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Petitioner - Prehearing Statement.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 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

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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.

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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

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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

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