R's PHS_Groesbeck_FINAL.pdf
Geosebeck Holdings Limited Partnership, Petitioner Vs. Township Of Clinton, Respondent · 25-002212-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Petitioner: Groesbeck Holdings Limited Partnership Respondent: Clinton Charter Township MTT Docket No. 25-002212 Petitioner’s Prehearing Statement RESPONDENT’S PREHEARING STATEMENT Petitioner’s representative: Brian E. Etzel (P54905) Williams, Williams, Rattner & Plunkett, P.C. 380 N. Old Woodward Avenue, Suite 300 Birmingham, MI 48009 (248) 642-0333 Respondent’s representative: Laura M. Hallahan (P42101) Seth A. O’Loughlin (P80257) Kelsea M. Melcher (P85821) Hallahan & Associates, P.C. 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, Michigan 48302 (248) 731-3089 I. VALUATION INFORMATION: A. The true cash value (TCV), assessed value (AV), and taxable value (TV) for each parcel and tax year at issue as established by the Board of Review: Parcel Number Year TCV AV TV 16-11-33-126-006 2025 $3,419,000 $1,709,500 $1,172,647 B. Respondent’s contentions of TCV, state equalized value (SEV), and TV for each parcel and tax year at issue: Parcel Number Year TCV SEV TV 16-11-33-126-006 2025 $3,419,000 $1,709,500 $1,172,647 C. Petitioner’s contentions of TCV, state equalized value (SEV), and TV for each parcel and tax year at issue (per Petitioner’s Petition and Motions to Amend, if applicable): Parcel Number Year TCV SEV TV 16-11-33-126-006 2025 $1,600,000 $800,000 $800,000
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MTT Docket No. 25-002212 Respondent’s Prehearing Statement, Page 2 of 5 D. Amounts in dispute for the tax year(s) at issue: Parcel Number Year TCV SEV TV 16-11-33-126-006 2025 $1,819,000 $909,500 $372,647 II. TAX INFORMATION: A. Have taxes been paid for each property for each tax year at issue? ☒ Yes ☐ No III. FACTUAL STATEMENT OF CLAIMS: A. Describe any additions or losses for each property for each tax year at issue (by parcel number and tax year): Respondent is unaware of any additions or losses to the subject property. B. Classification of each property for each tax year at issue (by parcel number): 16-11-33-126-006 2025 Commercial-Improved C. Current use of each property for each tax year at issue, if different than above (by parcel number): Not applicable. D. Contention of highest and best use for each property for each tax year at issue, if different than property’s current use for each tax year at issue (by parcel number): Not applicable. E. Your factual statement of claims in support of your contentions, including additions and losses, if any (i.e., what facts are you relying on in support of your claim or defense?): Respondent contends that it lawfully and uniformly assessed the subject property. F. If non-uniformity of assessment is alleged, what evidence will you rely upon in support of your contents? Respondent contends that it lawfully and uniformly assessed the subject property. G. Affirmative Defenses (if any): Respondent incorporates by reference the affirmative defenses contained in its Answer to the Petition and its Answer to Petitioner’s Motion to Amend (if applicable).
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MTT Docket No. 25-002212 Respondent’s Prehearing Statement, Page 3 of 5 IV. ISSUES TO BE LITIGATED: A. Factual Issues: - What is the true cash value of the subject property as of December 31, 2024? B. Legal Issues: - What is the lawful assessed and taxable value of the subject property for the 2025 tax year? V. DO THE PLEADINGS NEED TO BE AMENDED TO CONFORM TO THE EVIDENCE? ☐ Yes ☒ No A. If yes, state all necessary amendments (a motion may be required to amend the pleadings): Not applicable. VI. ARE THERE CONSOLIDATION ISSUES? ☐ Yes ☒ No A. If yes, state the cases, by docket number, that should be consolidated with this case (a motion may be required to consolidate the cases): Not applicable. VII. PENDING OR ANTICIPATED MOTIONS OR OUTSTANDING DISCOVERY ISSUES, IF ANY: A. Motions: None at this time. B. Discovery: Respondent reserves the right to conduct post-valuation discovery in accordance with the Prehearing General Call. VIII. WITNESSES – IDENTIFY THE NAME AND ADDRESS OF ANY PERSON WHO MAY TESTIFY AND PROVIDE A GENERAL SUMMARY OF THE SUBJECT AREA OF THE TESTIMONY OF EACH PERSON IDENTIFIED: • Alicia Bernabei, MMAO, MCPPE, Clinton Charter Township, c/o Respondent’s counsel. Ms. Bernabei may be called to testify as to her knowledge of the subject property, her knowledge of the surrounding area, Respondent’s valuation disclosure,
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MTT Docket No. 25-002212 Respondent’s Prehearing Statement, Page 4 of 5 and any other matter necessary to make Respondent to make its case in chief or rebut Petitioner’s allegations. • John R. Widmer, MAI, Frohm & Widmer, 33966 W. Eight Mile Road, Suite 108, Farmington Hills, MI 48335. Mr. Widmer may be called to testify as to his knowledge of the subject property as well as Petitioner’s valuation evidence, Respondent’s valuation evidence, and any review appraisal as permitted by TTR 259. • David M. Tisdale, 5657 West Maple Road, West Bloomfield, MI 48322. Mr. Tisdale may be called to testify as to his knowledge of the subject property, the leasing of the subject property, Petitioner’s financials, and any other matter necessary for Respondent to make its case in chief or rebut Petitioner’s contentions. • Expert(s) to be selected and identified by Respondent. • Any and all witnesses listed by Petitioner. • Any and all persons who assisted in the preparation of Petitioner’s valuation disclosure. • Any and all necessary rebuttal witnesses. • Any and all custodians of the records. • Other witnesses to be determined. As provided by TTR 241, a person, other than a rebuttal witness, who is NOT identified as a witness in the prehearing statement, shall NOT be permitted to give testimony, unless, for good cause shown, the Tribunal permits the testimony to be taken. IX. NUMBER OF DAYS REQUIRED FOR HEARING: 1 day X. DISCLOSURE AND TAXATION OF COSTS: Respondent reserves the right to request costs. HALLAHAN & ASSOCIATES, P.C. /s/Kelsea M. Melcher____________ LAURA M. HALLAHAN (P42101) SETH A. O’LOUGHLIN (P80257) KELSEA M. MELCHER (P85821) Attorneys for Respondent 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302 Dated: September 8, 2026 (248) 731-3089
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MTT Docket No. 25-002212 Respondent’s Prehearing Statement, Page 5 of 5 PROOF OF MAILING On the date below I sent by electronic mail a copy of the foregoing Respondent’s Prehearing Statement and Valuation Disclosure to: Brian E. Etzel Williams, Williams, Rattner & Plunkett, P.C. bee@wwrplaw.com I declare that the statement above is true to the best of my information, knowledge and belief. /s/Kelsea M. Melcher______________ Dated: September 8, 2026 Kelsea M. Melcher