Full record / 24-000110.pdf

24-000110.pdf

D&E Property Services LLC, Petitioner V Township Of Northfield, Respondent · 24-004250-TT

← View full record

Text extracted from the reviewed PDF, organized by page. OCR and reading order may contain errors; confirm details in the PDF below.

Page 1

STATE OF MICHIGAN

 

GRETCHEN WHITMER 

GOVERNOR 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

LANSING

MARLON I. BROWN, DPA 

DIRECTOR 

 

 

MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760 

PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906 

D&E Property Services LLC, 

 

 

 

MICHIGAN TAX TRIBUNAL 

Petitioner, 

 

 

 

 

 

SMALL CLAIMS DIVISION 

 

MTT Docket No. 24-000110 & 

 

 

 

 

 

 

 

 

 

24-004250 

 

v 

 

 

 

 

 

 

 

Case Type: Principal Residence 

 

 

 

 

 

 

 

 

Exemption 

 

Northfield Township, 

 

 

 

 

Presiding Judge 

 

Respondent. 

 

 

 

 

Joshua M. Wease 

 

ORDER SEVERING PETITIONER’S UNCAPPING APPEAL AND ASSIGNING IT 

TO DOCKET NUMBER 24-004250 

 

FINAL OPINION AND JUDGMENT 

 

Location of Hearing: 

 

 

Telephonic 

Hearing Held on: 

 

 

 

October 15, 2024 

Appearances on Behalf of Petitioner: 

Daniel Prast 

Appearances on Behalf of Respondent: Thomas Monchak 

 

SUMMARY OF JUDGMENT 

 

Petitioner is not liable for the additional taxes, penalties, and interest owing as a 

result of the delay rescission of the previous owner’s Principal Residence Exemption 

(PRE) of Parcel No. B-02-05-400-004 for the 2021, 2022, and 2023 tax years pursuant 

to MCL 211.7cc(6), and (8). 

 

PROCEDURAL HISTORY 

 

Respondent issued a notice denying the property’s PRE on December 19, 2023. 

Petitioner filed a petition with the Tribunal on January 19, 2024, and Respondent filed 

an answer on May 28, 2024. 

 

ISSUES AND APPLICABLE LAW 

 

The issues in this matter are: (1) whether Petitioner’s property qualifies for a PRE under 

MCL 211.7cc and (2) whether Petitioner is liable for tax, interest, and penalty where 

they never claimed the PRE and Respondent improperly processed the PRE Rescission 

filed by the previous owner.

Page 2

MTT Docket No. 24-000110 & 24-004250 

Page 2 of 10 

 

A petitioner must prove, by a preponderance of the evidence, that they are entitled to an 

exemption.1 

 

As for the applicable statutory law: 

 

MCL 211.7cc provides that: 

 

A principal residence is exempt from the tax levied by a local school 

district for school operating purposes to the extent provided under . . . 

MCL 380.1211, if an owner of that principal residence claims an 

exemption as provided in this section. 

 

MCL 211.7cc(6) provides that: 

 

Except as otherwise provided in subsections (5), (32), and (33), if the 

assessor of the local tax collecting unit believes that the property for which 

an exemption is claimed is not the principal residence of the owner 

claiming the exemption, the assessor may deny a new or existing claim by 

notifying the owner and the county treasurer in writing of the reason for the 

denial and advising the owner that the denial may be appealed to the 

residential and small claims division of the Michigan tax tribunal within 35 

days after the date of the notice. The assessor may deny a claim for 

exemption for the current year and for the 3 immediately preceding 

calendar years. If the assessor denies an existing claim for exemption, 

the assessor shall remove the exemption of the property and, if the tax roll 

is in the local tax collecting unit's possession, amend the tax roll to reflect 

the denial and the local treasurer shall within 30 days of the date of the 

denial issue a corrected tax bill for any additional taxes with interest at the 

rate of 1.25% per month or fraction of a month and penalties computed 

from the date the taxes were last payable without interest or penalty. If 

the tax roll is in the county treasurer's possession, the tax roll shall be 

amended to reflect the denial and the county treasurer shall within 30 days 

of the date of the denial prepare and submit a supplemental tax bill for any 

additional taxes, together with interest at the rate of 1.25% per month or 

fraction of a month and penalties computed from the date the taxes were 

last payable without interest or penalty. Interest on any tax set forth in a 

corrected or supplemental tax bill shall again begin to accrue 60 days after 

the date the corrected or supplemental tax bill is issued at the rate of 

1.25% per month or fraction of a month. Taxes levied in a corrected or 

supplemental tax bill shall be returned as delinquent on the March 1 in the 

year immediately succeeding the year in which the corrected or 

supplemental tax bill is issued. If the assessor denies an existing claim for 

exemption, the interest due shall be distributed as provided in subsection 

(25). However, if the property has been transferred to a bona fide 

purchaser before additional taxes were billed to the seller as a result of the 

 

1 ProMed Healthcare v Kalamazoo, 249 Mich App 490; 644 NW2d 47 (2002).

Page 3

MTT Docket No. 24-000110 & 24-004250 

Page 3 of 10 

 

denial of a claim for exemption, the taxes, interest, and penalties shall not 

be a lien on the property and shall not be billed to the bona fide purchaser, 

and the local tax collecting unit if the local tax collecting unit has 

possession of the tax roll or the county treasurer if the county has 

possession of the tax roll shall notify the department of treasury of the 

amount of tax due, interest, and penalties through the date of that 

notification. The department of treasury shall then assess the owner who 

claimed the exemption under this section for the tax, interest, and 

penalties accruing as a result of the denial of the claim for exemption, if 

any, as for unpaid taxes provided under 1941 PA 122, MCL 205.1 to 

205.31, and shall deposit any tax or penalty collected into the state school 

aid fund and shall distribute any interest collected as provided in 

subsection (25). The denial shall be made on a form prescribed by the 

department of treasury. The assessor shall forward to the department of 

treasury a copy of a denial upon a request by the department of treasury. 

 

MCL 211.7dd provides that: 

 

Principal residence means the 1 place where an owner of the property has 

his or her true, fixed, and permanent home to which, whenever absent, he 

or she intends to return and that shall continue as a principal residence 

until another principal residence is established. . . . Principal residence 

includes only that portion of a dwelling or unit in a multiple-unit dwelling 

that is subject to ad valorem taxes and that is owned and occupied by an 

owner of the dwelling or unit. . . . Principal residence also includes all of 

an owner’s unoccupied property classified as residential that is adjoining 

or contiguous to the dwelling subject to ad valorem taxes and that is 

owned and occupied by the owner. Contiguity is not broken by a road, a 

right-of-way, or property purchased or taken under condemnation 

proceedings by a public utility for power transmission lines if the 2 parcels 

separated by the purchased or condemned property were a single parcel 

prior to the sale or condemnation. . . . Principal residence also includes 

any portion of a dwelling or unit of an owner that is rented or leased to 

another person as a residence as long as that portion of the dwelling or 

unit that is rented or leased is less than 50% of the total square footage of 

living space in the dwelling or unit. 

 

MCL 211.7dd also provides that: 

 

Owner means any of the following: (i) A person who owns property or who 

is purchasing property under a land contract. (ii) A person who is a partial 

owner of property. (iii) A person who owns property as a result of being a 

beneficiary of a will or trust or as a result of intestate succession. (iv) A 

person who owns or is purchasing a dwelling on leased land. (v) A person 

holding a life lease in property previously sold or transferred to another. 

(vi) A grantor who has placed the property in a revocable trust. (vii) The

Page 4

MTT Docket No. 24-000110 & 24-004250 

Page 4 of 10 

 

sole present beneficiary of a trust if the trust purchased or acquired the 

property as a principal residence for the sole present beneficiary of the 

trust, and the sole present beneficiary of the trust is totally and 

permanently disabled. As used in this subparagraph, "totally and 

permanently disabled" means disability as defined in section 216 of title II 

of the social security act, 42 USC 416, without regard as to whether the 

sole present beneficiary of the trust has reached the age of retirement. 

(viii) A cooperative housing corporation. (ix) A facility as defined by former 

1976 PA 440 and registered under the continuing care community 

disclosure act, 2014 PA 448, MCL 554.901 to 554.993. 

 

MCL 211.7dd(b) provides that: “‘Person’ for purposes of defining owner as used in 

section 7cc means an individual.” 

 

Pursuant to R 792.10133, after hearing, the Tribunal must issue a final decision in 

writing. Additionally, “[a] written final decision shall include separate sections entitled 

“findings of fact” and “conclusions of law.’” Findings of fact “shall include a concise 

statement of the underlying supporting facts” that are “based exclusively on the 

evidence.”2 Consequently, the Tribunal has not addressed every piece of evidence or 

every inference that might lead to a conflicting conclusion and has rejected evidence 

contrary to its findings. Furthermore, “[e]ach conclusion of law shall be supported by 

authority or reasoned opinion.”3 Accordingly, the Tribunal will outline the summary of 

evidence, findings of facts, and conclusions of law, before ultimately rendering 

judgment. 

 

SUMMARY OF EVIDENCE 

 

A. Petitioner’s Evidence 

 

The exhibits offered by Petitioner may be viewed on lines 2, 8, and 20 of the 

docket maintained in this case.4 No exhibits were excluded from evidence. 

 

Based on the pleadings, admitted exhibits, and sworn testimony, Petitioner 

contends that interest was charged because of a delayed uncapping. Petitioner’s 

Property Transfer Affidavit (PTA) and the previous owners PRE Rescission were not 

processed at the time they were timely filed on August 30, 2020. Then in 2023, 

Petitioner received the PRE denial invoice and assessment of late payment interest. 

Petitioner does not believe they should be liable for interest because Respondent never 

sent a bill. Petitioner does not disagree with the PRE denial but is protesting the 

assessment of interest. Second, the property was uncapped in 2022. If the form was 

submitted in 2020, Petitioner does not understand why it would be uncapped again in 

2022. 

 

2 See also MCR 2.517(a). 

3 Id. 

4 The docket is located on the Tribunal’s website at Tax Docket Lookup Search Page and may be 

accessed by entering the docket number assigned to this case.

Page 5

MTT Docket No. 24-000110 & 24-004250 

Page 5 of 10 

 

B. Respondent’s Evidence 

 

The exhibits offered by Respondent may be viewed on lines 13 and 21 of the 

docket maintained in this case.5 No exhibits were excluded from evidence. 

 

Based on the pleadings, admitted exhibits, and sworn testimony, Respondent 

contends that they included a summary of the facts with respect to the property in 

evidence. During the Covid pandemic, Petitioner filed a PTA and the previous owner 

filed a PRE Rescission form. The form was improperly processed and was stamped 

“copy” rather than date received with township office name on it. Then the township 

performed an audit of their records. They found these forms from Petitioner and the 

previous owner that were not processed. Respondent’s assessor decided to present 

the delayed uncapping to the BOR. The assessor denied the PRE and subsequent 

years in December 2023, which is giving rise to this appeal. Petitioner’s LLC is not 

entitled to a PRE. Since the property transferred in 2020, it would have uncapped back 

to 2021. However, Respondent only uncapped back to 2022. Since they were not 

processed correctly, they are only corrected for the current year and previous year only. 

Interest was limited to the PRE denial, not the uncapping. In response to Petitioner, 

Respondent’s assessor stated that the 2022 Tax Due Notice, dated December 20, 

2023, is for the uncapping. 

 

FINDINGS OF FACT 

 

The following facts were found to be proven by a preponderance of the evidence: 

 

1. The subject property is located at 254 East Shore Drive in Washtenaw County. 

2. The subject property is classified as residential. 

3. Petitioner is a limited liability company. 

4. Petitioner purchased the subject property in 2020 and was the owner of the 

property for the years at issue. 

5. Petitioner is a bona fide purchaser of the subject property from the previous 

owner. 

6. Petitioner timely filed a PTA for the subject property in August 2020. 

7. Petitioner did not file a PRE Affidavit for the subject property for any of the years 

at issue. 

8. The previous owner, who sold the subject property to Petitioner, timely filed a 

PRE Rescission form. 

9. Respondent discovered Petitioner’s unprocessed PTA in November 2023. 

10. Respondent discovered previous owner’s PRE Rescission in November 2023. 

 

CONCLUSIONS OF LAW 

 

Petitioner admits that they are not eligible for a PRE for the years at issue. The 

issue is that Petitioner timely filed a PTA in 2020 during the Covid pandemic. 

 

5 The docket is located on the Tribunal’s website at Tax Docket Lookup Search Page and may be 

accessed by entering the docket number assigned to this case.

Page 6

MTT Docket No. 24-000110 & 24-004250 

Page 6 of 10 

 

Respondent admits that this PTA was not properly processed until 2023. Once 

Respondent processed the PTA, Petitioner was issued a bill that included an 

assessment of interest. While the previous owner filed a PRE Recission, there is no 

dispute that Petitioner did not file a PRE Affidavit to claim a PRE for the subject 

property. The PTA is a form that is used by the parties to determine when there has 

been a transfer that causes the property to “uncap.” The uncapping is not at issue in 

this case. The Tribunal finds that there are two legal theories under which Petitioner is 

not liable for the tax, interest, or penalties. First, the persuasive caselaw of Mikelonis v 

Department of Treasury6 holds that a PRE cannot be denied when someone has not 

claimed the PRE. Second, MCL 211.7o(6) states that where a previous owner’s PRE 

claim is denied, it cannot be assessed to a bona fide purchaser. 

 

Petitioner did not claim a PRE 

 

“A ‘claim’ for a PRE is not properly filed unless the owner submits an affidavit 

with the taxing unit.”7 Just as in Mikelonis v Department of Treasury, “[i]t is not possible 

for respondent to determine the validity of, or to deny, an exemption that was never 

claimed.”8 An important consideration is that Respondent in this case is the township 

instead of the Department of Treasury. This is relevant because the statutory provision 

that was considered in Mikelonis was MCL 211.7cc(8), which only applies to the 

Department of Treasury. The Mikelonis Court found that: 

 

by misinterpreting the scope of respondent's authority under MCL 

211.7cc(8). MCL 211.7cc(8) clearly limits respondent's authority to review 

a taxpayer's PRE status to instances where the taxpayer claimed a PRE, 

and to deny a claim for a PRE if the property is not the residence of the 

owner claiming the exemption. Respondent cannot broaden the clear 

statutory language by denying exemptions under § 7cc(8) that were not 

claimed by the property owner. In this case, petitioner did not claim a PRE 

and, therefore, there was no claim for respondent to deny.9 

 

However, there is the same “claim” language in Section 6 – which involves 

instances where the assessor of a local taxing authority denies a claimed PRE -- as 

there is in Section 8 that the Mikelonis Court considered. 

 

 

6 Mikelonis v Dep’t of Treasury, unpublished per curiam opinion of the Court of Appeals, issued June 26, 

2012 (Docket No. 304054). 

7 MCL 211.7cc(2); Mikelonis v Dep’t of Treasury, unpublished per curiam opinion of the Court of Appeals, 

issued June 26, 2012 (Docket No. 304054) at 3. See also Delger v Dep't of Treasury, unpublished per 

curiam opinion of the Court of Appeals, issued May 30, 2024 (Docket No. 367878) at 5 (“petitioners did in 

fact file PRE affidavits that created the confusion from the beginning, distinguishing these cases from 

Mikelonis”) and Marie De Lamielleure Trust v Dep’t of Treasury, 305 Mich App at 287; 853 NW2d 708 

(2014) (distinguishing Mikelonis on the basis that “De Lamielleure claimed a PRE on the property during 

her lifetime and . . . benefitted from that claim despite an ineffectual attempt to rescind the PRE”). 

8 Id. 

9 Mikelonis v. Dep't of Treasury, No. 304054, 2012 WL 2402596, at *3 (Mich. Ct. App. June 26, 2012).

Page 7

MTT Docket No. 24-000110 & 24-004250 

Page 7 of 10 

 

Except as otherwise provided in subsections (5), (32), and (33), if the 

assessor of the local tax collecting unit believes that the property for which 

an exemption is claimed is not the principal residence of the owner claiming 

the exemption, the assessor may deny a new or existing claim by notifying 

the owner and the county treasurer in writing of the reason for the denial 

and advising the owner that the denial may be appealed to the residential 

and small claims division of the Michigan tax tribunal within 35 days after 

the date of the notice. The assessor may deny a claim for exemption for 

the current year and for the 3 immediately preceding calendar years. If the 

assessor denies an existing claim for exemption, the assessor shall remove 

the exemption of the property and, if the tax roll is in the local tax collecting 

unit's possession, amend the tax roll to reflect the denial and the local 

treasurer shall within 30 days of the date of the denial issue a corrected tax 

bill for any additional taxes with interest at the rate of 1.25% per month or 

fraction of a month and penalties computed from the date the taxes were 

last payable without interest or penalty. If the tax roll is in the county 

treasurer's possession, the tax roll shall be amended to reflect the denial 

and the county treasurer shall within 30 days of the date of the denial 

prepare and submit a supplemental tax bill for any additional taxes, together 

with interest at the rate of 1.25% per month or fraction of a month and 

penalties computed from the date the taxes were last payable without 

interest or penalty. Interest on any tax set forth in a corrected or 

supplemental tax bill shall again begin to accrue 60 days after the date the 

corrected or supplemental tax bill is issued at the rate of 1.25% per month 

or fraction of a month.10 

 

In this case, Petitioner did not file a PRE Affidavit for the subject property and 

has never claimed the PRE. Just as in Mikelonis, Petitioner merely received the benefit 

of the PRE. Also, like Mikelonis, Respondent argues that Petitioner is liable for the 

unclaimed PRE that they received. The Mikelonis Court held that the Petitioner in that 

case was not liable for the tax, interest, or penalty of a PRE that they never claimed. 

Although not binding precedent, the facts and reasoning are similar to this case and are 

persuasive that Petitioner should receive the same result in this case. 

 

Petitioner is a bona fide purchaser 

 

This case is actually about a PRE Rescission -- that the previous owner filed -- 

but was not timely processed. Pursuant to MCL 211.7cc(5): 

 

Except as otherwise provided in this subsection and subsections (32) and 

(33), not more than 90 days after exempted property is no longer used as a 

principal residence by the owner claiming an exemption, that owner shall 

rescind the claim of exemption by filing with the local tax collecting unit a 

rescission form prescribed by the department of treasury.11 

 

10 MCL 211.7cc(6) (emphasis added). 

11 Id. (Emphasis added).

Page 8

MTT Docket No. 24-000110 & 24-004250 

Page 8 of 10 

 

 

In cases where the assessor of the local taxing authority denies an existing 

claim, they may assess the owner tax, interest, and penalty for the current year and 

three years back pursuant to MCL 211.7cc(6). The Tribunal finds that the township 

actually denied or otherwise removed the previous owner’s PRE claim pursuant to the 

previous owner’s PRE Rescission. In these instances, Section 6 also states: 

 

However, if the property has been transferred to a bona fide purchaser 

before additional taxes were billed to the seller as a result of the denial of a 

claim for exemption, the taxes, interest, and penalties shall not be a lien on 

the property and shall not be billed to the bona fide purchaser, and the local 

tax collecting unit if the local tax collecting unit has possession of the tax 

roll or the county treasurer if the county has possession of the tax roll shall 

notify the department of treasury of the amount of tax due, interest, and 

penalties through the date of that notification.12 

 

The Tribunal further finds that the subject property was transferred to Petitioner 

as a bona fide purchaser before the additional taxes were billed to the seller, as a result 

of the denial of the claim for exemption. MCL 211.7cc(5) specifically states that the 

rescission is to be filed by the owner claiming the exemption. Respondent cited no legal 

authority making Petitioner responsible for this filing, and the Tribunal finds no statutory 

language or case law supporting such a finding. Petitioner has met their burden of 

proof that they are not liable for the accrued tax, interest, or penalties on the past tax 

debts due to the late processed PRE Rescission. 

 

Uncapping 

 

In regard to the uncapping, the subject property’s TV was uncapped for the 2022 

and 2023 tax years by the December 2023 Board of Review (BOR). The BOR decision 

states: “2023-12-12 delayed uncapping for 2021, 2022, & 2023. Date of transfer was 

2020-08-30.”13 Petitioner’s amended petition, filed on March 27, 2024, was made on 

the PRE petition form, but includes statements that question the December BOR 

uncapping. Further, Petitioner attached the December BOR decision, which gave rise 

to the appeal. Petitioner’s original petition, although defective, was timely filed on 

January 19, 2024. Therefore, the Tribunal finds that Petitioner attempted to appeal both 

the PRE claim and the uncapping claim. The Tribunal further finds that it erred in failing 

to require petitioner to file a separate petition and filing fee for the uncapping appeal 

when the petition in this case was processed. The Tribunal has jurisdiction to hear the 

appeal on uncapping. However, because this issue is not properly pending in this 

appeal and was not adequately addressed by either party at the hearing, this claim will 

be severed to determine whether the December 2023 BOR had authority to uncap the 

subject property’s taxable value after that value was confirmed by the March BOR. 

 

 

 

12 Id. (Emphasis added). 

13 Petitioner’s Petition, attachments at 7.

Page 9

MTT Docket No. 24-000110 & 24-004250 

Page 9 of 10 

 

JUDGMENT 

 

IT IS ORDERED that Petitioner’s uncapping appeal is SEVERED and assigned Docket 

No. 24-004250. 

 

IT IS FURTHER ORDERED that Petitioner shall file a petition pertaining to the 

uncapping appeal with the additional $50.00 fee required for the filing of that 

petition within 21 days of the entry of this Order.14 The petition shall note the 

docket number assigned by the Tribunal for the uncapping appeal. 

Unfortunately, the payment may not be made via e-filing.15 

 

IT IS ORDERED that the officer charged with maintaining the assessment rolls for the 

tax year(s) at issue shall correct or cause the assessment rolls to be corrected to reflect 

the property’s principal residence exemption for the tax year(s) at issue within 20 days 

of entry of this Final Opinion and Judgment. 

 

IT IS FURTHER ORDERED that the officer charged with collecting or refunding the 

affected taxes shall collect taxes and any applicable interest or issue a refund within 28 

days of the entry of this Final Opinion and Judgment. If a refund is warranted, it shall be 

without interest, as provided by MCL 211.7cc. It shall, however, include a proportionate 

share of any property tax administration fees paid and penalty and interest paid on 

delinquent taxes. The refund shall also separately indicate the amount of the taxes, 

fees, penalties, and interest being refunded. 

 

This Final Opinion and Judgment resolves all pending claims in this matter and closes 

this case. 

 

APPEAL RIGHTS 

If you disagree with the final decision in this case, you may file a motion for 

reconsideration with the Tribunal or a claim of appeal with the Michigan Court of 

Appeals. 

 

A motion for reconsideration must be filed with the Tribunal with the required filing fee 

within 21 days from the date of entry of the final decision. Because the final decision 

closes the case, the motion cannot be filed through the Tribunal’s web-based e-filing 

system; it must be filed by mail or personal service. The fee for the filing of such 

motions is $50.00 in the Entire Tribunal and $25.00 in the Small Claims Division, unless 

the Small Claims decision relates to the valuation of property and the property had a 

principal residence exemption of at least 50% at the time the petition was filed or the 

decision relates to the grant or denial of a poverty or disabled veterans exemption and, 

 

14 Petitioner paid a $100.00 fee for the filing of this appeal and the combined filing fee for the two 

separate appeals is $150.00. 

15 The petition may be downloaded from the Tribunal’s website and mailed to the Tribunal via United 

States Postal Service at: Michigan Tax Tribunal, PO BOX 30232, Lansing, MI 48909. The petition may 

also be delivered to the Tribunal via overnight carrier (UPS, FedEx, or DHL) at: Michigan Tax Tribunal, 

2nd Floor MTT, 2407 N. Grand River Avenue, Lansing, MI 48933.

Page 10

MTT Docket No. 24-000110 & 24-004250 

Page 10 of 10 

 

if so, there is no filing fee. You are required to serve a copy of the motion on the 

opposing party by mail or personal service or by email if the opposing party agrees to 

electronic service, and proof demonstrating that service must be submitted with the 

motion. Responses to motions for reconsideration are prohibited and there are no oral 

arguments unless otherwise ordered by the Tribunal. 

 

Alternatively, you may file a claim of appeal with the Michigan Court of Appeals. If the 

claim is filed within 21 days of the entry of the final decision, it is an “appeal of right.” If 

the claim is filed more than 21 days after the entry of the final decision, it is an “appeal 

by leave.” A copy of the claim of appeal must be filed with the Tribunal to certify the 

record on appeal. There is no certification fee. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

By _______________________________________ 

 

Entered: May 14, 2025 

 

 

PROOF OF SERVICE 

 

I certify that a copy of the foregoing was sent on the entry date indicated above to the 

parties or their attorneys or authorized representatives, if any, utilizing either the mailing 

or email addresses on file, as provided by those parties, attorneys, or authorized 

representatives. 

 

By: Tribunal Clerk

PDF reading copy

← View full record