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Respondents Objections to Petitioners Motion to Set Aside Default.pdf

Mary Ann Lamkin, Petitioner V Township Of Hamburg, Respondent · 25-003057-TT

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

SMALL CLAIMS DIVISION 

 

Mary Ann Lamkin and 

Steven Lamkin, 

 

 

 

 

 

 

 

MTT Docket No. 25-003057 

 

Petitioners, 

 

v. 

 

 

 

Township of Hamburg, 

 

 

Respondent. 

 

Mary Ann Lamkin and Steve Lamkin 

ROSATI SCHULTZ JOPPICH 

Petitioners In Pro Per 

 

 

 

& AMTSBUECHLER 

P.O. Box 546 

 

 

 

 

Stephanie Simon Morita (P53864) 

Lakeland, MI 48143 

 

 

 

Matthew C. Wayne (P80542) 

(810) 231-3134 

 

 

 

 

Attorneys for Respondent 

malamkin@chartermi.net 

 

 

27555 Executive Dr., Ste. 250 

 

 

 

 

 

 

 

Farmington Hills, MI 48331 

 

 

 

 

 

 

 

(248) 489-4100 

 

 

 

 

 

 

 

smorita@rsjalaw.com 

 

 

 

 

 

 

 

mwayne@rsjalaw.com 

 

Respondent’s Objections to Petitioners’ Motion to Set Aside Default 

 

 

 

NOW COMES Respondent, TOWNSHIP OF HAMBURG, through counsel, 

ROSATI SCHULTZ JOPPICH & AMTSBUECHLER, by MATTHEW C. WAYNE, 

who, for its Objections to Petitioners’ Motion to Set Aside Default, states as follows: 

1. 

Petitioners commenced the instant action maliciously and without proper 

cause. 

2. 

 The instant matter is merely the latest attempt to relitigate issues and 

circumvent the inevitable.

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3. 

On or about November 18, 2025, Petitioners filed their Motion to Set Aside 

Default, professing a lack of understanding as to the procedural requirements of filing 

(i.e., submission of incomplete Petition). 

4. 

Petitioners failed, however, to serve Respondent in conformity with the court 

rules. 

5. 

Specifically, Petitioners failed not only to serve Respondent's counsel of 

record but all other necessary parties. 

6. 

TT Rule 211 states, in relevant part, that “[i]f a question concerning proper 

service is raised, the person or party claiming to have effectuated proper service bears 

the burden of proof.” 

7. 

Respondent respectfully asks this Tribunal to sustain its Objections and deny 

Petitioner’s motion. 

 

 

 

 

 

 

Respectfully submitted: 

 

 

 

 

 

 

ROSATI SCHULTZ JOPPICH & AMTSBUECHLER 

 

 

 

 

 

 

 

/s/ Matthew C. Wayne 

 

 

 

 

 

 

 

 

 

Stephanie Simon Morita (P53864) 

 

 

 

 

 

 

Matthew C. Wayne (P80542) 

 

 

 

 

 

 

 

 

Attorneys for Respondent 

 

 

 

 

 

 

27555 Executive Dr., Ste. 250 

 

 

 

 

 

 

Farmington Hills, MI 48331 

 

 

 

 

 

 

(248) 489-4100 

 

 

 

 

 

 

smorita@rsjalaw.com 

 

 

 

 

 

 

mwayne@rsjalaw.com 

 

Dated: December 8, 2025

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PROOF OF SERVICE 

 

The undersigned certified that a copy of the foregoing instrument was served 

upon all parties to the above cause at their respective addresses as directed on the 

pleadings by depositing the same in the United States Mail with postage fully prepaid 

thereon on December 8, 2025. 

 

/s/ Dawn Hallman 

Dawn Hallman

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