Motion to Compel and Brief in Support - Napior Adrian (26-000636).pdf

Napior Leasing, LLC Petitioner Vs. City Of Adrian Respondent · 26-000636-TT

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77449536.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Napior Leasing, LLC, 

Petitioner, 

v. 

City of Adrian, 

Respondent. 

MTT Docket No. 26-000636 

Jackie J. Cook (P68781) 

Scott L. Damich (P74126) 

Honigman LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7270 

jcook@honigman.com

sdamich@honigman.com

Laura M. Hallahan (P42101)

Seth A. O’Loughlin (P80251)

Kelsea M. Melcher (P85821)

Hallahan & Associates, P.C. 

Attorneys for Respondent

1750 S. Telegraph Rd., Suite 202

Bloomfield Hills, MI 48302

(248) 731-3089 

lhallahan@hallahanlaw.com

soloughlin@hallahanlaw.com

kmelcher@hallahanlaw.com

PETITIONER’S MOTION TO COMPEL RESPONDENT’S ANSWERS TO 

INTERROGATORIES AND REQUESTS FOR PRODUCTION 

Petitioner, Napior Leasing LLC (“Petitioner”), by and through its attorneys, Honigman 

LLP, respectfully moves this Tribunal pursuant to MCR 2.313(A), as incorporated by TTR 201(5), 

for an order compelling Respondent City of Adrian ("Respondent") to provide complete, 

substantive answers to Interrogatory Nos. 4, 5, and 6, including subparts (A) through (D) for each 

Request for Admission that Respondent denied, partially denied, qualified, or was unable to admit 

in full, and to produce responsive documents concerning how Respondent valued the property. 

WHEREFORE, Petitioner respectfully requests that this Tribunal enter an order: [a] 

overruling Respondent's relevance, scope, pre-valuation discovery, MCR 2.309(A)(2), custody-

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and-control, and possession objections to discovery concerning the September 19, 2025 sale of the 

subject property; [b] compelling Respondent to serve complete, substantive answers to 

Interrogatory Nos. 4, 5, and 6, including subparts (A) through (D) for each non-admitted Request 

for Admission, within fourteen (14) days, including but not limited to every fact upon which 

Respondent or its assessor relied in coding the sale “NOT USED/OTHER” on its 2026 property 

record card; [c] compelling production under Request for Production Nos. 6 and 7 of all responsive 

documents and requiring Respondent to identify any document it contends is already in Petitioner’s 

possession; [d] compelling Respondent to explain why the September 19, 2025 sale was excluded 

from its 2026 ECF Study and 2026 Land Study, to identify all sales considered and rejected for 

those studies, and to explain how the studies were applied in valuing the property; [e] compelling 

Respondent to serve answers verified under oath and signed by an authorized officer or agent of 

the City within fourteen (14) days; [f] awarding Petitioner its reasonable costs and attorney fees 

incurred in bringing this Motion pursuant to MCR 2.313(A)(5); and [g] granting such other and 

further relief as the Tribunal deems just and appropriate.

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Respectfully submitted, 

HONIGMAN LLP 

Attorney for Petitioner 

By: ___/s/ Scott L. Damich 

Jackie J. Cook (P68781) 

Scott L. Damich (P74126) 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7270 

jcook@honigman.com

Dated: October 15, 2026 

sdamich@honigman.com

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77449536.1 

BRIEF IN SUPPORT OF PETITIONER’S MOTION TO COMPEL RESPONDENT’S 

ANSWERS TO INTERROGATORIES AND PRODUCTION 

I.

Introduction 

This motion turns on a simple question that Respondent refuses to answer: why does 

Respondent’s assessor believe the September 2025 sale of the subject property was not an arm’s-

length transaction? The assessor reviewed the September 2025 sale and coded it in a manner that 

appears as though the assessor believes was not arms-length. Exhibit A, Property Record Card. 

When Petitioners served discovery asking about facts bearing on the arms-length character of the 

sale, including the sale’s marketing, offers, price, type, voluntariness, and the relationship between 

buyer and seller, Respondent refused to answer, objecting that the sale is irrelevant and outside the 

scope of this appeal. Exhibit B, Respondent’s Responses to Petitioners’ Interrogatories; 

Exhibit C, Respondent’s Response to Petitioners’ Requests for Admission. Respondent’s 

assessor cannot withhold the basis for her determination the sale was not arm’s length when her 

conclusion that it wasn’t is on the assessment record. 

Respondent has not identified the facts, persons, or documents supporting its non-

admissions, has not explained how it considered the September 19, 2025 sale, and has not 

explained why its assessor coded that pre-tax-day sale “NOT USED/OTHER.” Respondent’s 

failure to provide complete and properly verified answers warrants an order compelling full 

responses. 

II.

Statement of Facts 

This matter involves the 2026 ad valorem property tax assessment of real property located 

at 1751 W. Beecher St., Adrian, Lenawee County, Michigan (Parcel No. XA0-109-1150-02). 

Respondent’s 2026 assessed and taxable value of the Property is $5,590,000, consisting of a land 

value of $229,500 and a building value of $5,360,500. Exhibit A, 2026 Property Record Card.

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The Property was sold on September 19, 2025, before the December 31, 2025 tax day and 

valuation date. The purchase agreement was signed on May 31, 2025, and the sale price for the 

real property was $3,837,537. Information about how the sale was treated and about its arm’s-

length character is directly relevant to the Tribunal’s determination of the property’s true cash 

value. 

Respondent's 2025 and 2026 property record card demonstrate that the City of Adrian's 

assessor tracks and verifies sales of this parcel. Exhibit A, 2026 Property Record Card; Exhibit 

F, 2025 Property Record Card. The 2025 record card lists the property's prior sales history, 

including the 2018 sale coded "ARM'S LENGTH.” Exhibit F. The 2026 record card lists the 

September 19, 2025 sale from Fluresh, LLC to Napior Leasing, LLC, recorded by warranty deed 

at Liber/Page 2690:0467, with 100.0% transferred, verified by deed, and coded “NOT 

USED/OTHER.” Exhibit A. The card also lists a companion September 19, 2025 $0 OTH 

instrument at Liber/Page 2690:0468 with the same code. The record card reflects 2026 estimated 

true cash value of $11,180,036, a TCV/TFA ratio of 106.9, and land valued at $458,996 for 27.076 

acres. Id. The assessor’s practice of tracking, verifying, and coding sales undercuts Respondent's 

claims that it lacks information about the September 2025 sale. 

Respondent has since produced its 2026 ECF Study and 2026 Land Study for the property. 

Exhibit D, 2026 ECF Study; Exhibit E, 2026 Land Study. The 2026 ECF Study derives the 

0.683 average ECF that the record card applies to each of the property’s five buildings from just 

four sales, all coded “ARM’S LENGTH,” that occurred between January 31, 2022 and October 

26, 2023, involving buildings of 847 to 12,149 square feet that sold for $45,000 to $262,500. 

Exhibits A and D. The 2026 ECF Study is identical in every respect to Respondent’s 2025 ECF 

Study; it includes no sale from 2024 or 2025. The 2026 Land Study derives a rate of approximately

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$88,300 per net acre from eight sales, each coded “03-ARM’S LENGTH,” of parcels between 0.18 

and 1.64 acres that sold for $40,000 to $300,000 between September 8, 2023 and February 28, 

2025. Exhibit E. The record card values the property’s 27.076 acres at $16,952 per acre, for a land 

value of $458,996. Exhibit A. Neither study includes the September 19, 2025 sale of the property 

itself. Exhibits D and E.

Petitioner served its First Set of Interrogatories and Requests for Production on 

Respondent. Exhibit B, Respondent’s 2026 Interrogatory and Request for Production 

Responses. Respondent also served responses to Petitioner’s Requests for Admission. Exhibit C, 

Respondent’s 2026 Responses to Requests for Admission (RFAs). The responses address the 

September 2025 sale, including the sale’s marketing and offers (RFAs 4–7), purchase agreement 

and price (RFAs 8–11), type and voluntariness of the sale (RFAs 12–22), and the independence 

and relationship of the Buyer and Seller (RFAs 23–31). 

Interrogatory Nos. 4 and 5 ask how Respondent considered the September 2025 sale in 

determining true cash value as of December 31, 2025 and, if it did not consider the sale, why not. 

Interrogatory No. 6 asks for the facts, persons, documents, and disputed portions underlying each 

non-admitted RFA. Respondent objected and referred Petitioner to attached assessment records or 

to the RFA responses rather than providing the requested information. Exhibits B and C. 

III.

Legal Standard 

The Michigan Tax Tribunal applies the Michigan Court Rules where its own rules do not 

otherwise govern. TTR 201(5). Discovery extends to "any matter, not privileged, which is relevant 

to the subject matter involved in the pending action." MCR 2.302(B)(1). "It is not ground for 

objection that the information sought will be inadmissible at trial if the information sought appears 

reasonably calculated to lead to the discovery of admissible evidence." Id. Interrogatories must be

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"answered separately and fully in writing under oath." MCR 2.309(B). If a party fails to answer an 

interrogatory, the discovering party may move to compel an answer under MCR 2.313(A). 

Critically, "[a]n evasive or incomplete answer is to be treated as a failure to answer." MCR 

2.313(A)(4). If a motion to compel is granted, the Tribunal must order the resisting party to pay 

the moving party's reasonable expenses, including attorney fees, unless the resistance was 

substantially justified or other circumstances make an award unjust. MCR 2.313(A)(5). 

IV.

Argument 

A.

Respondent’s cross-reference to its RFA responses is not a substantive answer 

to Interrogatory No. 6. 

Interrogatory No. 6 asked Respondent, for each RFA it denied, partially denied, qualified, 

or was unable to admit in full, to state in detail:

(A) every fact upon which the denial, partial denial, qualification, or failure to admit is 

based;

(B) the identity of all people with knowledge of those facts;

(C) the identity of all documents, information, communications, and other materials that 

support the response;

(D) the specific portion of the RFA contended inaccurate, incomplete, or otherwise 

incapable of admission. [Exhibit B.] 

After objecting, Respondent's sole substantive response was: "Subject to and without 

waiving said objections, please see Respondent's Responses to Petitioner's Request for 

Admission." Id. Respondent’s cross-reference does not answer the interrogatory. Respondent's 

RFA responses contain objections, qualified admissions, and non-admissions, not the facts, people, 

and documents that Interrogatory No. 6 specifically requests. For example, Respondent's response 

to RFA No. 7, concerning whether at least three offers were made, objects on lack-of-knowledge

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grounds and leaves Petitioner to its proofs. Exhibit C. Nowhere does that response identify the 

facts supporting the non-admission, the persons with knowledge, or the documents relied upon. 

The same is true of RFAs 4–6, 11–12, 19–22, and 28-31. 

MCR 2.309(B) requires that interrogatories be "answered separately and fully." An answer 

that merely points to another discovery response is incomplete and evasive. Under MCR 

2.313(A)(4), Respondent’s response to Interrogatory No. 6 should be treated as a failure to answer. 

B.

The September 2025 sale is relevant to true cash value and is within the scope 

of discovery. 

Respondent's overriding objections are that the September 2025 sale is "outside the scope 

of this appeal" and irrelevant to the true cash value of the subject property as of December 31, 

2025. Exhibits B and C. This objection fundamentally misapprehends the scope of discovery and 

the law of property-tax valuation in Michigan. 

True cash value is "the usual selling price" of the property. MCL 211.27(1). A recent arm's-

length sale of the property itself is among the strongest evidence of its true cash value. A sale of 

the subject property shortly before the valuation date is particularly probative. See, e.g., Jones & 

Laughlin Steel Corp. v. City of Warren, 193 Mich. App. 348 (1992); Detroit Lions, Inc. v. City of 

Dearborn, 302 Mich. App. 676, 696 (2013); Professional Plaza, LLC v. City of Detroit, 250 Mich. 

App. 473, 476 (2002). 

The Tribunal exercises independent judgment and may consider all relevant evidence in 

arriving at its own determination of true cash value. Whether the September 2025 sale is probative 

depends on whether it was arm's length. That is precisely what Petitioner’s RFAs and Interrogatory 

No. 6 seek to establish. The factors bearing on arm's-length status—adequate market exposure, 

multiple offers, voluntariness, absence of financial distress, and the independence of the Buyer 

and Seller—are defined by statute. MCL 211.27(6). A sale is not arm's length if the price was

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influenced by a "special relationship" between the parties. Id. Petitioner is entitled to develop the 

factual record on these points. 

Here, the September 19, 2025 sale occurred before the December 31, 2025 valuation date. 

Respondent therefore cannot rely on the timing objection it asserted in the prior matter, and its 

RFAs 28–31 objection that the sale is “outside the scope of this appeal” cannot apply to a pre-tax-

day sale of the subject property. The sales timing supports, rather than defeats, discoverability. 

MCR 2.302(B)(1) extends to information "reasonably calculated to lead to the discovery of 

admissible evidence." Respondent cannot unilaterally resolve the contested question of relevance 

by refusing to answer. Its position that the sale is irrelevant is a merits argument for the Tribunal 

during hearing. It is not a basis for refusing discovery.

C.

Respondent’s pre-valuation discovery objection is misplaced. 

Respondent objects that Interrogatory No. 6 "exceeds the scope of pre-valuation 

discovery." Exhibit B. This objection conflates two distinct categories of discovery.

Interrogatory No. 6 does not seek Respondent's valuation opinions, appraisals, or expert 

analyses. Those are disclosures governed by the Prehearing General Call. Rather, it seeks 

foundational facts: the factual basis for Respondent's non-admissions, the identity of persons with 

knowledge, and the identity of supporting documents. Requests for Production Nos. 4 and 8 

likewise seek the 2026 work file and documents supporting the assessed value, not expert 

testimony. This is standard factual discovery about the Property and the circumstances of its sale.

Moreover, the sale occurred before the December 31, 2025 valuation date. Respondent 

itself relies on factual positions in its RFA responses, including that it lacks knowledge of the 

sale’s circumstances and that the requests are outside the scope of the appeal. It then refuses to 

disclose the facts, people, and documents underlying those positions. A party cannot wield factual 

non-admissions as both a sword and a shield.

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D.

The interrogatory-limit objection under MCR 2.309(A)(2) is without merit. 

Respondent objects that Interrogatory No. 6 "seeks to use the above interrogatory as a 

method to circumvent the limitation placed on interrogatory requests under MCR 2.309(A)(2)." 

Exhibit B. MCR 2.309(A)(2) limits interrogatories to twenty, including subparts, absent a 

stipulation or court order. Interrogatory No. 6 is a single interrogatory with four defined subparts 

(A-D), keyed to the RFAs. It is a standard and efficient discovery device. But even if the Tribunal 

were to characterize each RFA subpart as a separate interrogatory, the Tribunal retains discretion 

to allow additional interrogatories for good cause. MCR 2.309(A)(2). Good cause exists because 

Respondent's blanket objections prevent Petitioner from preparing for hearing with an 

understanding of the factual basis for Respondent's positions. 

E.

Respondent’s lack-of-knowledge claims are undercut by its own records. 

Several of Respondent's RFA responses assert that it "lacks knowledge" of facts about the 

September 2025 sale, particularly regarding the number of offers (RFA 7), whether the sale was 

forced or voluntary (RFAs 11, 12, 19–22), and the parties' relationship (RFAs 28-31). Exhibit C.

These claims are undercut by Respondent's own records. 

The assessor’s 2026 property record card records the September 19, 2025 sale, identifies 

the warranty deed at Liber/Page 2690:0467, states that 100.0% transferred, identifies “DEED” as 

the verification source, and codes the transaction “NOT USED/OTHER.” Exhibit A. It separately 

records the companion $0 OTH instrument at Liber/Page 2690:0468 with the same code. Exhibit 

A. The assessor necessarily had information sufficient to verify and code the sale. 

Given the assessor's established verification practice, the information sought by 

Interrogatory No. 6 is either already in Respondent's possession or readily obtainable through 

reasonable inquiry. Respondent's blanket claims of ignorance about a sale of property within its

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own taxing jurisdiction, closed before the applicable tax day and valuation date, do not withstand 

scrutiny. 

F.

Respondent must produce responsive documents concerning the sale. 

Request for Production No. 6 seeks all documents regarding the September 2025 sale, and 

Request for Production No. 7 seeks documents supporting Respondent’s answers to Interrogatory 

Nos. 4–6. Exhibit B. Respondent’s custody-and-control and possession objections do not excuse 

production of the assessor’s own sales-verification records, the property transfer affidavit as 

received by the assessor, sales verification questionnaires and records, sales-study coding entries, 

assessor notes, or correspondence concerning the sale. Respondent must at least identify the 

documents it relies upon, including any document it contends is already in Petitioner’s possession. 

Petitioner requests that the Tribunal compel production of all responsive documents and 

identification of any withheld or relied-upon document. 

G.

Respondent must explain the “NOT USED/OTHER” coding. 

The 2026 property record card does not merely omit information about the September 2025 

sale; it affirmatively records the sale and classifies it as “NOT USED/OTHER,” while the earlier 

2018 sale is coded “ARM’S LENGTH.” Exhibit A; Exhibit F. The September 19, 2025 warranty-

deed sale is listed at $3,837,537, with 100.0% transferred and verified by deed. Id. That coding 

presents a factual question Respondent must answer: what facts, documents, or analysis caused the 

assessor to treat a pre-tax-day sale of the subject property as not used or other rather than as an 

arm’s-length sale? 

Respondent’s RFA responses admit the purchase agreement, the real-property price, and 

that the sale was not an auction, foreclosure, sheriff’s, tax-foreclosure, bankruptcy, or liquidation 

sale. Respondent also admitted, upon information and belief, that the Buyer and Seller were 

separate, unrelated business entities and restated that response for related requests. Exhibit C. Yet

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Respondent refuses to answer Interrogatory Nos. 4 and 5, which ask how the sale was considered 

in determining TCV as of December 31, 2025 and, if it was not considered, why not. Exhibit B. 

Referring Petitioner to “assessment records” does not explain the “NOT USED/OTHER” coding. 

Respondent must provide the facts, people, and documents supporting its treatment of the 

sale, including every fact on which the assessor relied in assigning the “NOT USED/OTHER” 

code. Kristen Brown established the 2026 tax-roll values and is identified as the source of 

Respondent’s answers “as to content.” Exhibit B. The record card confirms that the assessor 

verified and coded the sale. Exhibit A. Respondent cannot both rely on its assessor’s coded record 

and refuse to disclose the factual basis for that coding. MCR 2.309(B) and MCR 2.313(A)(4) 

require complete answers, and the Tribunal should compel Respondent to provide them. 

H.

Respondent’s 2026 ECF and Land Studies confirm that the September 2025 

sale was excluded and that Respondent must explain why. 

The 2026 studies Respondent produced underscore the need for a complete answer. The 

0.683 ECF applied to every building on the Property comes from four sales, the most recent of 

which occurred on October 26, 2023, and none of which involved a building larger than 12,149 

square feet. Exhibit D. The 2026 ECF Study is the same study Respondent used for 2025; 

Respondent did not add a single 2024 or 2025 sale. The 2026 Land Study, by contrast, relies on 

sales through February 28, 2025, of parcels no larger than 1.64 acres, to value a 27.076-acre site. 

Exhibit E. Respondent was therefore willing to rely on small, dated, or 2025 sales of other 

properties, yet excluded from both studies the September 19, 2025, $3,837,537 sale of the property 

itself, a sale it coded “NOT USED/OTHER.” Exhibits B, D, and E.

The studies themselves do not explain that choice. They list only the sales Respondent 

included; they say nothing about which sales Respondent considered and rejected, or why. Nor do 

they explain how a 0.683 factor derived from four small commercial buildings, or a per-acre rate

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derived from parcels under two acres, was applied to a 104,569-square-foot facility on 27 acres. 

Exhibits B, D, and E. Respondent’s statement in response to Interrogatory No. 4 that the “attached 

assessment records” reflect “the factors taken into consideration” is therefore incomplete. Exhibit 

B. The Tribunal should compel Respondent to explain why the September 2025 sale was excluded 

from its 2026 studies, what sales were considered and rejected, and how the studies were applied 

to the Property, and to produce all documents relating to those determinations. 

I.

Respondent’s Interrogatory answers are deficient because they are not 

verified by the party under oath. 

The Tax Tribunal Rules requires that interrogatory answers be provided by the responding 

party under oath. Respondent violated the Tribunal Rules because its interrogatory answers were 

signed only by counsel. 

TTR 243(1) provides that a party may serve “written interrogatories to be answered by the 

party to whom the interrogatories are directed.” (Emphasis added.) Notably, the rule identifies the 

responding party, not counsel, as the individual responsible for providing the answer. “The answer 

must be signed by the person making them.” TTR 243(2). TTR 243(2) further provides that 

“[e]ach interrogatory shall be answered separately and fully in writing under oath.” (Emphasis 

added.) When these provisions are read together, the only reasonable interpretation is that the 

party to whom the interrogatories are directed must answer each interrogatory separately and fully 

under oath. Facts are known by witnesses, not attorneys. Parties are generally witnesses because 

they are the persons knowledgeable about the underlying facts to a case. That’s why a party must 

sign the interrogatory answers, swearing under oath the facts given are true, and that the answers 

“contain information that is available to the party served or that could be obtained by the party 

from its employees, agents, representatives, or persons who may testify on the party’s behalf.” 

TTR 243(2). If an attorney is the person signing to the veracity of facts, then the attorney is the

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fact witness who should be called to testify about those facts at trial. For this same reason, attorneys 

do not sign affidavits. Only a fact witness who can testify to the accuracy of the facts presented in 

the affidavit can sign an affidavit. There are many reasons an attorney would not apply their 

signature to factual representations, swearing under oath they are true, including MCR 1.109(E)(6) 

which imposes sanctions on an attorney who signs a document that the attorney should have known 

is not grounded in fact. And if the attorney is the person personally verifying the accuracy of the 

facts, then the attorney is a witness. 

Michigan courts construe rules according to the same principles governing statutory 

interpretation. Airgas Specialty Products v Michigan Occupational Safety & Health 

Administration, 338 Mich App 482, 495 (2021). Under those principles, every word and phrase 

must be given meaning, and a court must avoid constructions that render language surplusage or 

nugatory. Estate of Shinholster v Annapolis Hosp, 471 Mich 540, 549 (2004). Respondent’s 

interpretation violates these principles. If counsel alone may answer interrogatories and satisfy 

the oath requirement merely by signing the responses, then the phrase “answered by the party to 

whom the interrogatories are directed” serves no purpose. Similarly, the rules requirement that 

interrogatories be answered “under oath” becomes pointless if the oath need not be made by the 

individual possessing personal knowledge of the facts. The Tribunal should avoid an interpretation 

that renders either provision superfluous. 

The Michigan Court Rules confirm this understanding. Under MCR 2.309(B)(1), “[e]ach 

interrogatory must be answered separately and fully in writing under oath.” MCR 2.309(B)(3) 

further provides that “[t]he answers must be signed by the person making them and the objections 

signed by the attorney or an unrepresented party making them.” Michigan discovery practice

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requires factual answers to be verified by the person possessing the relevant knowledge, while 

legal objections may be asserted by counsel. 

Moreover, an attorney signature serves a fundamentally different purpose than a party 

answering a question under oath. Counsel may certify that reasonable inquiry has been made and 

that a filing is warranted, but counsel cannot swear to factual matters outside counsel’s personal 

knowledge. The oath required by TTR 243(2) necessarily contemplates a sworn attestation from 

the responding party that the answers are true and complete. A signature by counsel alone provides 

no such assurance. 

This interpretation is also consistent with the Tribunal’s statutory authority to ensure the 

integrity of proceedings. The Tribunal is empowered to issue orders and directives necessary or 

appropriate for the disposition of matters within its jurisdiction. MCL 205.732(c). Requiring 

interrogatory answers to be verified by the responding party advances the truth-seeking purpose 

of discovery and ensures that factual responses are supported by the individual possessing the 

relevant information. 

Accordingly, because TTR 243 requires interrogatories to be answered by the party and 

further requires that the answers be provided under oath, Respondent’s unverified responses signed 

only by counsel are deficient. The Tribunal should order Respondent to serve complete, verified 

interrogatory answers executed under oath by Respondent. If the Tribunal agrees with Respondent 

that its attorneys can swear to facts alleged in its client’s discovery responses by signing them, 

then the attorney must sign “under oath” under TTR 243(2). If the attorney is the person answering 

each interrogatory “separately and fully in writing” under TTR 243(2), then the attorney’s 

signature must be “under oath.”

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V.

Conclusion and Relief Requested 

For the foregoing reasons, Petitioner respectfully requests that the Tribunal enter an order: 

(1)

Overruling Respondent's relevance, scope, pre-valuation discovery, MCR 

2.309(A)(2), custody-and-control, and possession objections to discovery 

concerning the September 19, 2025 sale and the 2026 assessment; 

(2)

Compelling Respondent to serve complete, substantive answers to Interrogatory 

Nos. 4 and 5 within fourteen (14) days of the Tribunal’s order, separately explaining 

how Respondent considered the September 2025 sale in determining true cash value 

as of December 31, 2025 and, if it did not consider the sale, why not; 

(3)

Compelling Respondent to serve a complete, substantive answer to Interrogatory 

No. 6, subparts (A) through (D), within fourteen (14) days of the Tribunal’s order, 

for each Request for Admission that Respondent denied, partially denied, qualified, 

or was unable to admit in full, including without limitation RFAs 4–7, 11, 12, 19–

22, and 28–31, and any other RFA not fully admitted, including every fact upon 

which Respondent or its assessor relied in coding the September 19, 2025 sale 

“NOT USED/OTHER”; 

(4)

Compelling Respondent to serve answers to all interrogatories verified under oath 

and signed by an authorized officer or agent of the City within fourteen (14) days 

of the Tribunal’s order; 

(5)

Compelling Respondent, under Request for Production No. 6, to produce within the 

same fourteen-day period all documents regarding the September 19, 2025 sale, 

and to identify any document Respondent contends Petitioner already possesses; 

(6)

Compelling Respondent, under Request for Production No. 7, to produce within the

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same fourteen-day period all documents supporting its answers to Interrogatory 

Nos. 4, 5, and 6, including every document identified under Interrogatory No. 6(C), 

and, to the extent not already produced, the responsive portions of the 2026 work 

file and assessed-value materials sought by Request for Production Nos. 4 and 8; 

(7)

Compelling Respondent, within the same fourteen-day period, to explain why the 

September 19, 2025 sale of the property was excluded from its 2026 ECF Study 

and 2026 Land Study, to identify all sales considered and rejected for those studies, 

to explain how the studies were applied in valuing the property, and to produce all 

documents relating to those determinations; 

(8)

Awarding Petitioner its reasonable expenses, including attorney fees, incurred in 

bringing this Motion, pursuant to MCR 2.313(A)(5); and 

(9)

Granting such other and further relief as the Tribunal deems just and appropriate.

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Respectfully submitted, 

HONIGMAN LLP 

Attorney for Petitioner 

By: ___/s/ Scott L. Damich 

Jackie J. Cook (P68781) 

Scott L. Damich (P74126) 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7270 

jcook@honigman.com

Dated: October 15, 2026 

sdamich@honigman.com

77449536.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Napior Leasing, LLC, 

Petitioner, 

v. 

City of Adrian, 

Respondent. 

MTT Docket No. 26-000636 

Jackie J. Cook (P68781) 

Scott L. Damich (P74126) 

Honigman LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7270 

jcook@honigman.com

sdamich@honigman.com

Laura M. Hallahan (P42101)

Seth A. O’Loughlin (P80251)

Kelsea M. Melcher (P85821)

Hallahan & Associates, P.C. 

Attorneys for Respondent

1750 S. Telegraph Rd., Suite 202

Bloomfield Hills, MI 48302

(248) 731-3089 

lhallahan@hallahanlaw.com

soloughlin@hallahanlaw.com

kmelcher@hallahanlaw.com

Proof of Service 

The undersigned states that she is employed by Honigman LLP and that on October 15, 

2026 she served a copy of the foregoing on Respondent’s counsel of record, by way of electronic 

mail. 

/s/ Lisa Joseph 

Dated: October 15, 2026 

Lisa Joseph

20 

Exhibit A

*** Information herein deemed reliable but not guaranteed***

LENAWEE

County:

CITY OF ADRIAN

Jurisdiction:

Printed on

Parcel Number:

XA0-109-1150-02

6,219,900S

6,219,900X

6,219,900M

6,219,900

6,064,700

155,200

2023

5,977,900S

5,977,900M

5,977,900

5,692,500

285,400

2024

5,641,400S

5,641,400M

5,641,400

5,378,600

262,800

2025

5,590,000S

5,590,000M

5,590,000

5,360,500

229,500

2026

Taxable

Value

Tribunal/

Other

Board of

Review

Assessed

Value

Building

Value

Land

Value

Year

Land Improvement Cost Estimates

Description Rate Size % Good Cash Value

D/W/P: Asphalt Paving 2.75 123256 79 267,774

Fencing: Wire Mesh, #11 3.21 10000 79 25,359

Fencing: Wire Mesh, #11 3.21 9074 79 23,011

 Total Estimated Land Improvements True Cash Value = 316,144

 * Factors *

Description Frontage Depth Front Depth Rate %Adj. Reason Value

100K 1ST ACRE 27.076 Acres 16,952 100 458,996

 27.08 Total Acres Total Est. Land Value = 458,996

Land Value Estimates for Land Table C100K.COMM 100K 1ST ACRE

KIR 01/21/2020 AssessApp 

Who When What

Level

Rolling

Low

High

Landscaped

Swamp

Wooded

Pond

Waterfront

Ravine

Wetland

Flood Plain

 

 

 

 

 

 

 

 

 

 

 

 

 

Topography of 

Site

Dirt Road

Gravel Road

Paved Road

Storm Sewer

Sidewalk

Water

Sewer

Electric

Gas

Curb

Street Lights

Standard Utilities

Underground Utils.

 

 

 

 

 

 

 

 

 

 

 

 

 

Public

Improvements

Vacant

 

Improved

X

The Equalizer. Copyright (c) 1999 - 2009.

Licensed To: City of Adrian, County of

Lenawee, Michigan

12/9/25 - RCVD MAIL BACK FROM USPS AS NO

SUCH NUMBER. NO CONTACT INFO FOUND TO GET

UPDATED MAILING. LK 

Split/Comb. on 06/04/2018 completed

06/04/2018 KWETZEL ;

Parent Parcel(s): XA0-109-1150-01;

Comments/Influences

BEING ALL THAT PART OF THE NORTHWEST 1/4,

SECTION 9, TOWN 7 SOUTH, RANGE 3 EAST,

CITY OF ADRIAN, LENAWEE COUNTY, MICHIGAN,

AND FURTHER DESCRIBED AS FOLLOWS:

COMMENCING AT THE NORTH 1/4 CORNER OF

SAID SECTION 9, BEING A FOUND 5/8" IRON

ROD WITH CAP # 13040 IN MONUMENT BOX,

ALSO BEING ON THE CENTERLINE RIGHT-OF-WAY

OF BEECHER ROAD (A/K/A M-34); THENCE

NORTH 89°40'39" WEST A DISTANCE OF 870.56

FEET ALONG SAID NORTH LINE OF SECTION 9

AND SAID CENTERLINE RIGHT-OF-WAY OF

BEECHER ROAD TO A POINT, SAID POINT BEING

THE TRUE POINT OF BEGINNING; THENCE SOUTH

00°39'55" WEST AND PARALLEL WITH THE

NORTH-SOUTH 1/4 LINE OF SAID SECTION 9 A

DISTANCE OF 1318.32 FEET TO A FOUND IRON

ROD CAP # 46682 AES SET ON THE NORTHERLY

RIGHT-OF-WAY LINE OF ADRIAN-BLISSFIELD

RAILROAD, PASSING THROUGH A FOUND IRON

ROD WITH CAP # 46682 AES AT 50 FEET SET

***BALANCE OF DESCRIPTION ON FILE***

Tax Description

NAPIOR LEASING, LLC

2501 TRAVERSEFIELD DRIVE

TRAVERSE CITY MI 49686

Owner's Name/Address

1751 W BEECHER ST

Property Address

PM19-241

12/27/2019

Mechanical New Com

2026 Est TCV 11,180,036 TCV/TFA: 106.9

PP19-124

12/27/2019

Plumbing New Com

MAP #: 

PB20-024

02/11/2020

B- Com Add/Alter/Repair

P.R.E. 0% Qual. Ag.

PB25-263

09/26/2025

B- Com Add/Alter/Repair

School: ADRIAN CITY SCHOOL DISTRICT

Status

Number

Date

Building Permit(s)

Zoning: I-2

Class: COMMERCIAL-IMPROVE

0.0

DEED

2637:0072

21-NOT USED/OTHER

OTH

03/23/2022

0

TRC - DEVCO LLC

FLURESH, LLC

0.0

DEED

2637:0071

21-NOT USED/OTHER

WD

03/23/2022

0

FLURESH, LLC

TRC-DEVCO LLC

0.0

DEED

2690:0468

21-NOT USED/OTHER

OTH

09/19/2025

0

NAPIOR LEASING, LLC

100.0

DEED

2690:0467

21-NOT USED/OTHER

WD

09/19/2025

3,837,537

NAPIOR LEASING, LLC 

FLURESH, LLC

Prcnt.

Trans.

Verified

By

Liber

& Page

Terms of Sale

Inst.

Type

Sale

Date

Sale

Price

Grantee

Grantor

04/22/2026

Bsmnt Insul.

 

Thickness

 

 (40) Exterior Wall:

 (39) Miscellaneous:

 (14) Roof Cover:

 (13) Roof Structure: Slope=0 

Incandescent

Fluorescent

Mercury

Sodium Vapor

Transformer

 

 

 

 

 

Flex Conduit

Rigid Conduit

Armored Cable

Non-Metalic

Bus Duct

 

 

 

 

 

Few

Average

Many

Unfinished

Typical

 

 

 

 

 

Few

Average

Many

Unfinished

Typical

 

 

 

 

 

Fixtures:

Outlets:

 (11) Electric and Lighting:

Hand Fired

Boiler

 

 

Coal

Stoker

 

 

Gas

Oil

 

 

 (10) Heating and Cooling:

 (9) Sprinklers:

Urinals

Wash Bowls

Water Heaters

Wash Fountains

Water Softeners

 

 

 

 

 

Total Fixtures

3-Piece Baths

2-Piece Baths

Shower Stalls

Toilets

 

 

 

 

 

Few

None

 

 

Average

Typical

 

 

Many

Above Ave.

 

 

 (8) Plumbing:

 (7) Interior:

 (6) Ceiling:

 (5) Floor Cover:

 (4) Floor Structure:

 (3) Frame:

Block

 

Brick/Stone

 

Poured Conc.

X

Footings

 

 (2) Foundation:

 (1) Excavation/Site Prep:

<<<<< Calculator Cost Computations >>>>>

 Class: S Quality: Good

Stories: 1 Story Height: 20 Perimeter: 604

 

Base Rate for Upper Floors = 99.82

 

(10) Heating system: Complete H.V.A.C. Cost/SqFt: 50.77 100%

Adjusted Square Foot Cost for Upper Floors = 150.59

 

Total Floor Area: 19,469 Base Cost New of Upper Floors = 2,931,837

 

 Reproduction/Replacement Cost = 2,931,837

Eff.Age:8 Phy.%Good/Abnr.Phy./Func./Econ./Overall %Good: 82 /100/100/100/82.0

 Total Depreciated Cost = 2,404,106

 

Unit in Place Items Rate Quantity Arch %Good Depr.Cost

 /CI11/WELSW/50000 154500.00 1 1.00 62 95,790

 /CI11/VERBS/F10000 27810.00 1 1.00 62 17,242

 

ECF (COMM W BEECHER ST ETAL) 0.683 => TCV of Bldg: 1 = 1,719,205

 Replacement Cost/Floor Area= 159.95 Est. TCV/Floor Area= 88.30

 ** ** Calculator Cost Data ** **

Quality: Good 

Heat#1: Complete H.V.A.C. 100%

Heat#2: Electric, Cable or Baseboard 0%

Ave. SqFt/Story: 19469

Ave. Perimeter: 604

Has Elevators:

 

 *** Basement Info ***

Area:

Perimeter:

Type:

Heat:

 

 * Mezzanine Info *

Area #1:

Type #1:

Area #2:

Type #2:

 

 * Sprinkler Info *

Area:

Type:

Low

X

Ave.

 

Above Ave.

 

High

 

Construction Cost

Comments:

Overall Bldg

Height

 

Year Built

Remodeled

 

 

Depr. Table : 2.5%

Effective Age : 8

Physical %Good: 82

Func. %Good : 100

Economic %Good: 100

Class: S

Floor Area: 19,469

Gross Bldg Area: 104,569

Stories Above Grd: 1

Average Sty Hght : 20

Bsmnt Wall Hght 

Desc. of Bldg/Section: 

Calculator Occupancy: Industrial - Light Manufacturing

*** Information herein deemed reliable but not guaranteed***

Commercial/Industrial Building/Section 1 of 5

Printed on

Parcel Number:

XA0-109-1150-02

04/22/2026

*** Information herein deemed reliable but not guaranteed***

Parcel Number: XA0-109-1150-02, Commercial/Industrial Building 1

Printed on

04/22/2026

Parcel Number: 

XA0-109-1150-02, 

Commercial/Industrial Building 

1 

Printed on 

04/22/2026 

Storage Building | 3 

3600.0sf 

| © 

3 

15 

| 

19465.3 

Ses 

= 

Greenhouse 

31200.0 sf 

260° 

5 

Greenhouse 

so 

& 

46800.0 sf 

Secured waste | 2 

35000%F 

‘Sketch by Apex Sketch 

*** 

Information herein deemed reliable 

but 

not guaranteed***

Bsmnt Insul.

 

Thickness

 

 (40) Exterior Wall:

 (39) Miscellaneous:

 (14) Roof Cover:

 (13) Roof Structure: Slope=0 

Incandescent

Fluorescent

Mercury

Sodium Vapor

Transformer

 

 

 

 

 

Flex Conduit

Rigid Conduit

Armored Cable

Non-Metalic

Bus Duct

 

 

 

 

 

Few

Average

Many

Unfinished

Typical

 

 

 

 

 

Few

Average

Many

Unfinished

Typical

 

 

 

 

 

Fixtures:

Outlets:

 (11) Electric and Lighting:

Hand Fired

Boiler

 

 

Coal

Stoker

 

 

Gas

Oil

 

 

 (10) Heating and Cooling:

 (9) Sprinklers:

Urinals

Wash Bowls

Water Heaters

Wash Fountains

Water Softeners

 

 

 

 

 

Total Fixtures

3-Piece Baths

2-Piece Baths

Shower Stalls

Toilets

 

 

 

 

 

Few

None

 

 

Average

Typical

 

 

Many

Above Ave.

 

 

 (8) Plumbing:

 (7) Interior:

 (6) Ceiling:

 (5) Floor Cover:

 (4) Floor Structure:

 (3) Frame:

Block

 

Brick/Stone

 

Poured Conc.

X

Footings

 

 (2) Foundation:

 (1) Excavation/Site Prep:

<<<<< Calculator Cost Computations >>>>>

 Class: S Quality: Excellent

Stories: 1 Story Height: 20 Perimeter: 880

 

Base Rate for Upper Floors = 167.65

 

(10) Heating system: Package Heating & Cooling Cost/SqFt: 19.36 100%

Adjusted Square Foot Cost for Upper Floors = 187.01

 

Total Floor Area: 46,800 Base Cost New of Upper Floors = 8,752,068

 

 Reproduction/Replacement Cost = 8,752,068

Eff.Age:8 Phy.%Good/Abnr.Phy./Func./Econ./Overall %Good: 82 /100/100/100/82.0

 Total Depreciated Cost = 7,176,696

 

ECF (COMM W BEECHER ST ETAL) 0.683 => TCV of Bldg: 2 = 4,901,683

 Replacement Cost/Floor Area= 187.01 Est. TCV/Floor Area= 104.74

 ** ** Calculator Cost Data ** **

Quality: Excellent

Heat#1: Package Heating & Cooling 100%

Heat#2: Electric, Cable or Baseboard 0%

Ave. SqFt/Story: 46800

Ave. Perimeter: 880

Has Elevators:

 

 *** Basement Info ***

Area:

Perimeter:

Type:

Heat:

 

 * Mezzanine Info *

Area #1:

Type #1:

Area #2:

Type #2:

 

 * Sprinkler Info *

Area: 100

Type: Excellent

Low

X

Ave.

 

Above Ave.

 

High

 

Construction Cost

Comments:

Overall Bldg

Height

 

Year Built

Remodeled

 

 

Depr. Table : 2.5%

Effective Age : 8

Physical %Good: 82

Func. %Good : 100

Economic %Good: 100

Class: S

Floor Area: 46,800

Gross Bldg Area: 104,569

Stories Above Grd: 1

Average Sty Hght : 20

Bsmnt Wall Hght 

Desc. of Bldg/Section: 

Calculator Occupancy: Greenhouses - Commercial

*** Information herein deemed reliable but not guaranteed***

Commercial/Industrial Building/Section 2 of 5

Printed on

Parcel Number:

XA0-109-1150-02

04/22/2026

Bsmnt Insul.

 

Thickness

 

 (40) Exterior Wall:

 (39) Miscellaneous:

 (14) Roof Cover:

 (13) Roof Structure: Slope=0 

Incandescent

Fluorescent

Mercury

Sodium Vapor

Transformer

 

 

 

 

 

Flex Conduit

Rigid Conduit

Armored Cable

Non-Metalic

Bus Duct

 

 

 

 

 

Few

Average

Many

Unfinished

Typical

 

 

 

 

 

Few

Average

Many

Unfinished

Typical

 

 

 

 

 

Fixtures:

Outlets:

 (11) Electric and Lighting:

Hand Fired

Boiler

 

 

Coal

Stoker

 

 

Gas

Oil

 

 

 (10) Heating and Cooling:

 (9) Sprinklers:

Urinals

Wash Bowls

Water Heaters

Wash Fountains

Water Softeners

 

 

 

 

 

Total Fixtures

3-Piece Baths

2-Piece Baths

Shower Stalls

Toilets

 

 

 

 

 

Few

None

 

 

Average

Typical

 

 

Many

Above Ave.

 

 

 (8) Plumbing:

 (7) Interior:

 (6) Ceiling:

 (5) Floor Cover:

 (4) Floor Structure:

 (3) Frame:

Block

 

Brick/Stone

 

Poured Conc.

X

Footings

 

 (2) Foundation:

 (1) Excavation/Site Prep:

<<<<< Calculator Cost Computations >>>>>

 Class: S Quality: Excellent

Stories: 1 Story Height: 20 Perimeter: 760

 

Base Rate for Upper Floors = 173.20

 

(10) Heating system: Package Heating & Cooling Cost/SqFt: 20.00 100%

Adjusted Square Foot Cost for Upper Floors = 193.20

 

Total Floor Area: 31,200 Base Cost New of Upper Floors = 6,027,840

 

 Reproduction/Replacement Cost = 6,027,840

Eff.Age:8 Phy.%Good/Abnr.Phy./Func./Econ./Overall %Good: 82 /100/100/100/82.0

 Total Depreciated Cost = 4,942,829

 

ECF (COMM W BEECHER ST ETAL) 0.683 => TCV of Bldg: 3 = 3,375,952

 Replacement Cost/Floor Area= 193.20 Est. TCV/Floor Area= 108.20

 ** ** Calculator Cost Data ** **

Quality: Excellent

Heat#1: Package Heating & Cooling 100%

Heat#2: Electric, Cable or Baseboard 0%

Ave. SqFt/Story: 31200

Ave. Perimeter: 760

Has Elevators:

 

 *** Basement Info ***

Area:

Perimeter:

Type:

Heat:

 

 * Mezzanine Info *

Area #1:

Type #1:

Area #2:

Type #2:

 

 * Sprinkler Info *

Area: 100

Type: Excellent

Low

X

Ave.

 

Above Ave.

 

High

 

Construction Cost

Comments:

Overall Bldg

Height

 

Year Built

Remodeled

 

 

Depr. Table : 2.5%

Effective Age : 8

Physical %Good: 82

Func. %Good : 100

Economic %Good: 100

Class: S

Floor Area: 31,200

Gross Bldg Area: 104,569

Stories Above Grd: 1

Average Sty Hght : 20

Bsmnt Wall Hght 

Desc. of Bldg/Section: 

Calculator Occupancy: Greenhouses - Commercial

*** Information herein deemed reliable but not guaranteed***

Commercial/Industrial Building/Section 3 of 5

Printed on

Parcel Number:

XA0-109-1150-02

04/22/2026

Bsmnt Insul.

 

Thickness

 

 (40) Exterior Wall:

 (39) Miscellaneous:

 (14) Roof Cover:

 (13) Roof Structure: Slope=0 

Incandescent

Fluorescent

Mercury

Sodium Vapor

Transformer

 

 

 

 

 

Flex Conduit

Rigid Conduit

Armored Cable

Non-Metalic

Bus Duct

 

 

 

 

 

Few

Average

Many

Unfinished

Typical

 

 

 

 

 

Few

Average

Many

Unfinished

Typical

 

 

 

 

 

Fixtures:

Outlets:

 (11) Electric and Lighting:

Hand Fired

Boiler

 

 

Coal

Stoker

 

 

Gas

Oil

 

 

 (10) Heating and Cooling:

 (9) Sprinklers:

Urinals

Wash Bowls

Water Heaters

Wash Fountains

Water Softeners

 

 

 

 

 

Total Fixtures

3-Piece Baths

2-Piece Baths

Shower Stalls

Toilets

 

 

 

 

 

Few

None

 

 

Average

Typical

 

 

Many

Above Ave.

 

 

 (8) Plumbing:

 (7) Interior:

 (6) Ceiling:

 (5) Floor Cover:

 (4) Floor Structure:

 (3) Frame:

Block

 

Brick/Stone

 

Poured Conc.

X

Footings

 

 (2) Foundation:

 (1) Excavation/Site Prep:

<<<<< Calculator Cost Computations >>>>>

 Class: C Quality: Average

Stories: 1 Story Height: 16 Perimeter: 240

 

Base Rate for Upper Floors = 90.15

 

(10) Heating system: Forced Air Furnace Cost/SqFt: 12.04 100%

Adjusted Square Foot Cost for Upper Floors = 102.19

 

Total Floor Area: 3,600 Base Cost New of Upper Floors = 367,884

 

 Reproduction/Replacement Cost = 367,884

Eff.Age:8 Phy.%Good/Abnr.Phy./Func./Econ./Overall %Good: 82 /100/100/100/82.0

 Total Depreciated Cost = 301,665

 

ECF (COMM W BEECHER ST ETAL) 0.683 => TCV of Bldg: 4 = 206,037

 Replacement Cost/Floor Area= 102.19 Est. TCV/Floor Area= 57.23

 ** ** Calculator Cost Data ** **

Quality: Average 

Heat#1: Forced Air Furnace 100%

Heat#2: Electric, Cable or Baseboard 0%

Ave. SqFt/Story: 3600

Ave. Perimeter: 240

Has Elevators:

 

 *** Basement Info ***

Area:

Perimeter:

Type:

Heat:

 

 * Mezzanine Info *

Area #1:

Type #1:

Area #2:

Type #2:

 

 * Sprinkler Info *

Area:

Type: Average

Low

X

Ave.

 

Above Ave.

 

High

 

Construction Cost

Comments:

Overall Bldg

Height

 

Year Built

Remodeled

 

 

Depr. Table : 2.5%

Effective Age : 8

Physical %Good: 82

Func. %Good : 100

Economic %Good: 100

Class: C

Floor Area: 3,600

Gross Bldg Area: 104,569

Stories Above Grd: 1

Average Sty Hght : 16

Bsmnt Wall Hght 

Desc. of Bldg/Section: STORAGE

Calculator Occupancy: Garages - Storage

*** Information herein deemed reliable but not guaranteed***

Commercial/Industrial Building/Section 4 of 5

Printed on

Parcel Number:

XA0-109-1150-02

04/22/2026

Bsmnt Insul.

 

Thickness

 

 (40) Exterior Wall:

 (39) Miscellaneous:

 (14) Roof Cover:

 (13) Roof Structure: Slope=0 

Incandescent

Fluorescent

Mercury

Sodium Vapor

Transformer

 

 

 

 

 

Flex Conduit

Rigid Conduit

Armored Cable

Non-Metalic

Bus Duct

 

 

 

 

 

Few

Average

Many

Unfinished

Typical

 

 

 

 

 

Few

Average

Many

Unfinished

Typical

 

 

 

 

 

Fixtures:

Outlets:

 (11) Electric and Lighting:

Hand Fired

Boiler

 

 

Coal

Stoker

 

 

Gas

Oil

 

 

 (10) Heating and Cooling:

 (9) Sprinklers:

Urinals

Wash Bowls

Water Heaters

Wash Fountains

Water Softeners

 

 

 

 

 

Total Fixtures

3-Piece Baths

2-Piece Baths

Shower Stalls

Toilets

 

 

 

 

 

Few

None

 

 

Average

Typical

 

 

Many

Above Ave.

 

 

 (8) Plumbing:

 (7) Interior:

 (6) Ceiling:

 (5) Floor Cover:

 (4) Floor Structure:

 (3) Frame:

Block

 

Brick/Stone

 

Poured Conc.

X

Footings

 

 (2) Foundation:

 (1) Excavation/Site Prep:

<<<<< Calculator Cost Computations >>>>>

 Class: C Quality: Average

Stories: 1 Story Height: 16 Perimeter: 240

 

Base Rate for Upper Floors = 90.92

 

(10) Heating system: Forced Air Furnace Cost/SqFt: 12.14 100%

Adjusted Square Foot Cost for Upper Floors = 103.06

 

Total Floor Area: 3,500 Base Cost New of Upper Floors = 360,710

 

 Reproduction/Replacement Cost = 360,710

Eff.Age:8 Phy.%Good/Abnr.Phy./Func./Econ./Overall %Good: 82 /100/100/100/82.0

 Total Depreciated Cost = 295,782

 

ECF (COMM W BEECHER ST ETAL) 0.683 => TCV of Bldg: 5 = 202,019

 Replacement Cost/Floor Area= 103.06 Est. TCV/Floor Area= 57.72

 ** ** Calculator Cost Data ** **

Quality: Average 

Heat#1: Forced Air Furnace 100%

Heat#2: Electric, Cable or Baseboard 0%

Ave. SqFt/Story: 3500

Ave. Perimeter: 240

Has Elevators:

 

 *** Basement Info ***

Area:

Perimeter:

Type:

Heat:

 

 * Mezzanine Info *

Area #1:

Type #1:

Area #2:

Type #2:

 

 * Sprinkler Info *

Area:

Type: Average

Low

X

Ave.

 

Above Ave.

 

High

 

Construction Cost

Comments:

Overall Bldg

Height

 

Year Built

Remodeled

 

 

Depr. Table : 2.5%

Effective Age : 8

Physical %Good: 82

Func. %Good : 100

Economic %Good: 100

Class: C

Floor Area: 3,500

Gross Bldg Area: 104,569

Stories Above Grd: 1

Average Sty Hght : 16

Bsmnt Wall Hght 

Desc. of Bldg/Section: SECURED WASTE

Calculator Occupancy: Garages - Storage

*** Information herein deemed reliable but not guaranteed***

Commercial/Industrial Building/Section 5 of 5

Printed on

Parcel Number:

XA0-109-1150-02

04/22/2026

77449536.1 

Exhibit B

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

NAPIOR LEASING LLC, 

 

 

 

Petitioner, 

 

v 

 

CITY OF ADRIAN, 

 

 

 

Respondent. 

 

 

 

MTT Docket No. 26-000636 

 

 

_____________________________________________________________________________/ 

 

JACKIE J. COOK (P68781) 

SCOTT L. DAMICH (P74126) 

HONIGMAN LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7270 

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 

_____________________________________________________________________________/ 

 

RESPONDENT’S RESPONSES TO 

PETITIONER’S FIRST SET OF INTERROGATORIES 

AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO RESPONDENT 

 

 

Respondent, City of Adrian, by and through it counsel, Hallahan & Associates, P.C., states 

the following in response to Petitioner’s First Set of Interrogatories and Requests for Production 

of Documents: 

Interrogatories 

 

1. 

Identify each person answering and/or assisting in answering these Discovery 

Requests and identify which Discovery Requests each person answered or assisted in answering. 

ANSWER: Respondent objects to the above request to the extent it is overly broad, unduly 

burdensome, and interposed with the sole purpose to burden and harass Respondent. Subject to 

and without waiving said objections, Kristen Brown as to content; Laura M. Hallahan, Seth A. 

O’Loughlin, and Kelsea M. Melcher as to form and objections. 

 

2. Identify each appraiser, consultant, expert, professional, advisor, and/or other individual 

you consulted with deriving or calculating the assessed value(s) and/or taxable value(s) placed on 

the City’s tax roll for tax year 2026 and summarize the related contribution(s) made by each person 

identified.

2

ANSWER: Respondent objects to the above request to the extent it is overly broad, unduly 

burdensome, irrelevant, and interposed with the sole purpose to burden and harass Respondent. As 

the Tribunal maintains de novo review, Respondent’s 2026 assessment of the subject property is 

of little relevance to Petitioner’s valuation claims. Subject to and without waiving said objections, 

the subject property’s 2026 tax roll values were established by Kristen Brown prior to confirmation 

of said values by the March Board of Review. 

 

3. Identify each person answering and/or assisting in answering these Discovery Requests 

and identify which Discovery Requests each person answered or assisted in answering. 

ANSWER: Respondent objects to the above request as duplicative and as interposed with 

the sole purpose to burden and harass Respondent. Subject to and without waiving said objections, 

Respondent restates its response and objections to Interrogatory No. 1 herein. 

 

4. Explain in detail how you took into consideration the sale of the subject property in 2025 

when determining the subject property’s true cash value as of December 31, 2025. 

ANSWER: Respondent objects to the above request to the extent it is overly broad, unduly 

burdensome, irrelevant, and interposed with the sole purpose to burden and harass Respondent. As 

the Tribunal maintains de novo review, Respondent’s 2026 assessment of the subject property is 

of little relevance to Petitioner’s valuation claims. Subject to and without waiving said objections, 

please see the attached assessment records for the factors taken into consideration in Respondent’s 

determination of the subject property’s true cash value for the 2026 tax year. 

 

5. If you did not take the sale of the subject property in 2025 into consideration when 

determining the subject property’s true cash value as of December 31, 2025, why not? 

ANSWER: Respondent restates its response and objections to Interrogatory No. 4 herein. 

 

6. For each Request for Admission that you deny, partially deny, qualify, or are unable to 

admit in full, please state in detail: 

A. Every fact upon which your denial, partial denial, qualification, or failure to 

admit is based; 

B. The identity of all people with knowledge of those facts: 

C. The identity of all documents, information, communications, and other materials 

that support your response; and 

D. The specific portion of the Request for Admission that you content is inaccurate, 

incomplete, or otherwise incapable of admission. 

ANSWER: Respondent objects to the above request, including subparts (A)-(D), as vague, 

overly broad, unduly burdensome, and as interposed with the sole purpose to burden and harass 

Respondent. Further objections are raised to the extent Petitioner’s request exceeds the scope of 

pre-valuation discovery. Respondent also objects to the extent Petitioner seeks to use the above 

interrogatory as a method to circumvent the limitation placed on interrogatory requests under MCR 

2.309(A)(2). Subject to and without waiving said objections, please see Respondent’s Responses 

to Petitioner’s Request for Admission.

3

Request for Production of Documents 

 

1. Produce any correspondence regarding deriving, analyzing, or calculating the assessed 

value(s) and/or taxable value(s) placed on the City’s tax roll for tax year 2026. 

ANSWER: Respondent objects to the above request as overly broad, unduly burdensome, 

irrelevant, and as interposed with the sole purpose to burden and harass Respondent. As the 

Tribunal maintains de novo review, Respondent’s 2026 assessment is of little relevance to 

Petitioner’s valuation claims. Further objections are raised to the extent Petitioner seeks 

information and documentation protected via attorney client privilege. Objections are also raised 

to the extent Petitioner’s request exceeds the scope of pre-valuation discovery as set forth in the 

Prehearing General Call. Subject to and without waiving said objections, please see the 2026 

Notice of Assessment previously mailed to Petitioner as well as the attached record cards. 

 

2. Produce the complete assessment record cards and valuation reports for tax year 2026, 

including but not limited to, supplemental pages for “calculations too long” to be displayed on the 

record cards and/or valuation reports; “valuation printouts” with “complete pricing” information; 

pictures of the subject property; parcel maps or site maps of the subject property; and any other 

documents that support the information or calculations in the assessment record cards and 

valuation reports. 

ANSWER: Respondent objects to the above request as overly broad, unduly burdensome, 

irrelevant, and as interposed with the sole purpose to burden and harass Respondent. As the 

Tribunal maintains de novo review, Respondent’s 2026 assessment is of little relevance to 

Petitioner’s valuation claims. Subject to and without waiving said objections, please see the 

attached record cards. 

 

3. Produce all documents containing any and all calculations and/or analysis related to, 

used in, or supporting any documents produced in response to Interrogatory 2 above. 

ANSWER: Respondent restates its response and objections to Request to Produce No. 2 

herein. 

 

4. Produce, in electronic form, a complete copy of the entire work file and/or assessment 

file for the subject property maintained by you for tax year 2026, including but not limited to, 

appraisals, valuations based on a cost approach, valuations based on an income approach, and/or 

valuations based on a sales comparison approach. 

ANSWER: Respondent objects to the above request as overly broad, unduly burdensome, 

vague, irrelevant, and as interposed with the sole purpose to burden and harass Respondent. As the 

Tribunal maintains de novo review, Respondent’s 2026 assessment is of little relevance to 

Petitioner’s valuation claims. Further objections are raised to the extent Petitioner’s request 

exceeds the scope of pre-valuation discovery as set forth in the Prehearing General Call. Subject 

to and without waiving said objections, please see the attached record cards. 

 

5. Produce all documents related to other properties’ sales history, appraisals, Tax Tribunal 

matters, and/or valuations based on a cost approach, income approach, and/or sales comparison 

approach that you reviewed and considered in deriving, analyzing, and/or calculating the assessed 

value(s) and/or taxable value(s) placed on the City’s tax roll for tax year 2026.

4

ANSWER: Respondent restates its response and objections to Request to Produce No. 4 

herein. 

 

6. Produce copies of all documents regarding the sale of the subject property in 2025. 

ANSWER: Respondent objects to the above request to the extent it is vague, overly broad, 

unduly burdensome, irrelevant, and interposed with the sole purpose to burden and harass 

Respondent. Further objections are set forth to the extent Petitioner seeks documentation outside 

of Respondent’s custody and control. Objections are also raised to the extent the requested 

documentation is already in Petitioner’s possession. 

 

7. Produce copies of all documents supporting or related to your Answers to Interrogatory 

Nos. 4, 5, and 6. 

ANSWER: Please see Respondent’s responses and objections to Interrogatory Nos. 4 and 

6. 

 

8. Produce copies of all documents supporting your conclusions and/or research regarding 

the assessed value of the subject property reflected on the tax roll for tax year 2026. 

ANSWER: Respondent objects to the above request to as overly broad, unduly 

burdensome, vague, irrelevant, and interposed with the sole purpose to burden and harass 

Respondent. As the Tribunal maintains de novo review, Respondent’s 2026 assessment is of little 

relevance to Petitioner’s valuation claims. Further objections are raised to the extent Petitioner’s 

request exceeds the scope of pre-valuation discovery as set forth in the Prehearing General Call. 

Subject to and without waiving said objections, please see the attached record cards. 

 

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 15, 2026 

(248) 731-3089

5

PROOF OF MAILING 

 

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

Petitioner’s First Set of Interrogatories and Requests for Production of Documents to Respondent 

City of Adrian to: 

 

Jackie J. Cook 

Honigman LLP 

jcook@honigman.com 

 

Scott L. Damich 

Honigman LLP 

sdamich@honigman.com 

 

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

 

 

/s/Kelsea M. Melcher_______________ 

Dated: September 15, 2026 

Kelsea M. Melcher

77449536.1 

Exhibit C

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

NAPIOR LEASING LLC, 

 

 

 

Petitioner, 

 

v 

 

CITY OF ADRIAN, 

 

 

 

Respondent. 

 

 

 

MTT Docket No. 26-000636 

 

 

_____________________________________________________________________________/ 

 

JACKIE J. COOK (P68781) 

SCOTT L. DAMICH (P74126) 

HONIGMAN LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7270 

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 

_____________________________________________________________________________/ 

 

RESPONDENT’S RESPONSES TO 

PETITIONER’S REQUESTS FOR ADMISSION 

 

 

Respondent, City of Adrian, by and through it counsel, Hallahan & Associates, P.C., states 

the following in response to Petitioner’s Requests for Admission: 

 

1. Admit that Green Life Business Group, Inc. has an established relationship with cannabis 

operators worldwide. 

ANSWER: Respondent objects to the above request as vague, irrelevant, and as interposed 

with sole purpose to burden and harass Respondent. To begin, it is unclear what Petitioner 

classifies as an “established relationship” and said phrase is not defined in the definition section 

of Petitioner’s Request for Admission. Moreover, said request is entirely irrelevant as it pertains 

to an entity that is not a party to this appeal. There is no apparent relevancy to the above request 

and the claims identified in Petitioner’s Petition. 

 

2. Admit that Green Life Business Group, Inc. is recognized as a premier authority in 

cannabis mergers and acquisitions. 

ANSWER: Respondent objects to the above request as vague, irrelevant, and as interposed 

with sole purpose to burden and harass Respondent. To begin, it is unclear what Petitioner deems 

a “premier authority” and said phrase is not defined in the definition section of Petitioner’s Request 

for Admission. Moreover, said request is entirely irrelevant as it pertains to an entity that is not a

2

party to this appeal. There is no apparent relevancy to the above request and the claims identified 

in Petitioner’s Petition. 

 

3. Admit that Green Life Business Group, Inc. has closed over 300 cannabis transactions 

nationwide. 

ANSWER: Respondent objects to the above request as vague, irrelevant, and as interposed 

with sole purpose to burden and harass Respondent. To begin, it is unclear what Petitioner means 

when it refers to “cannabis transactions” and said phrase is not defined in the definition section of 

Petitioner’s Request for Admission. Moreover, said request is entirely irrelevant as it pertains to 

an entity that is not a party to this appeal. There is no apparent relevancy to the above request and 

the claims identified in Petitioner’s Petition. 

 

4. Admit that Green Life Business Group, Inc. listed the subject property for sale on its 

national platform on March 28, 2025. 

ANSWER: Respondent objects to the above request as vague, irrelevant, and as interposed 

with sole purpose to burden and harass Respondent. To begin, it is unclear what “national 

platform” Petitioner is referring as said platform is not defined in the definition section of 

Petitioner’s Request for Admission. Moreover, said request is entirely irrelevant as it pertains to 

an entity that is not a party to this appeal. 

 

5. Admit that Green Life Business Group, Inc. initiated a nationwide email blast campaign 

targeting cannabis operators and investors. 

ANSWER: Respondent objects to the above request as vague, irrelevant, and as interposed 

with sole purpose to burden and harass Respondent. To begin, it is unclear what Petitioner deems 

to be a “nationwide email blast campaign” and said phrase is not defined in the definition section 

of Petitioner’s Request for Admission. Moreover, said request is entirely irrelevant as it pertains 

to an entity that is not a party to this appeal. There is no apparent relevancy to the above request 

and the claims identified in Petitioner’s Petition. 

 

6. Admit that calls for offers for the subject property were due May 16, 2025. 

ANSWER: Respondent objects to the above request as vague, irrelevant, and as interposed 

with sole purpose to burden and harass Respondent. To begin, it is unclear what Petitioner means 

by “calls for offers” and said phrase is not defined in the definition section of Petitioner’s Request 

for Admission. Moreover, said request is entirely irrelevant as it seeks an admission regarding a 

time months prior to the applicable date of value—December 31, 2025. There is no apparent 

relevancy to the above request and the claims identified in Petitioner’s Petition. 

 

7. Admit that at least three offers were made for the purchase of the subject property. 

ANSWER: Respondent objects to the above request as vague, irrelevant, and as interposed 

with sole purpose to burden and harass Respondent. Further objections are raised to the above 

request to the extent it seeks an admission regarding occurrences of which Respondent lacks 

knowledge and which a reasonable inquiry could not provide Respondent with knowledge 

sufficient to respond to said request. Subject to and without waiving said objections, Respondent 

leaves Petitioner to its proofs regarding the number of offers received to purchase the subject 

property.

3

8. Admit that Buyer signed the purchase agreement for the subject property on May 31, 

2025. 

ANSWER: Upon information and belief, Respondent admits Request No. 8. 

 

9. Admit that Buyer purchased the subject property from Seller for $3,837,537 

ANSWER: Upon information and belief, Respondent admits Request No. 9. 

 

10. Admit that Buyer purchased the subject property and the personal property located at 

the subject property from Seller for $6,000,000. 

ANSWER: Respondent objects to the above request as vague, irrelevant, and as interposed 

with the sole purpose to burden and harass Respondent as no personal property was identified to 

be at issue in Petitioner’s Petition. Subject to and without waiving said objections, Respondent 

admits the allegations in Paragraph 10. 

 

11. Admit that the Buyer purchased the subject property for less than the listing price. 

ANSWER: Respondent objects to the above request as vague, irrelevant, and as interposed 

with the sole purpose to burden and harass Respondent. Further objections are raised to the above 

request to the extent it seeks an admission regarding matters which Respondent lacks knowledge 

and which a reasonable inquiry could not provide Respondent with knowledge sufficient to 

respond to said request. Subject to and without waiving said objections, Respondent neither admits 

nor denies said request and leaves Petitioner to its proofs. 

 

12. Admit that the sale of the subject property was not a private sale. 

ANSWER: Respondent objects to the above request as vague, irrelevant, and as interposed 

with the sole purpose to burden and harass Respondent. To begin, it is unclear what Petitioner 

defines as a “private sale” and said phrase is not defined in the definition section of Petitioner’s 

Request for Admission. Further objections are raised to the above request to the extent it seeks an 

admission regarding matters which Respondent lacks knowledge and which a reasonable inquiry 

could not provide Respondent with knowledge sufficient to respond to said request. Subject to and 

without waiving said objections, Respondent neither admits nor denies said request and leaves 

Petitioner to its proofs. 

 

13. Admit that the sale of the subject property was not conducted by public auction. 

ANSWER: Respondent objects to the above request as vague, irrelevant, and as interposed 

with the sole purpose to burden and harass Respondent. To begin, it is unclear what Petitioner 

means by a “conducted by public auction” and said phrase is not defined in the definition section 

of Petitioner’s Request for Admission. Upon information and belief as well as subject to and 

without waiving said objections, admitted. 

 

14. Admit that the sale of the subject property was not a foreclosure sale. 

ANSWER: Respondent objects to the above request as vague, irrelevant, and as interposed 

with the sole purpose to burden and harass Respondent. To begin, it is unclear what Petitioner 

means by a “foreclosure sale” and said phrase is not defined in the definition section of Petitioner’s 

Request for Admission. Upon information and belief as well as subject to and without waiving 

said objections, admitted.

4

15. Admit that the sale of the subject property was not a sheriff’s sale. 

ANSWER: Respondent objects to the above request as vague, irrelevant, and as interposed 

with the sole purpose to burden and harass Respondent. To begin, it is unclear what Petitioner 

means by a “sheriff sale” and said phrase is not defined in the definition section of Petitioner’s 

Request for Admission. Upon information and belief as well as subject to and without waiving 

said objections, admitted. 

 

16. Admit that the sale of the subject property was not a tax foreclosure sale. 

ANSWER: Respondent objects to the above request as vague, irrelevant, and as interposed 

with the sole purpose to burden and harass Respondent. To begin, it is unclear what Petitioner 

means by a “tax foreclosure sale” and said phrase is not defined in the definition section of 

Petitioner’s Request for Admission. Upon information and belief as well as subject to and without 

waiving said objections, admitted. 

 

17. Admit that sale of the subject property was not a bankruptcy sale. 

ANSWER: Respondent objects to the above request as vague, irrelevant, and as interposed 

with the sole purpose to burden and harass Respondent. To begin, it is unclear what Petitioner 

means by a “bankruptcy sale” and said phrase is not defined in the definition section of Petitioner’s 

Request for Admission. Upon information and belief as well as subject to and without waiving 

said objections, admitted. 

 

18. Admit that the sale of the subject property was not a liquidation sale. 

ANSWER: Respondent objects to the above request as vague, irrelevant, and as interposed 

with the sole purpose to burden and harass Respondent. To begin, it is unclear what Petitioner 

means by a “liquidation sale” and said phrase is not defined in the definition section of Petitioner’s 

Request for Admission. Upon information and belief as well as subject to and without waiving 

said objections, admitted. 

 

19. Admit that the sale of the subject property was not a forced sale. 

ANSWER: Respondent objects to the above request as vague, irrelevant, and as interposed 

with the sole purpose to burden and harass Respondent. To begin, it is unclear what Petitioner 

defines as a “forced sale” and said phrase is not defined in the definition section of Petitioner’s 

Request for Admission. Further objections are raised to the above request to the extent it seeks an 

admission regarding matters which Respondent lacks knowledge and which a reasonable inquiry 

could not provide Respondent with knowledge sufficient to respond to said request. Subject to and 

without waiving said objections, Respondent neither admits nor denies said request and leaves 

Petitioner to its proofs. 

 

20. Admit that neither the Buyer nor the Seller was compelled by court order to 

consummate the sale. 

ANSWER: Respondent objects to the above request as vague, irrelevant, and as interposed 

with the sole purpose to burden and harass Respondent. Further objections are raised to the above 

request to the extent it seeks an admission regarding matters which Respondent lacks knowledge 

and which a reasonable inquiry could not provide Respondent with knowledge sufficient to 

respond to said request. Subject to and without waiving said objections, Respondent neither admits 

nor denies said request and leaves Petitioner to its proofs.

5

 

21. Admit that the Seller voluntarily offered the subject property for sale. 

ANSWER: Respondent objects to the above request as vague, irrelevant, and as interposed 

with the sole purpose to burden and harass Respondent. Further objections are raised to the above 

request to the extent it seeks an admission regarding matters which Respondent lacks knowledge 

and which a reasonable inquiry could not provide Respondent with knowledge sufficient to 

respond to said request. Subject to and without waiving said objections, Respondent neither admits 

nor denies said request and leaves Petitioner to its proofs. 

 

22. Admit that the Seller voluntarily entered into the purchase agreement. 

ANSWER: Respondent objects to the above request as vague, irrelevant, and as interposed 

with the sole purpose to burden and harass Respondent. Further objections are raised to the above 

request to the extent it seeks an admission regarding matters which Respondent lacks knowledge 

and which a reasonable inquiry could not provide Respondent with knowledge sufficient to 

respond to said request. Subject to and without waiving said objections, Respondent neither admits 

nor denies said request and leaves Petitioner to its proofs. 

 

23. Admit that the Buyer and the Seller in the subjection transaction were separate business 

entities. 

ANSWER: Respondent objects to the above request as vague, irrelevant, outside the scope 

of this appeal, and interposed with the sole purpose to burden and harass Respondent. Further 

objections are raised to the above request to the extent it seeks an admission regarding matters 

which Respondent lacks knowledge and which a reasonable inquiry could not provide Respondent 

with knowledge sufficient to respond to said request. Upon information and belief as well as 

subject to and without waiving said objections, Respondent admits the above request. Respondent 

reserves the right to supplement and/or revise this response should additional information become 

available or known. 

 

24. Admit that the Buyer and the Seller were not related entities at the time of the subject 

transaction. 

ANSWER: Respondent restates its response and objections to Request No. 23 herein. 

 

25. Admit that neither the Buyer nor the Seller owned any ownership interest in the other 

at the time of the subject transaction. 

ANSWER: Respondent restates its response and objections to Request No. 23 herein. 

 

26. Admit that the Buyer and the Seller were not under common ownership at the time of 

the subject transaction. 

ANSWER: Respondent restates its response and objections to Request No. 23 herein. 

 

27. Admit that the Buyer and the Seller were not parent, subsidiary, affiliate, or sister 

companies. 

ANSWER: Respondent restates its response and objections to Request No. 23 herein. 

 

28. Admit that no individual or entity held a controlling ownership interest in both the 

Buyer and the Seller at the time of the subject transaction.

6

ANSWER: Respondent objects to the above request as vague, irrelevant, outside the scope 

of this appeal, and interposed with the sole purpose to burden and harass Respondent. Further 

objections are raised to the above request to the extent it seeks an admission regarding matters 

which Respondent lacks knowledge and which a reasonable inquiry could not provide Respondent 

with knowledge sufficient to respond to said request. 

 

29. Admit that no officer, director, manager, member, partner, or shareholder of the Buyer 

held a controlling ownership interest in the Buyer. 

ANSWER: Respondent restates its response and objection to Request No. 28 herein. 

 

30. Admit that the Buyer and Seller dealt with each other as independent parties acting in 

their own economic self-interests. 

ANSWER: Respondent restates its response and objection to Request No. 28 herein. 

 

31. Admit that the purchase price was not influenced by any familial, ownership, affiliate, 

or other special relationship between the Buyer and Seller. 

ANSWER: Respondent restates its response and objection to Request No. 28 herein. 

 

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 15, 2026 

(248) 731-3089 

 

 

 

PROOF OF MAILING 

 

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

Petitioners’ Requests to Admit to: 

 

Jackie J. Cook 

Honigman LLP 

jcook@honigman.com 

 

Scott L. Damich 

Honigman LLP 

sdamich@honigman.com 

 

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

 

 

/s/Seth A. O’Loughlin_______________ 

Dated: September 15, 2026 

Seth A. O’Loughlin

77449536.1 

Exhibit D

COMEB & COMWB Combined ECF Study

Parcel Number

Street Address

Sale Date

Sale Price

Instr.

Terms of Sale

Adj. Sale $

Asd. when Sold

Asd/Adj. Sale

Cur. Appraisal

Land + Yard

Bldg. Residual

Cost Man. $

E.C.F.

Floor Area

$/Sq.Ft.

ECF Area

Land Value

Land Table

Property Class

XA0-515-0187-00

221 S CENTER ST

08/08/22

$50,000 LC

03-ARM'S LENGTH

$50,000

$16,700

33.40

$52,096

$33,690

$16,310

$26,034

0.626

847

$19.26

COMEB

$26,286 COMM 100K 1ST ACRE

201

XA0-820-2013-01

825 E BEECHER ST

08/03/22

$202,000 WD

03-ARM'S LENGTH

$202,000

$80,200

39.70

$184,583

$43,437

$158,563

$199,641

0.794

5,509

$28.78

COMEB

$37,407 COMM 100K 1ST ACRE

201

XA0-230-1004-03

321 S DEAN ST

10/26/23

$45,000 WD

03-ARM'S LENGTH

$45,000

$22,700

50.44

$43,544

$18,602

$26,398

$35,279

0.748

1,841

$14.34

COMEB

$18,602 COMM 100K 1ST ACRE

201

XA0-515-0014-00

125 N TECUMSEH ST

01/31/22

$262,500 WD

03-ARM'S LENGTH

$232,500

$124,700

53.63

$269,262

$46,959

$185,541

$329,338

0.563

12,149

$15.27

COMEB

$36,234 COMM 100K 1ST ACRE

201

Totals:

$559,500

$529,500

$244,300

$549,485

$386,812

$590,291

$19.41

Sale. Ratio =>

46.14

E.C.F. =>

0.655

Std. Dev. =>

9.40

Ave. E.C.F. =>

0.683

77449536.1 

Exhibit E

2026 Land Study

Parcel Number

Street Address

Sale Date

Sale Price

Instr.

Terms of Sale

Adj. Sale $

Asd. when Sold

Asd/Adj. Sale

Cur. Appraisal

Land Residual

Est. Land Value

Net Acres

Total Acres

Dollars/SqFt

ECF Area

Land Table

Class

XA0-104-3680-00

2000 W BEECHER ST BLK

09/08/23

$168,000 WD

03-ARM'S LENGTH

$168,000

$56,300

33.51

$107,495

$124,523

$64,018

1.61

1.61

$1.78

COMWB COMM 100K 1ST ACRE

201

XA0-000-0063-01

147 E CHURCH ST

11/30/23

$40,000 WD

03-ARM'S LENGTH

$40,000

$15,700

39.25

$27,869

$40,000

$20,220

0.20

0.20

$4.59

010 COMM 100K 1ST ACRE

202

XA0-230-1004-03

321 S DEAN ST

10/26/23

$45,000 WD

03-ARM'S LENGTH

$45,000

$22,700

50.44

$43,748

$19,854

$18,602

0.18

0.18

$2.48

COMEB COMM 100K 1ST ACRE

201

XA0-515-0164-01

205 S LOCUST ST

05/16/24

$300,000 LC

03-ARM'S LENGTH

$213,611

$113,000

52.90

$201,411

$30,398

$18,198

0.18

0.18

$3.88

COMHS COMM 100K 1ST ACRE

201

XA0-133-3300-00

1149 SAND CREEK HWY

09/05/24

$180,000 WD

03-ARM'S LENGTH

$180,000

$96,600

53.67

$178,831

$100,247

$99,078

0.98

0.98

$2.35

COMWM COMM 100K 1ST ACRE

201

XA0-260-0010-00

600 E BEECHER ST

12/19/24

$240,000 WD

03-ARM'S LENGTH

$240,000

$131,200

54.67

$249,557

$106,039

$115,596

1.32

1.32

$1.85

COMEB COMM 100K 1ST ACRE

201

XA0-250-4020-00

726 N MAIN ST

02/28/25

$125,000 WD

03-ARM'S LENGTH

$125,000

$71,400

57.12

$131,993

$39,008

$46,001

0.46

0.46

$1.97

COMDT COMM 100K 1ST ACRE

201

XA0-280-0003-00

737 W BEECHER ST

11/22/24

$120,000 QC

03-ARM'S LENGTH

$120,000

$70,200

58.50

$129,185

$120,000

$129,185

1.64

1.64

$1.68

COMWB COMM 100K 1ST ACRE

202

Totals:

$1,218,000

$1,131,611

$577,100

$1,070,089

$580,069

$510,898

6.57

6.57

Sale. Ratio =>

51.00

Average

Std. Dev. =>

8.90

per Net Acre=>

88,317.45

88,300.00

77449536.1 

Exhibit F

*** Information herein deemed reliable but not guaranteed***

LENAWEE

County:

CITY OF ADRIAN

Jurisdiction:

Printed on

Parcel Number:

XA0-109-1150-02

6,176,100S

6,176,100

6,043,900

132,200

2022

6,219,900S

6,219,900X

6,219,900M

6,219,900

6,064,700

155,200

2023

5,977,900S

5,977,900M

5,977,900

5,692,500

285,400

2024

5,641,400S

5,641,400M

5,641,400

5,378,600

262,800

2025

Taxable

Value

Tribunal/

Other

Board of

Review

Assessed

Value

Building

Value

Land

Value

Year

Land Improvement Cost Estimates

Description Rate Size % Good Cash Value

D/W/P: Asphalt Paving 2.94 123256 80 289,898

Fencing: Wire Mesh, #11 3.45 10000 80 27,600

Fencing: Wire Mesh, #11 3.45 9074 80 25,044

 Total Estimated Land Improvements True Cash Value = 342,542

 * Factors *

Description Frontage Depth Front Depth Rate %Adj. Reason Value

100K 1ST ACRE 27.076 Acres 19,410 100 525,533

 27.08 Total Acres Total Est. Land Value = 525,533

Land Value Estimates for Land Table C100K.COMM 100K 1ST ACRE

KIR 01/21/2020 AssessApp 

Who When What

Level

Rolling

Low

High

Landscaped

Swamp

Wooded

Pond

Waterfront

Ravine

Wetland

Flood Plain

 

 

 

 

 

 

 

 

 

 

 

 

 

Topography of 

Site

Dirt Road

Gravel Road

Paved Road

Storm Sewer

Sidewalk

Water

Sewer

Electric

Gas

Curb

Street Lights

Standard Utilities

Underground Utils.

 

 

 

 

 

 

 

 

 

 

 

 

 

Public

Improvements

Vacant

 

Improved

X

The Equalizer. Copyright (c) 1999 - 2009.

Licensed To: City of Adrian, County of

Lenawee, Michigan

Split/Comb. on 06/04/2018 completed

06/04/2018 KWETZEL ;

Parent Parcel(s): XA0-109-1150-01;

Child Parcel(s): XA0-109-1150-02,

XA0-109-1150-03;

-----------------------------------------

Comments/Influences

BEING ALL THAT PART OF THE NORTHWEST 1/4

OF SECTION 9, TOWN 7 SOUTH, RANGE 3 EAST,

AND FURTHER DESCRIBED AS FOLLOWS;

COMMENCING AT THE NORTH 1/4 CORNER OF

SAID SECTION 9, TOWN 7 SOUTH, RANGE 3

EAST BEING A FOUND 5/8” IRON ROD WITH CAP

# 13040 IN MONUMENT BOX, ALSO BEING ON

THE CENTERLINE RIGHT OF WAY OF BEECHER

ROAD (AKA M-34) HAVING A ROW WIDTH OF

100.00 FEET;THENCE NORTH 89° 40' 39” WEST

A DISTANCE OF 1110.08 FEET ALONG SAID

NORTH LINE OF SECTION 9 AND SAID

CENTERLINE RIGHT OF WAY OF BEECHER ROAD

TO A POINT. SAID POINT BEING THE TRUE

POINT OF BEGINNING. THENCE SOUTH 00° 39'

42” WEST A DISTANCE OF 350 FEET TO A

FOUND IRON ROD WITH CAP # 51478, PASSING

THROUGH A FOUND IRON ROD WITH CAP # 51478

AT 50.00 FEET SET ON THE SOUTHERLY RIGHT

OF WAY LINE OF SAID BEECHER ROAD; THENCE

SOUTH 89° 40' 39” EAST AND PARALLEL WITH

***BALANCE OF DESCRIPTION ON FILE***

Tax Description

FLURESH, LLC

1213 PHILLIPS AVE SW

GRAND RAPIDS MI 49507-1516

Owner's Name/Address

1751 W BEECHER ST

Property Address

PM19-229

12/11/2019

Mechanical New Com

2025 Est TCV 11,282,827 TCV/TFA: 107.9

PM19-241

12/27/2019

Mechanical New Com

MAP #: 

PP19-124

12/27/2019

Plumbing New Com

P.R.E. 0% Qual. Ag.

PB20-024

02/11/2020

B- Com Add/Alter/Repair

School: ADRIAN CITY SCHOOL DISTRICT

Status

Number

Date

Building Permit(s)

Zoning: I-2

Class: COMMERCIAL-IMPROVE

0.0

DEED

2566:0436

21-NOT USED/OTHER

OTH

06/11/2018

0

THE CITY OF ADRIAN

FLURESH, LLC

100.0

DEED

2564:0957

03-ARM'S LENGTH

WD

06/13/2018

250,000

FLURESH, LLC 

CITY OF ADRIAN

0.0

DEED

2637:0072

21-NOT USED/OTHER

OTH

03/23/2022

0

TRC - DEVCO LLC

FLURESH, LLC

0.0

DEED

2637:0071

21-NOT USED/OTHER

WD

03/23/2022

0

FLURESH, LLC

TRC-DEVCO LLC

Prcnt.

Trans.

Verified

By

Liber

& Page

Terms of Sale

Inst.

Type

Sale

Date

Sale

Price

Grantee

Grantor

07/28/2025

Bsmnt Insul.

 

Thickness

 

 (40) Exterior Wall:

 (39) Miscellaneous:

 (14) Roof Cover:

 (13) Roof Structure: Slope=0 

Incandescent

Fluorescent

Mercury

Sodium Vapor

Transformer

 

 

 

 

 

Flex Conduit

Rigid Conduit

Armored Cable

Non-Metalic

Bus Duct

 

 

 

 

 

Few

Average

Many

Unfinished

Typical

 

 

 

 

 

Few

Average

Many

Unfinished

Typical

 

 

 

 

 

Fixtures:

Outlets:

 (11) Electric and Lighting:

Hand Fired

Boiler

 

 

Coal

Stoker

 

 

Gas

Oil

 

 

 (10) Heating and Cooling:

 (9) Sprinklers:

Urinals

Wash Bowls

Water Heaters

Wash Fountains

Water Softeners

 

 

 

 

 

Total Fixtures

3-Piece Baths

2-Piece Baths

Shower Stalls

Toilets

 

 

 

 

 

Few

None

 

 

Average

Typical

 

 

Many

Above Ave.

 

 

 (8) Plumbing:

 (7) Interior:

 (6) Ceiling:

 (5) Floor Cover:

 (4) Floor Structure:

 (3) Frame:

Block

 

Brick/Stone

 

Poured Conc.

X

Footings

 

 (2) Foundation:

 (1) Excavation/Site Prep:

<<<<< Calculator Cost Computations >>>>>

 Class: S Quality: Good

Stories: 1 Story Height: 20 Perimeter: 604

 

Base Rate for Upper Floors = 96.66

 

(10) Heating system: Complete H.V.A.C. Cost/SqFt: 49.05 100%

Adjusted Square Foot Cost for Upper Floors = 145.71

 

Total Floor Area: 19,469 Base Cost New of Upper Floors = 2,836,828

 

 Reproduction/Replacement Cost = 2,836,828

Eff.Age:7 Phy.%Good/Abnr.Phy./Func./Econ./Overall %Good: 84 /100/100/100/84.0

 Total Depreciated Cost = 2,382,936

 

Unit in Place Items Rate Quantity Arch %Good Depr.Cost

 /CI11/WELSW/50000 220000.00 1 1.00 64 140,800

 /CI11/VERBS/F10000 26986.67 1 1.00 64 17,271

 

ECF (COMM W BEECHER ST ETAL) 0.683 => TCV of Bldg: 1 = 1,735,507

 Replacement Cost/Floor Area= 158.40 Est. TCV/Floor Area= 89.14

 ** ** Calculator Cost Data ** **

Quality: Good 

Heat#1: Complete H.V.A.C. 100%

Heat#2: Electric, Cable or Baseboard 0%

Ave. SqFt/Story: 19469

Ave. Perimeter: 604

Has Elevators:

 

 *** Basement Info ***

Area:

Perimeter:

Type:

Heat:

 

 * Mezzanine Info *

Area #1:

Type #1:

Area #2:

Type #2:

 

 * Sprinkler Info *

Area:

Type:

Low

X

Ave.

 

Above Ave.

 

High

 

Construction Cost

Comments:

Overall Bldg

Height

 

Year Built

Remodeled

 

 

Depr. Table : 2.5%

Effective Age : 7

Physical %Good: 84

Func. %Good : 100

Economic %Good: 100

Class: S

Floor Area: 19,469

Gross Bldg Area: 104,569

Stories Above Grd: 1

Average Sty Hght : 20

Bsmnt Wall Hght 

Desc. of Bldg/Section: 

Calculator Occupancy: Industrial - Light Manufacturing

*** Information herein deemed reliable but not guaranteed***

Commercial/Industrial Building/Section 1 of 5

Printed on

Parcel Number:

XA0-109-1150-02

07/28/2025

*** Information herein deemed reliable but not guaranteed***

Parcel Number: XA0-109-1150-02, Commercial/Industrial Building 1

Printed on

07/28/2025

Parcel Number: 

XA0-109-1150-02, 

Commercial/Industrial Building 

1 

Printed on 

07/28/2025 

Storage Building | 3 

3600.0sf 

| © 

3 

15 

| 

19465.3 

Ses 

= 

Greenhouse 

31200.0 sf 

260° 

5 

Greenhouse 

so 

& 

46800.0 sf 

Secured waste | 2 

35000%F 

‘Sketch by Apex Sketch 

*** 

Information herein deemed reliable 

but 

not guaranteed***

Bsmnt Insul.

 

Thickness

 

 (40) Exterior Wall:

 (39) Miscellaneous:

 (14) Roof Cover:

 (13) Roof Structure: Slope=0 

Incandescent

Fluorescent

Mercury

Sodium Vapor

Transformer

 

 

 

 

 

Flex Conduit

Rigid Conduit

Armored Cable

Non-Metalic

Bus Duct

 

 

 

 

 

Few

Average

Many

Unfinished

Typical

 

 

 

 

 

Few

Average

Many

Unfinished

Typical

 

 

 

 

 

Fixtures:

Outlets:

 (11) Electric and Lighting:

Hand Fired

Boiler

 

 

Coal

Stoker

 

 

Gas

Oil

 

 

 (10) Heating and Cooling:

 (9) Sprinklers:

Urinals

Wash Bowls

Water Heaters

Wash Fountains

Water Softeners

 

 

 

 

 

Total Fixtures

3-Piece Baths

2-Piece Baths

Shower Stalls

Toilets

 

 

 

 

 

Few

None

 

 

Average

Typical

 

 

Many

Above Ave.

 

 

 (8) Plumbing:

 (7) Interior:

 (6) Ceiling:

 (5) Floor Cover:

 (4) Floor Structure:

 (3) Frame:

Block

 

Brick/Stone

 

Poured Conc.

X

Footings

 

 (2) Foundation:

 (1) Excavation/Site Prep:

<<<<< Calculator Cost Computations >>>>>

 Class: S Quality: Excellent

Stories: 1 Story Height: 20 Perimeter: 880

 

Base Rate for Upper Floors = 163.71

 

(10) Heating system: Package Heating & Cooling Cost/SqFt: 18.72 100%

Adjusted Square Foot Cost for Upper Floors = 182.43

 

Total Floor Area: 46,800 Base Cost New of Upper Floors = 8,537,724

 

 Reproduction/Replacement Cost = 8,537,724

Eff.Age:7 Phy.%Good/Abnr.Phy./Func./Econ./Overall %Good: 84 /100/100/100/84.0

 Total Depreciated Cost = 7,171,688

 

ECF (COMM W BEECHER ST ETAL) 0.683 => TCV of Bldg: 2 = 4,898,263

 Replacement Cost/Floor Area= 182.43 Est. TCV/Floor Area= 104.66

 ** ** Calculator Cost Data ** **

Quality: Excellent

Heat#1: Package Heating & Cooling 100%

Heat#2: Electric, Cable or Baseboard 0%

Ave. SqFt/Story: 46800

Ave. Perimeter: 880

Has Elevators:

 

 *** Basement Info ***

Area:

Perimeter:

Type:

Heat:

 

 * Mezzanine Info *

Area #1:

Type #1:

Area #2:

Type #2:

 

 * Sprinkler Info *

Area: 100

Type: Excellent

Low

X

Ave.

 

Above Ave.

 

High

 

Construction Cost

Comments:

Overall Bldg

Height

 

Year Built

Remodeled

 

 

Depr. Table : 2.5%

Effective Age : 7

Physical %Good: 84

Func. %Good : 100

Economic %Good: 100

Class: S

Floor Area: 46,800

Gross Bldg Area: 104,569

Stories Above Grd: 1

Average Sty Hght : 20

Bsmnt Wall Hght 

Desc. of Bldg/Section: 

Calculator Occupancy: Greenhouses - Commercial

*** Information herein deemed reliable but not guaranteed***

Commercial/Industrial Building/Section 2 of 5

Printed on

Parcel Number:

XA0-109-1150-02

07/28/2025

Bsmnt Insul.

 

Thickness

 

 (40) Exterior Wall:

 (39) Miscellaneous:

 (14) Roof Cover:

 (13) Roof Structure: Slope=0 

Incandescent

Fluorescent

Mercury

Sodium Vapor

Transformer

 

 

 

 

 

Flex Conduit

Rigid Conduit

Armored Cable

Non-Metalic

Bus Duct

 

 

 

 

 

Few

Average

Many

Unfinished

Typical

 

 

 

 

 

Few

Average

Many

Unfinished

Typical

 

 

 

 

 

Fixtures:

Outlets:

 (11) Electric and Lighting:

Hand Fired

Boiler

 

 

Coal

Stoker

 

 

Gas

Oil

 

 

 (10) Heating and Cooling:

 (9) Sprinklers:

Urinals

Wash Bowls

Water Heaters

Wash Fountains

Water Softeners

 

 

 

 

 

Total Fixtures

3-Piece Baths

2-Piece Baths

Shower Stalls

Toilets

 

 

 

 

 

Few

None

 

 

Average

Typical

 

 

Many

Above Ave.

 

 

 (8) Plumbing:

 (7) Interior:

 (6) Ceiling:

 (5) Floor Cover:

 (4) Floor Structure:

 (3) Frame:

Block

 

Brick/Stone

 

Poured Conc.

X

Footings

 

 (2) Foundation:

 (1) Excavation/Site Prep:

<<<<< Calculator Cost Computations >>>>>

 Class: S Quality: Excellent

Stories: 1 Story Height: 20 Perimeter: 760

 

Base Rate for Upper Floors = 169.13

 

(10) Heating system: Package Heating & Cooling Cost/SqFt: 19.34 100%

Adjusted Square Foot Cost for Upper Floors = 188.47

 

Total Floor Area: 31,200 Base Cost New of Upper Floors = 5,880,264

 

 Reproduction/Replacement Cost = 5,880,264

Eff.Age:7 Phy.%Good/Abnr.Phy./Func./Econ./Overall %Good: 84 /100/100/100/84.0

 Total Depreciated Cost = 4,939,422

 

ECF (COMM W BEECHER ST ETAL) 0.683 => TCV of Bldg: 3 = 3,373,625

 Replacement Cost/Floor Area= 188.47 Est. TCV/Floor Area= 108.13

 ** ** Calculator Cost Data ** **

Quality: Excellent

Heat#1: Package Heating & Cooling 100%

Heat#2: Electric, Cable or Baseboard 0%

Ave. SqFt/Story: 31200

Ave. Perimeter: 760

Has Elevators:

 

 *** Basement Info ***

Area:

Perimeter:

Type:

Heat:

 

 * Mezzanine Info *

Area #1:

Type #1:

Area #2:

Type #2:

 

 * Sprinkler Info *

Area: 100

Type: Excellent

Low

X

Ave.

 

Above Ave.

 

High

 

Construction Cost

Comments:

Overall Bldg

Height

 

Year Built

Remodeled

 

 

Depr. Table : 2.5%

Effective Age : 7

Physical %Good: 84

Func. %Good : 100

Economic %Good: 100

Class: S

Floor Area: 31,200

Gross Bldg Area: 104,569

Stories Above Grd: 1

Average Sty Hght : 20

Bsmnt Wall Hght 

Desc. of Bldg/Section: 

Calculator Occupancy: Greenhouses - Commercial

*** Information herein deemed reliable but not guaranteed***

Commercial/Industrial Building/Section 3 of 5

Printed on

Parcel Number:

XA0-109-1150-02

07/28/2025

Bsmnt Insul.

 

Thickness

 

 (40) Exterior Wall:

 (39) Miscellaneous:

 (14) Roof Cover:

 (13) Roof Structure: Slope=0 

Incandescent

Fluorescent

Mercury

Sodium Vapor

Transformer

 

 

 

 

 

Flex Conduit

Rigid Conduit

Armored Cable

Non-Metalic

Bus Duct

 

 

 

 

 

Few

Average

Many

Unfinished

Typical

 

 

 

 

 

Few

Average

Many

Unfinished

Typical

 

 

 

 

 

Fixtures:

Outlets:

 (11) Electric and Lighting:

Hand Fired

Boiler

 

 

Coal

Stoker

 

 

Gas

Oil

 

 

 (10) Heating and Cooling:

 (9) Sprinklers:

Urinals

Wash Bowls

Water Heaters

Wash Fountains

Water Softeners

 

 

 

 

 

Total Fixtures

3-Piece Baths

2-Piece Baths

Shower Stalls

Toilets

 

 

 

 

 

Few

None

 

 

Average

Typical

 

 

Many

Above Ave.

 

 

 (8) Plumbing:

 (7) Interior:

 (6) Ceiling:

 (5) Floor Cover:

 (4) Floor Structure:

 (3) Frame:

Block

 

Brick/Stone

 

Poured Conc.

X

Footings

 

 (2) Foundation:

 (1) Excavation/Site Prep:

<<<<< Calculator Cost Computations >>>>>

 Class: C Quality: Average

Stories: 1 Story Height: 16 Perimeter: 240

 

Base Rate for Upper Floors = 88.07

 

(10) Heating system: Forced Air Furnace Cost/SqFt: 11.52 100%

Adjusted Square Foot Cost for Upper Floors = 99.59

 

Total Floor Area: 3,600 Base Cost New of Upper Floors = 358,524

 

 Reproduction/Replacement Cost = 358,524

Eff.Age:7 Phy.%Good/Abnr.Phy./Func./Econ./Overall %Good: 84 /100/100/100/84.0

 Total Depreciated Cost = 301,160

 

ECF (COMM W BEECHER ST ETAL) 0.683 => TCV of Bldg: 4 = 205,692

 Replacement Cost/Floor Area= 99.59 Est. TCV/Floor Area= 57.14

 ** ** Calculator Cost Data ** **

Quality: Average 

Heat#1: Forced Air Furnace 100%

Heat#2: Electric, Cable or Baseboard 0%

Ave. SqFt/Story: 3600

Ave. Perimeter: 240

Has Elevators:

 

 *** Basement Info ***

Area:

Perimeter:

Type:

Heat:

 

 * Mezzanine Info *

Area #1:

Type #1:

Area #2:

Type #2:

 

 * Sprinkler Info *

Area:

Type: Average

Low

X

Ave.

 

Above Ave.

 

High

 

Construction Cost

Comments:

Overall Bldg

Height

 

Year Built

Remodeled

 

 

Depr. Table : 2.5%

Effective Age : 7

Physical %Good: 84

Func. %Good : 100

Economic %Good: 100

Class: C

Floor Area: 3,600

Gross Bldg Area: 104,569

Stories Above Grd: 1

Average Sty Hght : 16

Bsmnt Wall Hght 

Desc. of Bldg/Section: STORAGE

Calculator Occupancy: Garages - Storage

*** Information herein deemed reliable but not guaranteed***

Commercial/Industrial Building/Section 4 of 5

Printed on

Parcel Number:

XA0-109-1150-02

07/28/2025

Bsmnt Insul.

 

Thickness

 

 (40) Exterior Wall:

 (39) Miscellaneous:

 (14) Roof Cover:

 (13) Roof Structure: Slope=0 

Incandescent

Fluorescent

Mercury

Sodium Vapor

Transformer

 

 

 

 

 

Flex Conduit

Rigid Conduit

Armored Cable

Non-Metalic

Bus Duct

 

 

 

 

 

Few

Average

Many

Unfinished

Typical

 

 

 

 

 

Few

Average

Many

Unfinished

Typical

 

 

 

 

 

Fixtures:

Outlets:

 (11) Electric and Lighting:

Hand Fired

Boiler

 

 

Coal

Stoker

 

 

Gas

Oil

 

 

 (10) Heating and Cooling:

 (9) Sprinklers:

Urinals

Wash Bowls

Water Heaters

Wash Fountains

Water Softeners

 

 

 

 

 

Total Fixtures

3-Piece Baths

2-Piece Baths

Shower Stalls

Toilets

 

 

 

 

 

Few

None

 

 

Average

Typical

 

 

Many

Above Ave.

 

 

 (8) Plumbing:

 (7) Interior:

 (6) Ceiling:

 (5) Floor Cover:

 (4) Floor Structure:

 (3) Frame:

Block

 

Brick/Stone

 

Poured Conc.

X

Footings

 

 (2) Foundation:

 (1) Excavation/Site Prep:

<<<<< Calculator Cost Computations >>>>>

 Class: C Quality: Average

Stories: 1 Story Height: 16 Perimeter: 240

 

Base Rate for Upper Floors = 88.81

 

(10) Heating system: Forced Air Furnace Cost/SqFt: 11.62 100%

Adjusted Square Foot Cost for Upper Floors = 100.43

 

Total Floor Area: 3,500 Base Cost New of Upper Floors = 351,505

 

 Reproduction/Replacement Cost = 351,505

Eff.Age:7 Phy.%Good/Abnr.Phy./Func./Econ./Overall %Good: 84 /100/100/100/84.0

 Total Depreciated Cost = 295,264

 

ECF (COMM W BEECHER ST ETAL) 0.683 => TCV of Bldg: 5 = 201,665

 Replacement Cost/Floor Area= 100.43 Est. TCV/Floor Area= 57.62

 ** ** Calculator Cost Data ** **

Quality: Average 

Heat#1: Forced Air Furnace 100%

Heat#2: Electric, Cable or Baseboard 0%

Ave. SqFt/Story: 3500

Ave. Perimeter: 240

Has Elevators:

 

 *** Basement Info ***

Area:

Perimeter:

Type:

Heat:

 

 * Mezzanine Info *

Area #1:

Type #1:

Area #2:

Type #2:

 

 * Sprinkler Info *

Area:

Type: Average

Low

X

Ave.

 

Above Ave.

 

High

 

Construction Cost

Comments:

Overall Bldg

Height

 

Year Built

Remodeled

 

 

Depr. Table : 2.5%

Effective Age : 7

Physical %Good: 84

Func. %Good : 100

Economic %Good: 100

Class: C

Floor Area: 3,500

Gross Bldg Area: 104,569

Stories Above Grd: 1

Average Sty Hght : 16

Bsmnt Wall Hght 

Desc. of Bldg/Section: SECURED WASTE

Calculator Occupancy: Garages - Storage

*** Information herein deemed reliable but not guaranteed***

Commercial/Industrial Building/Section 5 of 5

Printed on

Parcel Number:

XA0-109-1150-02

07/28/2025

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