MTA 26 Response_Chesterfield 5 24_FINAL.pdf
Chesterfield 5 LLC, Petitioner Vs. Township Of Clinton, Respondent · 25-002524-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Chesterfield 5, LLC, Petitioner, v Clinton Charter Township, Respondent. Docket No. 25-002524 _____________________________________________________________________________/ JOSHUA T. SHILLAIR (P72674) COLLIERS INTERNATIONAL Attorney for Petitioner 2 Corporate Drive, Suite 300 Southfield, MI 48076 (248) 226-1632 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 RESPONSE TO PETITIONER’S ENTIRE TRIBUNAL MOTION TO AMEND TO ADD SUBSEQUENT YEAR Respondent, Clinton Charter Township, by and through its attorneys, Hallahan & Associates, P.C., responds to the allegations made in Petitioner’s Motion to Amend as follows: 1. Respondent admits the allegations in Paragraph 1. 2. Respondent neither admits nor denies the allegations in Paragraph 2 for the reason that no allegations are set forth and thus no responsive pleading is required. 3. Respondent neither admits nor denies the allegations in Paragraph 3 for the reason that no allegations are set forth and thus no responsive pleading is required. 4. Respondent neither admits nor denies the allegations in Paragraph 4 for the reason that no allegations are set forth and thus no responsive pleading is required. 5. Respondent admits the allegations in Paragraph 5.
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Response to Petitioner’s Motion to Amend Page 2 of 3 6. Respondent neither admits nor denies the allegations in Paragraph 6 for the reason that no allegations are set forth and thus no responsive pleading is required. 7. Respondent acknowledges Petitioner’s belief as to the issues relevant to this appeal but denies those issues have merit. Respondent further denies Petitioner is entitled to any relief. 8. Respondent acknowledges Petitioner’s belief as to issues with the 2025 and 2026 tax year but denies any issues with said years. 9. Respondent neither admits nor denies the allegations in Paragraph 9 for the reason that no allegations are set forth and thus no responsive pleading is required. 10. The values for the property identified above as established by Respondent’s Board of Review are: Tax Year True Cash Value Assessed Value Taxable Value 2025 $692,800 $346,400 $310,537 2026 $868,600 $434,300 $318,921 11. Respondent contends that the values for the property identified above are: Tax Year True Cash Value State Equalized Value Taxable Value 2025 $692,800 $346,400 $310,537 2026 $868,600 $434,300 $318,921 12. The values in dispute for the property identified above are: Tax Year True Cash Value State Equalized Value Taxable Value 2025 $0 $0 $0 2026 $0 $0 $0 13. Respondent acknowledges the relief requested by Petitioner via Paragraph 13 but denies the Petitioner is entitled to said relief. Furthermore, the assessed, state equalized and/or taxable values do not exceed permitted amounts, do not exceed the percentage for true cash value permitted by law, were correctly determined and are based upon correct application of proper principles, and the values and Respondent’s mode of assessment are non-discriminatory and constitutional. Respondent restates the affirmative defenses set forth in its Answer to Petition herein. 14. Respondent admits there are no facts that support Petitioner’s request for relief. WHEREFORE, Respondent, Clinton Charter Township, requests the Tribunal enter an Order denying Petitioner’s Motion to Amend and dismissing the appeal
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Response to Petitioner’s Motion to Amend Page 3 of 3 /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: June 22, 2026 (248) 731-3089 PROOF OF MAILING On the date below I sent by electronic mail a copy of the foregoing Respondent’s Answer to Petition and Affirmative Defenses to: Joshua T. Shillair Colliers International joshua.shillair@colliers.com I declare that the statement above is true to the best of my information, knowledge and belief. /s/ Kelsea M. Melcher________________ Dated: June 22, 2026 Kelsea M. Melcher