Joint Motion for Abeyance - Partridge Senior Clinton (25-002498).pdf
Partridge Creek Senior Living LLC, Petitioner Vs. Township Of Clinton, Respondent · 25-002498-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL PARTRIDGE CREEK SENIOR LIVING, LLC, Petitioner, v CLINTON CHARTER TOWNSHIP Respondent. Docket No. 25-002498 _____________________________________________________________________________/ STEWART L. MANDELL (P33781) DANIEL L. STANLEY (P57052) HONIGMAN LLP Attorneys for Petitioner 39400 Woodward Avenue, Suite 101 Bloomfield Hills, MI 48304 (313) 465-7420 LAURA M. HALLAHAN (P42101) SETH A. O’LOUGHLIN (P80257) KELSEA M. MELCHER (P85821) HALLAHAN & ASSOCIATES, P.C. Attorneys for Respondent 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302 (248) 731-3089 _____________________________________________________________________________/ JOINT MOTION TO HOLD APPEAL IN ABEYANCE PENDING MTT DOCKET NO. 24-001683 The parties, by and through their respective counsel, state the following in support of the above captioned Joint Motion: 1. The above captioned appeal concerns the 2025 valuation of Parcel No. 16-11-05- 100-060 (the “Property”), located in Macomb County. This 2025 appeal has not yet been placed on a Prehearing General Call and Order of Procedure. 2. In MTT Docket No. 24-001683 (the “2024 Case”), the valuation of the Property is also at issue and valuation disclosures are currently due on November 17, 2025. With the
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62482872.1 2 exception of the tax year at issue, based on the pleadings filed to date, the parties, the Property, and issues raised in the 2024 Case and this case are substantially the same, if not identical. 3. The prosecution of this case will require the Parties and the Tribunal to expend substantial resources. Yet, it is quite likely that the resolution of the 2024 Case would have an important impact on this 2025 appeal. Therefore, not putting this case in abeyance could result in a tremendous waste of time and resources for the Parties and the Tribunal. 4. Given the foregoing, to proceed with this case before the resolution of the 2024 Case would not constitute an efficient administration of justice. 5. Placing this Case in abeyance at this juncture before substantial time and resources have been spent – including, but not limited to, the completion of appraisals – is in the interest of efficiency and judicial economy for the Tribunal and the Parties. 6. Granting this joint motion is proper under Tax Tribunal Act, MCL 205.732(c), which provides in pertinent part: "The tribunal's powers include, but are not limited to, all of the following: ... (c) Granting other relief or issuing writs, orders, or directives that it deems necessary or appropriate in the process of disposition of a matter over which it may acquire jurisdiction.” 7. Granting this Joint Motion will serve the interests of justice. 8. Indeed, in many similarly situated cases the Tribunal has granted the relief requested herein. 9. All of the foregoing establish that there is good cause for the Tribunal to grant this Joint Motion. WHEREFORE, the parties respectfully request the Tribunal enter an Order holding this case in abeyance pending the resolution of MTT Docket No. 24-001683.
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62482872.1 3 Respectfully submitted, HONIGMAN LLP /s/ Stewart L. Mandell________________ STEWART L. MANDELL (P33781) DANIEL L. STANLEY (P57052) Attorneys for Petitioner 39400 Woodward Avenue, Suite 101 Bloomfield Hills, MI 48304 (313) 465-7420 Dated: October 20, 2025 HALLAHAN & ASSOCIATES, P.C. /s/ Laura M. Hallahan______________ 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 (248) 731-3089 Dated: October 20, 2025