Corrected ex Motion to Compel Discovery .pdf
Ghafari Properties LLC Petitioner Vs. City Of Birmingham Respondent · 26-001459-TT
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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
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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
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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