 

 

 

Docket No. 24-003480 

 

 

_____________________________________________________________________________/ 

 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

HALLAHAN & ASSOCIATES, P.C. 

Attorneys for Petitioner 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

JEREMY J. ROMER (P77287) 

CITY OF DEARBORN 

Attorney for Respondent 

16901 Michigan Avenue, Suite 14 

Dearborn, MI 48126 

(313) 943-2035 

_____________________________________________________________________________/ 

 

JOINT MOTION TO TRANSFER APPEAL TO ENTIRE TRIBUNAL DIVISION 

 

 

Petitioner and Respondent, by and through their respective attorneys, state the following 

in support of the above captioned Motion: 

1. 

The above captioned appeal involves one parcel of commercial property. The 

taxable value for this parcel for the 2024 tax year as established by Respondent’s Board of Review 

exceeded $1.2 million. 

2. 

The appeal is currently pending in the small claims division where it was originally 

filed. 

3. 

The parties have discussed the appeal since its filing, and the retention of new 

counsel for Petitioner, and believe it would be more appropriate to have the case proceed in the 

entire tribunal division for several reasons.

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4. 

To begin, placing the case in the entire tribunal division would allow for more 

efficient discovery between the parties. The conduction of which may assist the parties in reaching 

an amicable resolution to the above captioned appeal. 

5. 

Second, the preparation of valuation disclosures and the conduction of an entire 

tribunal hearing, if necessary, should provide the parties with sufficient opportunity to present 

expert witness testimony regarding the value of each parcel at issue and, consequently, provide the 

Tribunal with the evidence it needs to make an independent determination of value. An opportunity 

that would be impaired if the parties were constrained to a 30-minute hearing. 

6. 

Finally, the above captioned appeal should be moved to the entire tribunal division 

as it appears that the parties’ final contentions of taxable value in dispute will likely exceed 

$100,000—depriving the small claims division of jurisdiction over this matter pursuant to TTR 

263 and MCL 205.762. 

7. 

The total taxable value in dispute as identified in Petitioner’s Petition is indicated 

to be $100,000—the maximum taxable value disparity the small claims division possesses 

jurisdiction to hear. Petitioner’s recently retained legal counsel further believes Petitioner’s 

contentions of value as set forth in its Petition may be overstated—resulting in further disparity in 

the parties’ taxable value contentions. Accordingly, the above captioned appeal should be moved 

to the Entire Tribunal at this stage of the proceedings to ensure that the parties, as well as the 

Tribunal, do not incur time and expense adjudicating this matter only for the small claims division 

to be left without jurisdiction to issue a final decision and requiring the above captioned appeal be 

moved to the entire tribunal division at the eleventh hour. 

8. 

TTR 273(1) allows for the requested relief and no hearing notice has been issued 

in the case. As Respondent has not filed an Answer, no costs have been incurred to Respondent in

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that respect furthering demonstrating the efficiency and practicality of a transfer at this stage of 

the proceedings. 

9.

In short, the parties believe that transferring the case to the entire tribunal division

is in the interest of the efficient administration of justice, will aid the parties and the Tribunal, and 

will aid in the efficient handling of the case. There is good cause to grant the requested relief. 

WHEREFORE, the parties jointly request that this Honorable Tribunal enter an Order: 

A. Granting the parties’ Joint Motion to Transfer and reassign the above

captioned matter to the Entire Tribunal Division;

B. Requiring Petitioner file an Entire Tribunal Petition, proof of service, as

well as pay the applicable difference in the required filing fee within 14

days of the Order; and

C. Affirming that no costs be awarded to Respondent as part of the transfer.

Respectfully Submitted, 

By:_/s/ Laura M. Hallahan________ 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

HALLAHAN & ASSOCIATES, P.C. 

Attorneys for Petitioner 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089

Dated: October 23, 2024 

 By: _/s/ Jeremy J. Romer (w/permission)_ 

JEREMY J. ROMER (P77287) 

CITY OF DEARBORN 

Attorney for Respondent 

16901 Michigan Avenue, Suite 14 

Dearborn, MI 48126 

(313) 943-2035

Dated: October 24, 2024

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