Petitioner - Prehearing Statement.pdf
Geosebeck Holdings Limited Partnership, Petitioner Vs. Township Of Clinton, Respondent · 25-002212-TT
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 DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN ADMINISTRATIVE HEARING SYSTEM MICHIGAN TAX TRIBUNAL Petitioner: GROESBECK HOLDINGS LIMITED PARTNERSHIP, v MTT Docket No. 25-002212 Respondent: CHARTER TOWNSHIP OF CLINTON X PETITIONER’S PREHEARING STATEMENT __ RESPONDENT’S PREHEARING STATEMENT Petitioner’s Representative: Brian E. Etzel (P54905) Respondent’s Representative: Laura M. Hallahan (P42101), Seth A. O’Loughlin (P80257) & Kelsea M. Melcher (P85821) 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: Paracel Number: 16-11-33-126-006 Tax Year True Cash Value Assessed Value Taxable Value 2025 $3,419,000 $1,709,500 $1,172,647 B. Petitioner’s contentions of TCV, state equalized value (SEV), and TV for each parcel and tax year at issue: Paracel Number: 16-11-33-126-006 Tax Year True Cash Value Assessed Value Taxable Value 2025 $1,000,000 $500,000 $500,000 C. Amounts in dispute for the tax year(s) at issue: Paracel Number: 16-11-33-126-006 Tax Year True Cash Value Assessed Value Taxable Value 2025 $2,419,000 $1,209,500 $672,647
Page 2
MTT Docket No. 25-002212 Page 2 of 4 2 II. TAX INFORMATION: A. Have taxes been paid for each property for each tax year at issue? X 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): None. B. Classification of each property for each tax year at issue (by parcel number): General Commercial Use. C. Current use of each property for each tax year at issue, if different than above (by parcel number): N/A 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): N/A 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?): Petitioner’s valuation of the Property’s TCV, AV, and TV as of December 31, 2024. F. If non-uniformity of assessment is alleged, what evidence will you rely upon in support of your contentions? N/A IV. ISSUES TO BE LITIGATED: A. Factual Issues: TCV, AV, and TV of Petitioner’s Property as of December 31, 2024.
Page 3
MTT Docket No. 25-002212 Page 3 of 4 3 B. Legal Issues: Same as the factual issue. V. DO THE PLEADINGS NEED TO BE AMENDED TO CONFORM TO THE EVIDENCE? ___ Yes X No A. If yes, state all necessary amendments (a motion may be required to amend the pleadings): N/A VI. ARE THERE CONSOLIDATION ISSUES? ___ Yes X 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): N/A VII. PENDING OR ANTICIPATED MOTIONS OR OUTSTANDING DISCOVERY ISSUES, IF ANY: A. Motions: No motions unless necessary in response to Respondent’s valuation disclosure. B. Discovery: Petitioner requests the opportunity to pursue limited post-valuation discovery. 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: A. Brandon L. Ellis, MAI, Vice President, Value Trends, Inc. will testify regarding his opinion of value for the subject property as of the relevant date of value and any other relevant topic within his knowledge. Mr. Ellis can be reached c/o Brian E. Etzel, 380 North Old Woodward Ave., Suite 300, Birmingham, MI 48009. B. David Tisdale, David M. Tisdale & Co. (c/o Brian E. Etzel, 380 North Old Woodward Ave., Suite 300, Birmingham, MI 48009), will testify regarding the operation, use, acquisition, income/expense, occupancy and condition of the subject property, along with any other relevant topic within his knowledge. C. David Amir, Facilities Assessment and Compliance Department Manager for ASTI Environmental, 10448 Citation Drive, Suite 100, Brighton, Michigan 48116, will
Page 4
MTT Docket No. 25-002212 Page 4 of 4 4 testify regarding his inspection of the subject property, potential environmental conditions affecting the subject property, including, but not limited to, mold, the remediation of such conditions, including the potential demolition of the building located on the subject property, and any other related or relevant matters within his knowledge or expertise. D. Nick Whitehurst, True North Asphalt, LLC, 1241 E. 11 Mile Road, Madison Heights, MI 48071 who would testify concerning the written estimate(s) his company prepared for parking lot removal, asphalt replacement, and related work at the subject property. E. Rick Dodaj, Silicoat Roofing, 1490 Premier Drive, Suite F, Troy, MI 48084 who would testify concerning the written estimate(s) his company prepared for roof repair, replacement, restoration and related work at the subject property, and subsequent completion of that work. F. Rajaei Habbas, RT Services & Management, 24650 N. Cromwell Dr, Frankling, MI 48025 who would testify concerning the written estimate(s) his company prepared for removal of tile, carpet, drywall, ceiling, and related items at the subject property. G. Matt Wallace AICP, Assistant Director, Clinton Charter Township Planning & Community Development Department, or another representative(s) of Clinton Charter Township, who would testify concerning the subject property’s permitted and non- permitted uses under the Township’s zoning ordinance, including self-storage. H. Petitioner reserves the right to call any witness listed by Respondent. I. Any rebuttal witnesses. J. Any witness required to authenticate any documents. K. Petitioner reserves the right to add witnesses as he/she becomes known to Petitioner. IX. NUMBER OF DAYS REQUIRED FOR HEARING: 3 to 4 days. X. DISCLOSURE AND TAXATION OF COSTS: None. WILLIAMS, WILLIAMS, RATTNER & PLUNKETT, P.C. Dated: September 8, 2026 By: /s/ Brian E. Etzel Brian E. Etzel (P54905) Attorneys for Petitioner 380 N. Old Woodward Avenue, Suite 300 Birmingham, MI 48009 (248) 642-0333 beetzel@wwrplaw.com