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Corrected ex Motion to Compel Discovery .pdf

Ghafari Properties LLC Petitioner Vs. City Of Birmingham Respondent · 26-001459-TT

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

Ghafari Properties LLC, 

Petitioner, 

vs. 

City of Birmingham, 

MTT Docket No. 26-001459 

Parcel No. 08-19-25-178-001 

Respondent. 

_____________________________________________________________________________/ 

MOTION TO COMPEL PETITIONER’S DISCOVERY RESPONSES, 

SCHEDULE A HEARING OR IN THE ALTERNATIVE ISSUE 

AN ORDER TO COMPEL, AND FOR FEES AND SANCTIONS 

FOR IMMEDIATE CONSIDERATION 

Corrected Exhibit B

Page 2

Respectfully submitted, 

BEIER HOWLETT, P.C. 

/s/ Michael C. Gibbons 

 

Michael C. Gibbons (P51304) 

Attorneys for Respondent 

3001 W. Big Beaver Rd., Ste. 600 

Troy, MI 48084 

Date: October 23, 2026 

 

 

248-282-1069/ mgibbons@bhlaw.us.com

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EXHIBIT B

Page 4

October 19, 2026 

 

 

 

 

 

 

VIA EMAIL 

 

Joshua T. Shillair, Esq 

Colliers International 

400 W 4th St., Suite 350 

Royal Oak, MI 48067 

tax.efile@colliers.com 

 

 

Re: 

Ghafari Properties, LLC v City of Birmingham 

 

 

MTT Docket No. 26-001459 

 

Dear Mr. Shillair: 

 

We served our Request for Production on September 18, 2026. We still have not received any 

responses which were due on October 16, 2026. Enclosed is the Motion to Compel Discovery 

Responses and Brief in support that we intend to file with the Tax Tribunal. 

 

In accordance with TTR 231, please advise immediately whether Petitioner will be filing a 

response to the Motion to Compel. 

 

 

 

 

 

 

 

 

Sincerely, 

 

 

 

 

 

 

 

BEIER HOWLETT, P.C. 

 

 

 

 

 

 

 

 

 

 

 

 

 

Michael C. Gibbons 

 

 

 

 

 

 

Michael C. Gibbons 

 

MCG/em

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