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R's PHS_D&M_FINAL.pdf

D & M Plumbing Specialists Inc, Petitioner Vs. Township Of Waterford, Respondent · 25-002183-TT

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Page 1

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

 

Petitioner: D & M Plumbing Specialists, Inc. 

v 

Respondent: Charter Township of Waterford 

 

 

MTT Docket No. 25-002183 

 

 

 

Petitioner’s Prehearing Statement 

 

RESPONDENT’S PREHEARING STATEMENT 

 

Petitioner’s representative: 

Jay A. Schwartz 

Property Tax Reduction Services, LLC 

37887 West 12 Mile Road, Suite B 

Farmington Hills, MI 48331 

(248) 672-1922 

 

Respondent’s representative: 

Laura M. Hallahan (P42101) 

 

Seth A. O’Loughlin (P80257) 

 

Kelsea M. Melcher (P85821) 

 

Hallahan & Associates, P.C. 

 

1750 S. Telegraph Road, Suite 202 

 

Bloomfield Hills, Michigan 48302 

 

(248) 731-3089 

 

I. 

VALUATION INFORMATION: 

A. The true cash value (TCV), assessed value (AV), and taxable value (TV) for each 

parcel and tax year at issue as established by the Board of Review: 

Parcel Number 

Year 

TCV 

AV 

TV 

W-13-20-126-002 

2025 

$1,175,900 

$587,950 

$509,130 

W-13-20-126-002 

2026 

$1,198,080 

$599,040 

$522,870 

 

B. Respondent’s contentions of TCV, state equalized value (SEV), and TV for each 

parcel and tax year at issue: 

Parcel Number 

Year 

TCV 

SEV 

TV 

W-13-24-451-015 

2025 

$1,200,000 

$600,000 

$509,130 

W-13-24-451-015 

2026 

$1,200,000 

$600,000 

$522,870

Page 2

MTT Docket No. 25-002183 

Respondent’s Prehearing Statement, Page 2 of 5 

 

 

C. Petitioner’s contentions of TCV, state equalized value (SEV), and TV for each 

parcel and tax year at issue (per Petitioner’s Petition and Motions to Amend, if 

applicable): 

Parcel Number 

Year 

TCV 

SEV 

TV 

W-13-20-126-002 

2025 

$800,000 

$400,000 

$400,000 

W-13-20-126-002 

2026 

$850,000 

$425,000 

$425,000 

 

D. Amounts in dispute for the tax year(s) at issue: 

Parcel Number 

Year 

TCV 

SEV 

TV 

W-13-20-126-002 

2025 

$400,000 

$200,000 

$109,130 

W-13-20-126-002 

2026 

$350,000 

$175,000 

$97,870 

 

I. 

TAX INFORMATION: 

A. Have taxes been paid for each property for each tax year at issue? 

☐ Yes 

☒ No 

III. 

FACTUAL STATEMENT OF CLAIMS: 

A. Describe any additions or losses for each property for each tax year at issue (by 

parcel number and tax year): 

Respondent is unaware of any additions or losses to the subject property. 

B. Classification of each property for each tax year at issue (by parcel number): 

W-13-20-126-002 

2025 & 2026 

Commercial 

 

C. Current use of each property for each tax year at issue, if different than above (by 

parcel number): 

Not applicable. 

D. Contention of highest and best use for each property for each tax year at issue, if 

different than property’s current use for each tax year at issue (by parcel number): 

Not applicable. 

E. Your factual statement of claims in support of your contentions, including additions 

and losses, if any (i.e., what facts are you relying on in support of your claim or 

defense?): 

Respondent contends that it lawfully and uniformly assessed the subject property.

Page 3

MTT Docket No. 25-002183 

Respondent’s Prehearing Statement, Page 3 of 5 

 

 

F. 

If non-uniformity of assessment is alleged, what evidence will you rely upon in 

support of your contents? 

Respondent contends that it lawfully and uniformly assessed the subject property. 

G. Affirmative Defenses (if any): 

 Respondent incorporates by reference the affirmative defenses contained in its 

Answer to the Petition and its Answer to Petitioner’s Motion to Amend (if 

applicable). 

IV. 

ISSUES TO BE LITIGATED: 

A. Factual Issues: 

- 

What is the true cash value of the subject property as of December 31, 2024 and 

December 31, 2025? 

B. Legal Issues: 

- 

What is the lawful assessed and taxable value of the subject property for the 2025 

and 2026 tax years? 

V. 

DO THE PLEADINGS NEED TO BE AMENDED TO CONFORM TO THE 

EVIDENCE? 

☐ Yes 

☒ No 

A. If yes, state all necessary amendments (a motion may be required to amend the 

pleadings): 

Not applicable. 

VI. 

ARE THERE CONSOLIDATION ISSUES? ☐ Yes 

☒ No 

A. If yes, state the cases, by docket number, that should be consolidated with this case 

(a motion may be required to consolidate the cases): 

Not applicable. 

VII. 

PENDING OR ANTICIPATED MOTIONS OR OUTSTANDING DISCOVERY 

ISSUES, IF ANY: 

A. Motions: 

- 

None at this time

Page 4

MTT Docket No. 25-002183 

Respondent’s Prehearing Statement, Page 4 of 5 

 

 

B. Discovery: 

- 

Respondent reserves the right to conduct post-valuation discovery in accordance 

with the Prehearing General Call. 

VIII. WITNESSES – IDENTIFY THE NAME AND ADDRESS OF ANY PERSON WHO 

MAY TESTIFY AND PROVIDE A GENERAL SUMMARY OF THE SUBJECT 

AREA OF THE TESTIMONY OF EACH PERSON IDENTIFIED: 

• Paula Moore, Chief Assessor, City of Waterford, c/o Respondent’s counsel. Ms. Moore 

may be called to testify as to her knowledge of the subject property, her knowledge of 

the surrounding area, Respondent’s valuation disclosures, Respondent’s assessment of 

the subject property, and any other matter necessary for Respondent to make its case in 

chief or rebut Petitioner’s allegations. 

• John R. Widmer, Jr., MAI, Frohm & Widmer, Inc., 33966 W. 8 Mile Road, Suite 108, 

Farmington Hills, MI 48335. Mr. Widmer may be called to testify as to his knowledge 

of the subject property, his knowledge of the surrounding area, his review appraisal, 

and any other matter necessary for Respondent to make its case in chief or rebut 

Petitioner’s allegations. 

• Melody Mohr, 6695 Highland Rd, Waterford Twp, MI 48327. Ms. Mohr may be called 

to testify as to her knowledge of the subject property, Petitioner’s discovery answers or 

any attachments thereto, and any other matter necessary for Respondent to make its 

case in chief or rebut Petitioner’s allegations. 

• Michael Illiades, 6695 Highland Rd, Waterford Twp, MI 48327. Mr. Illiades may be 

called to testify as to his knowledge of the subject property, Petitioner’s discovery 

answers or any attachments thereto, and any other matter necessary for Respondent to 

make its case in chief or rebut Petitioner’s allegations. 

• Zuelke Illiades, 6695 Highland Rd, Waterford Twp, MI 48327. Mr. Illiades may be 

called to testify as to his knowledge of the subject property, Petitioner’s discovery 

answers or any attachments thereto, the leasing of the subject property, and any other 

matter necessary for Respondent to make its case in chief or rebut Petitioner’s 

allegations. 

• Deborah Hockin, 5177 Ridgetop Drive, Waterford Twp, MI 48327. Ms. Hockin may 

be called to testify as to her knowledge of the subject property, the leasing of the subject 

property, and any other matter necessary for Respondent to make its case in chief or 

rebut Petitioner’s allegations. 

• Expert(s) to be selected and identified by Respondent. 

• Any and all witnesses listed by Petitioner. 

• Any and all persons who assisted in the preparation of Petitioner’s valuation 

disclosure. 

• Any and all necessary rebuttal witnesses. 

• Any and all custodians of the records. 

• Other witnesses to be determined. 

 

As provided by TTR 241, a person, other than a rebuttal witness, who is NOT identified as a witness sin 

the prehearing statement, shall NOT be permitted to give testimony, unless, for good cause shown, the 

Tribunal permits the testimony to be taken.

Page 5

MTT Docket No. 25-002183 

Respondent’s Prehearing Statement, Page 5 of 5 

 

 

IX. 

NUMBER OF DAYS REQUIRED FOR HEARING: 

4 days. 

X. 

DISCLOSURE AND TAXATION OF COSTS: 

Respondent reserves the right to request costs. 

 

 

HALLAHAN & ASSOCIATES, P.C. 

 

 

/s/Kelsea M. Melcher_________________ 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

Dated: September 8, 2026 

(248) 731-3089 

 

 

 

 

 

PROOF OF MAILING 

 

On the date below I sent by electronic mail a copy of the foregoing Respondent’s Prehearing 

Statement and Valuation Disclosure to: 

 

Jay A. Schwartz 

Property Tax Reduction Services, LLC 

jschwartz@propertytaxreductionservices.org 

 

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

 

 

/s/ Kelsea M. Melcher_______________ 

Dated: September 8, 2026 

Kelsea M. Melcher

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