25-002384.pdf

Broadway Detroit Development II LLC, Petitioner Vs. City Of Detroit, Respondent · 25-002384-TT

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RECEIVED 

SEP 252025 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

BROADWAY DETROIT DEVELOPMENT II LLC, 

Petitioner, 

MTT Docket No. 25-002384 

v 

CITY OF DETROIT, 

Traninfo:4606h 

260582211 

09/24/25 

Chk: 

1576 

Ants $50.00 

Respondent. 

ID: 

LAW OFFICE OF AARON M FALES FC 

/ 

AARON M. FALES (P72864) 

Kevin Richard (P43417) 

LAW OFFICE OF AARON M FALES PC 

Coleman A. Young Bldg. 

Attorney for Petitioner 

2 Woodward Ave., Suite 500 

1080 Canyon Creek Drive 

Detroit, MI 48226 

Rochester Hills, MI 48307 

313-237-3061 

(248) 767-9840 

PETITIONER’S MOTION FOR RECONSIDERATION 

Petitioner, by and through its counsel, Law Office of Aaron M. Fales, P.C., hereby serves 

its Motion for Reconsideration, and states as follows: 

BACKGROUND 

1. 

This case involves a very late issued 2025 March Board of Review determination 

erroneously uncapping Petitoner’s property 

that was transferred between related 

entities under common control. 

Petitioner timely appealed the final determination

. 

Respondent, 

City 

of Detroit, 

entered 

a March 

Board 

of Review 

(“MBOR”) 

Determination on May 17, 2025 ( EXHIBIT A — MBOR Notice) and subsequently 

mailed said determination to Petitioner. 

. 

Petitioner received the determination on June 7, 2025, after the normal May 31, 2025 

filing deadline (EXHIBIT B — Email Confirming receipt of Notice (6/7/25)). 

. 

Five (5) days after actually receiving the Notice, Petitioner’s Counsel appealed the 

final decision of Respondent’s MBOR on 6/12/25 (EXHIBIT C — Petition), pointing 

out the notice was issued on 5/17/25 (27 days prior) to the Tribunal. 

. 

On August 20" 

the Tribunal 

entered 

an Order dismissing Petitioner’s Petition 

(EXHIBIT D — 8/20/25 Order). 

The Tribunal’s 8/20/25 Order is an Error of Law and Must be Reversed. 

The Tribunal errored in its application of MCL 205.735a(6) (EXHIBIT E — Statute) 

by focusing solely on the May 31 deadline language, however, the May 31° deadline 

is not applicable in this matter as Petitioner is invoking the Tribunal’s jurisdiction 

pursuant the other prong of MCL 205.735a(6) which states: 

“In all other matters, the jurisdiction of the tribunal is invoked by a party in 

interest, as petitioner, filing a written petition within 35 days after the final 

decision, ruling, or determination.” 

. 

In this matter the “final decision, ruling, or determination” of the MBOR was issued 

on 5/17/25 (27 days prior to appeal) and actually received by Petitioner on 6/7/25 (5

IL 

was, and is, proper and this Motion for Reconsideration must be granted to correct 

this error in law. 

Petitioner alleged and invoked jurisdiction under MCL 205.735a(6) in section 5 of its 

Petition and the Tribunal has jurisdiction over this matter because it was filed within 

35 days of receipt of the final decision giving rise to this appeal and therefore 

Petitioner’s Motion for Reconsideration must be granted as a matter of Law. 

A Palpable Error Exists Therefore This Motion Must be Granted 

10. 

IIL. 

A palpable error is an error from which “a different disposition would result from a 

correction of the error.” Luckow v Luckow, 291 Mich App 417, 426; 805 NW2d 453 

(2011). 

Here, 

a different disposition would result from 

correcting 

this 

error; 

Petitioner would have a right to expeditious and properly correct the error by granting 

this motion for reconsideration. Therefore, there is a palpable error because dismissal 

is an error of law and not proper in this instance. Petitioner invoked the timely 

jurisdiction of the Tribunal and should be permitted to correct this error at the 

Tribunal. 

Petitioner would not be able to timely correct the erroneous uncapping 

unless this Motion is granted and therefore this dismissal results in a palpable error as 

well as an error in law. 

The error of law result in a palpable error as well and therefore Petitioner’s Motion 

for reconsideration should also be granted. 

Conclusions

WHEREFORE, Petitioner respectfully asks this Tribunal to 

1) enter an Order granting 

Petitioner’s Motion for Reconsideration, 

2) reinstate this case 

as active on the Tribunal’s 

docketing system, and 3) award any other costs or relief it deems necessary to Petitioner in this 

matter. 

Respectfully submitted, 

LAW OFFICES OF AARON M. FALES 

Attorneys for Petition 

By: 

Aaron M. Fales (P72864) 

330 Hamilton Row, Ste. 350 

Birmingham, MI 48009 

(248) 767-9840 

Dated: September 5, 2025

EXHIBIT A

Coleman A. Young Municipal Center 

2 Woodward Avenue, Suite 105 

Detroit, Michigan 48226 

Phone: (313) 628-0722 

Fax: (313) 224-4576 

www.detroitmi.gov 

Board of Review 

osm 

BROADWAY DETROIT DEVEL II, LLC 

1300 BROADWAY STE 600 

DETROIT MI 48236 

RE: 

2025 

MARCH BOARD OF REVIEW PETITION NUMBER: 

M-501258 

The March Board of Review has considered the appeal on the 2025 assessment for the below described property 

and concluded that: 

FINDING OF FACTS: 

1. 

Parcel Number: 

01004005. 

2. 

Property Address: 

1322 BROADWAY 

3. 

District: 

6 

4. 

Property Classification: 

201 

(COMMERCIAL-IMPROVED) 

Ad Valorem 

6. 

Principle Residence Exemption: 

0% 

5. 

Property Legal Description: 

NE BROADWAY 

N 30.65 FT OF 6 AND VAC 10 FT OF LAND IN FRONT PLAT OF SEC 9 GOVERNOR & JUDGES PLAN L34 P552 DEEL 

6. Petitioner timely filed an appeal to the March Board of Review. 

7. The March Board of Review considered 

(if any) petitioner's and/or duly authorized representative evidence 

and/or testimony. The March Board of Review considered facts presented as on the assessment roll and/or any 

recommendations offered by the Office of the Assessor. 

CONCLUSION: 

Taxable Value Uncapping due to Proposal A of 1994 

Before Appeal 

After Appeal 

2025 

Assessed Value 

411,700 

411,700 

2025 

Taxable Value 

184,490 

411,700 

If you are dissatisfied with the decision of the March Board of Review, submit this notice and complete the enclosed 

small claims form to appeal to: 

Michigan Tax Tribunal 

P.O. Box 30232 

Lansing 

MI 48909 

A Michigan Tax Tribunal appeal 

must 

be made 

by May 31st 

of the current year for properties classified 

as:

STATE OF MICHIGAN 

., 

GRETCHENWHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

PROPERTY TAX APPEAL PETITION FORM 

VALUATION / EXEMPTION / CLASSIFICATION APPEAL 

Do not use this form to appeal Principal Residence Exemption, Qualified Agricultural Exemption, Special Assessment, or 

Non-Property tax disputes. 

Pursuant to Michigan Tax Tribunal Rule (TTR) 277(3), you MUST submit a copy of the notice giving rise to the appeal 

(e.g. Board of Review Decision or Notice of Uncapping) with this Small Claims Petition, if applicable. If you do not 

submit this document, you may be held in default. 

Section 1: Petitioner's Contact Information 

First Name 

ML 

Last Name/Company Name 

Mailing Address (No., Street, P.O. Box or Rural Route) 

City or Town 

State 

ZIP Code 

Telephone Number 

Fax Number 

E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) 

Section 2: Petitioner's Attorney/Authorized Representative’s Contact Information 

First Name 

m.I 

Last Name 

Firm Name (if any) 

Address (No., Street, P.O. Box or Rural Route) 

City or Town 

State 

ZIP Code 

Telephone Number 

Fax Number 

E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) 

Section 3: Subject Property Information 

How many 

If you are appealing more than one parcel, are they contiguous or adjoining? 

parcelsareyou | [7] yes* 

[] No* 

appealing? 

*If yes, use a multiple parcel form for information regarding any contiguous parcels.

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

Section 7: Valuation Information *use the multiple parcel form for additional, contiguous parcels. 

Parcel ldentification Number: 

Classification 

of Property: 

Real 

Personal 

(check one) 

Agricultural 

Commercial 

Industrial 

Residential 

Timber-Cutover 

Developmental 

Utility 

(check one) 

Current Assessed Value (also known as State Equalized Value) as established by the BOR: 

Current Taxable Value as established by the BOR: 

What do you belleve is the fair market value (also known as True Cash Value)? 

Multiply the True Cash Value by .5 and enter here. This Is your contention of Assessed Value. 

If you believe the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value. 

Section 8: Classification Information *Only the MI Dep't of Treasury may appeal this Issue to the Tribunal* 

Parcel Identification Number: 

Current Classification of Property as established by Board of Review: 

Real 

Personal 

(check one) 

Agricultural 

Commercial 

Industrial 

Residential 

Timber-Cutover 

Developmental 

Utllity 

(check one) 

What do you believe is the property's classification? 

Real 

Personal 

(check one) 

Agricultural 

Commercial 

Industrial 

Residential 

Timber-Cutover 

Developmental 

Utility 

(check one) 

Ifimproved property, how 

is the property currently being used? 

Ifimproved property, for what use was the property designed?

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

PAPER FILING INSTRUCTIONS FOR VALUATION/EXEMPTION/GLASSIFICATION APPEAL 

Follow these instructions for filing this small claims petition. For any questions that are not answered in these 

instructions, see the Tribunal's website at www.michigan.gov/taxtrib or contact the Tribunal at 517-335-9760. 

Mail the completed form to: 

Michigan Tax Tribunal 

611 W. Ottawa St., Lansing, MI 48933 

U.S. Postal Mailing Address: PO BOX 30232, Lansing, MI 48909 

Other Carriers (UPS,FedEx,DHL): 

2nd Floor MTT, 2407 N. Grand River Avenue, Lansing, MI 48906 

Section 1: Petitioner's Contact Information: "Petitioner" is the person, business, or entity filing the appeal. 

Section 2: Petitioner's Attorney/Authorized Representative’s Contact Information: Petitioner does not have to 

be represented 

by an attorney or authorized representative to 

file an appeal with the Tribunal. 

If Petitioner 

is 

represented, provide all contact information for the attorney or authorized representative. 

If Petitioner elects to have 

an attorney or authorized representative, only the attorney or authorized representative will receive notices and 

documents from the Tribunal. 

IMPORTANT: If the contact information for Petitioner, or the attorney or authorized representative, 

if listed, includes 

an email address, the Tribunal will use that email address to electronically serve all future documents issued by the 

Tribunal. A request by Petitioner or Petitioner's attorney or authorized representative to opt out of electronic service 

once an email address is provided must be made in writing. 

Section 3: Subject Property Information: 

© 

How many parcels are you appealing: List the number of parcels under appeal. 

© 

Are they contiguous or adjoining: If multiple parcels are being appealed, indicate whether the parcels are 

adjoining. 

If multiple parcels are being appealed, a separate petition must be filed for each non-adjoining 

parcel being appealed. 

Property Address: Provide the address of all properties being appealed. 

o 

Taxing Authority: Provide the name of the city OR township (not both) where the property is located. 

© 

County: Provide the name of the county where the property is located. 

Section 4: Issues Being Appealed: Check all issues being appealed 

Section 5: Explain the Reason for this Appeal: Explain the reason(s) for the appeal. 

Section 6: Jurisdictional Issues: 

© 

Year(s) you are appealing: List the tax year(s) being appealed. 

If more than one year is being appealed, 

explain the reason(s). 

e 

Did you protest the assessment at a Board of Review (BOR): Indicate whether Petitioner

EXHIBIT B

0) Outlook 

FW: Scanned image from BASCO 

From Roger Basmajian <«gpinSiiuamiugre 

Date Tue 6/10/2025 9:05 AM 

To 

Aaron Fales SRSNGHREIRIISIED 

Cc 

Bridgette Smith <gEpENEEISES 

0 

1 attachment (2 MB) 

BASCO_20250607_125916.pdf; 

I'm trying to understand this. Looks like there was an appeal and they increased the value to the full 

assessed value? 

Lets discuss 

Roger Basmajian 

| President & CEO 

a: Basco 

| 1300 Broadway, 6th Floor, Detroit, MI 48226 

w: www.bascomi.com 

From: Bridgette Smith <{isigeea@iSanmmay» 

Sent: Saturday, June 7, 2025 1:22 PM 

To: Roger Basmajian < pianos 

Subject: FW: Scanned image from BASCO 

Hi, 

Does this need to go to Aaron Fales?

EXHIBIT C

STATE OF MICHIGAN 

MICHIGAN ADMINISTRATIVE HEARINGS SYSTEM 

MICHIGAN TAX TRIBUNAL 

BROADWAY DETROIT DEVELOPMENT II LLC, 

Petitioner, 

(= 

MTT Docket #25. 

OO 1384 

VS. 

Parcel No. 01004005. 

CITY OF DETROIT, 

Respondent. 

PETITION 

BROADWAY 

DETROIT 

DEVELOPMENT 

II 

LLC 

(“Petitioner”), 

through 

its 

attorneys, Law Office of Aaron M. Fales, P.C., says: 

1. 

Petitioner's 

principal 

office address 

is 

1300 Broadway, 

Suite 

600, 

Detroit, MI 48226. 

Petitioner is a party in interest with respect fo property taxes 

on 

real 

property 

tax parcel 

nos. 01004005. 

("Petitioner's 

Property"), 

at 

1322 

Broadway, Detroit, Ml, 48226. 

2. 

Respondent, City of Detroit assesses and collects property taxes on 

Petitioner's Property. 

3. 

In 2025, Respondent determined the taxable value of Petitioner's 

Parcel # 01004005. to be $184,490 and assessed Petitioner's Property at $411,700

4, 

At the March Board of Review, Respondent erroneosly uncapped 

Petitioner's Taxable Value and Adjusted it up to $411,700. 

6. 

Petitioner's 

Property 

is 

classified 

as 

Commercial 

Real 

Property. 

Petitioner's Property is commercial property. 

Petitioner believes that Petitioner's 

Property was designed to be used as a commercial purposes. 

5. 

This matter involves issues relating to: (a) valuation, (b) assessment, 

(c) taxable value, and (d) uniformity. 

6. 

At this time, Petitioner believes, as 

it relates to taxable value, that 

there is a dispute relative to an erroneous uncapping. 

Z. 

The 2025 assessment, including state equalized value and taxable 

value, 

imposed 

on 

Petitioner's 

Property, 

and 

the 

taxes 

to 

be 

levied 

and 

collected thereon, are invalid and unlawful and operate as a fraud upon the 

taxpayer for the reasons that: 

(a) 

The 

assessment, 

including 

state 

equalized 

value 

and/or 

taxable value, exceeds the amount permitted by the Michigan Constitution and 

applicable statutes;

(c) 

The 

assessment, 

including 

taxable 

value 

and/or 

state 

equalized value, are based upon an erroneous determination of the true cash 

value of that portion of Petitioner's Property that is taxable under Michigan law, 

and are based upon the application of wrong principles; and, 

(d) 

The 

assessment, 

including 

state 

equalized 

value 

and/or 

taxable 

value, 

and 

the 

mode 

of 

assessment 

adopted 

by 

Respondent, 

discriminate against Petitioner and deny Petitioner 

its constitutional rights to 

uniformity, equal protection and due process of law. 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an 

Order reducing and recapping the 2025 taxable value of Petitioner's Parcel # 

01004005. from $411,700 to $184,490, and requiring Respondent to pay Petitioner 

the refunds attributable to such reductions, plus interest and costs. 

Respectfully submitted, 

LAW OFFICE OF AARON M. FALES, P.C. 

Attorney for Petitioner 

By: 

Lm zs 2 

Aaron M. Fales (P72864) 

330 Hamilton Row, Ste 350 

Birmingham, MI 48009 

(248) 767-9840 

Dated: June 12, 2025

EXHIBIT D

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

DIRECTOR 

LANSING 

Broadway Detroit Development Il LLC, 

Petitioner, 

MICHIGAN TAX TRIBUNAL 

ENTIRE TRIBUNAL 

v 

MTT Docket No. 25-002384 

City of Detroit, 

Respondent. 

ORDER OF DISMISSAL 

The Tribunal has reviewed the file in the above-captioned case and finds that: 

The petition was not filed by May 31 or the next business day after the Tribunal offices 

were closed. See MCL 205.735a(6). 

Therefore, 

IT IS ORDERED that the case is DISMISSED. 

This order resolves all pending issues and closes the 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, 

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

MTT Docket No. 25-002384 

Page 2 of 6 

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: 

_ 7a lice LA 

A 

J PY. Fy 

Patricia L. Halm, Tribunal Chair 

Entered: August 20, 2025 

PROOF OF SERVICE 

| 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

EXHIBIT E

ICHIGAN LEGISI 

M 

Michigan Compiled Laws Complete Through PA 12 of 2025 

Senate adjourned until Tuesday, September 9, 2025 10:00 AM 

House adjourned until Tuesday, September 9, 2025 1:30 PM 

Home 

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MCL - Section 205.735a 

Download Section 

Chapter 205 

Act 186 of 1973 

186-1973-3 

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p 

TAX TRIBUNAL ACT (EXCERPT) 

Act 186 of 1973 

205.735a Applicability after December 31, 2006; de novo proceedings; 

jurisdiction in assessment disputes; filing of petition; amendment of petition 

or answer; representation; "designated delivery service" defined. 

Sec. 35a. 

(1) The provisions of this section apply to a proceeding before the tribunal that is 

commenced after December 31, 2006. 

(2) A proceeding before the tribunal is original and independent and is 

considered de novo. 

(3) Except as otherwise provided in this section or by law, for an assessment 

dispute as to the valuation or exemption of property, the assessment must be 

protested before the board of review before the tribunal acquires jurisdiction of the 

dispute under subsection (6). 

(4) In the 2007 tax year and each tax year after 2007, all of the following apply: 

(a) For an assessment dispute as to the valuation or exemption of property

appealed directly to the tribunal without protest before the board of review as 

provided in subsection (6), if a statement of assessable property is filed under 

section 19 of the general property tax act, 1893 PA 206, MCL 211.19, prior to the 

commencement of the board of review for the tax year involved. 

(c) For an assessment dispute as to the valuation of property that is subject to 

taxation under 1974 PA 198, MCL 207.551 to 207.572, the commercial 

redevelopment act, 1978 PA 255, MCL 207.651 to 207.668, the enterprise zone act, 

1985 PA 224, MCL 125.2101 to 125.2123, the technology park development act, 

1984 PA 385, MCL 207.701 to 207.718, the obsolete property rehabilitation act, 

2000 PA 146, MCL 125.2781 to 125.2797, the commercial rehabilitation act, 2005 

PA 210, MCL 207.841 to 207.856, or 1953 PA 189, MCL 211.181 to 211.182, the 

assessment may be protested before the board of review or appealed directly to the 

tribunal without protest before the board of review as provided in subsection (6). 

This subdivision does not apply to property that is subject to the neighborhood 

enterprise zone act, 1992 PA 147, MCL 207.771 to 207.786. 

(5) For a dispute regarding a determination of a claim of exemption of a principal 

residence or qualified agricultural property for a year in which the July or December 

board of review has authority to determine a claim of exemption for a principal 

residence or qualified agricultural property, the claim of exemption shall be 

presented to either the July or December board of review before the tribunal 

acquires jurisdiction of the dispute. For a special assessment dispute, the special 

assessment shall be protested at the hearing held for the purpose of confirming the 

special assessment roll before the tribunal acquires jurisdiction of the dispute. 

(6) The jurisdiction of the tribunal in an assessment dispute as to property 

classified under section 34c of the general property tax act, 1893 PA 206, MCL 

211.34c, as commercial real property, industrial real property, developmental real 

property, commercial personal property, industrial personal property, or utility 

personal property is invoked by a party in interest, as petitioner, filing a written 

petition on or before May 31 of the tax year involved. The jurisdiction of the tribunal 

in an assessment dispute as to property classified under section 34c of the general 

property tax act, 1893 PA 206, MCL 211.34c, as agricultural real property, 

residential real property, timber-cutover real property, or agricultural personal 

property is invoked by a party in interest, as petitioner, AL a written REtaET on or 

befors 

2 

duly cil of the tax year tye 

all 

0 

natter: 

35 

days 

afte 

nal 

decision, 

ruli 

> 

ation. Afi p— ps contested 

tax bill shall be made within 60 days after mailiig by the assessment district 

treasurer and the appeal is limited solely to correcting arithmetic errors or mistakes 

and is not a basis of appeal as to disputes of valuation of the property, the

(a) The petition is postmarked by the United States postal service on or before 

the expiration of that time period. 

(b) The petition is delivered in person on or before the expiration of that time 

period. 

(c) The petition is given to a designated delivery service for delivery on or before 

the expiration of that time period and the petition is delivered by that designated 

delivery service or, if the petition is not delivered by that designated delivery 

service, the petitioner establishes that the petition was given to that designated 

delivery service for delivery on or before the expiration of that time period. 

(8) A petition required to be filed by a day during which the offices of the tribunal 

are not open for business shall be filed by the next business day. 

(9) A petition or answer may be amended at any time by leave of the tribunal and 

in compliance with its rules. If a tax was paid while the determination of the right to 

the tax is pending before the tribunal, the taxpayer may amend his or her petition to 

seek a refund of that tax. 

(10) A person or legal entity may appear before the tribunal in his or her own 

behalf or may be represented by an attorney or by any other person. 

(11) As used in this section, "designated delivery service" means a delivery 

service provided by a trade or business that is designated by the tribunal for 

purposes of this subsection. The tribunal shall issue a tribunal notice not later than 

December 31 in each calendar year designating not less than 

1 delivery service for 

the immediately succeeding calendar year. The tribunal may designate a delivery 

service only if the tribunal determines that the delivery service meets all of the 

following requirements: 

(a) Is available to the general public. 

(b) Is at least as timely and reliable on a regular basis as the United States postal 

service. 

(c) Records electronically to a database kept in the regular course of business or 

marks on the petition the date on which the petition was given to the delivery 

service for delivery. 

(d) Any other requirement the tribunal prescribes. 

History: Add. 2006, Act 174, Imd. Eff. May 30, 2006 ;-- Am. 2008, Act 125, Imd. Eff. May 

9, 2008

PROOF OF SERVICE 

STATE OF MICHIGAN 

) 

) ss. 

COUNTY OF OAKLAND 

) 

Aaron M. Fales, being duly sworn, deposes and says that on September 5, 2025 he served a 

copy of Petitioner’s Motion for Reconsideration by Email to Respondent 

at the following 

Address: 

Kevin Richard (P43417) 

Coleman A. Young Bldg. 

2 Woodward Ave., Suite 500 

Detroit, MI 48226 

313-237-3061 

richkc@detroitmi.gov 

Aaron M. Fales

sy 

Gmail 

Aaron Fales <aaron@afaleslaw.com> 

Broadway - Motion for reconsideration 25-002384 

1 message 

Aaron Fales <aaron@afaleslaw.com> 

Fri, Sep 5, 2025 at 3:27 PM 

To: Kevin Richard <richkc@detroitmi.gov> 

Please see Attached which is going out today to the MTT. 

-Aaron 

= Motion for Reconsideration - Broadway.pdf 

4949K

le Ese 

LL 

ed asinat 

NA teen

Aaron M. Fales, P.C. 

330 Hamilton Row, Ste. 350 

Birmingham, MI 48009 

NM, BEL{IET.EEN

PO. Roe 

J 

CC

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