Monroe Capital Holdings LLC MTT# 24-004087 prehearing statement.pdf
Monroe Capital Holding LLC, Petitioner V City Of Detroit, Respondent · 24-004087-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Petitioner: MONROE CAPITAL HOLDINGS LLC v Respondent: CITY OF DETROIT MTT Docket No.: 24-004087 Petitioner’s Prehearing Statement Respondent’s Prehearing Statement Petitioner’s representative: Jerome Morgan 15450 Dale Street Detroit, MI. 48223 (313) 363-1682 kenlallen33@gmail.com Respondent’s representative: Kevin C Richard (P43417) City of Detroit Law Department Coleman A Young Municipal Center 2 Woodward Avenue, Suite 500 Detroit, Michigan 48226 (313) 237-3061 richkc@detroitmi.gov 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 Boards of Review: Parcel Number Year TCV AV TV 21043743.009 2023 $447,400 $223,700 $46,124 21043743.009 2024 $477,600 $238,800 $48,430 21043743.013 2023 $487,200 $243,600 $47,665 21043743.013 2024 $520,200 $260,100 $51,599 21043743.014 2023 $413,800 $206,900 $43,753 21043743.014 2024 $441,600 $220,800 $45,940 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 21043743.009 2023 $447,400 $223,700 $46,124 21043743.009 2024 $477,600 $238,800 $48,430 21043743.013 2023 $487,200 $243,600 $47,665 21043743.013 2024 $520,200 $260,100 $51,599 21043743.014 2023 $413,800 $206,900 $43,753 21043743.014 2024 $441,600 $220,800 $45,940
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MTT Docket No.: 24-004068 Respondent’s Prehearing Statement, Page 2 of 5 C. Petitioner’s contentions of TCV, 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 21043743.009 2023 $447,400 $223,700 $46,124 21043743.009 2024 $477,600 $238,800 $48,430 21043743.013 2023 $487,200 $243,600 $47,665 21043743.013 2024 $520,200 $260,100 $51,599 21043743.014 2023 $413,800 $206,900 $43,753 21043743.014 2024 $441,600 $220,800 $45,940 D. Amounts in dispute for the tax year(s) at issue: Parcel Number Year TCV SEV TV 21043743.009 2023 $0 $0 $0 21043743.009 2024 $0 $0 $0 21043743.013 2023 $0 $0 $0 21043743.013 2024 $0 $0 $0 21043743.014 2023 $0 $0 $0 21043743.014 2024 $0 $0 $0 I. 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 for the tax year at issue. B. Classification of each property for each tax year at issue (by parcel number): 21043743.009 2023 residential condominium 21043743.009 2024 residential condominium 21043743.013 2023 residential condominium 21043743.013 2024 residential condominium 21043743.014 2023 residential condominium 21043743.014 2024 residential condominium
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MTT Docket No.: 24-004068 Respondent’s Prehearing Statement, Page 3 of 5 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 the subject properties were errantly uncapped, however, were subsequently recapped by Respondent’s Board of Review as indicated by the attached parcel record cards for each of the subject properties. F. If non-uniformity of assessment is alleged, what evidence will you rely upon in support of your contentions? Respondent does not believe there are any valid non-uniformity of assessment issues. G. Affirmative Defenses (if any): Petitioner lacks standing to bring this action. IV. ISSUES TO BE LITIGATED: A. Factual Issues: Does the taxable value of the subject property still need to be recapped? Why hasn’t Petitioner dismissed this matter even though he has received the relief he wanted and has been requested to do so? B. Legal Issues: What is the taxable value of the subject property? Does Petitioner have standing? V. DO THE PLEADINGS NEED TO BE AMENDED TO CONFORM TO THE EVIDENCE? ☐ Yes ☒ No
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MTT Docket No.: 24-004068 Respondent’s Prehearing Statement, Page 4 of 5 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): VII. PENDING OR ANTICIPATED MOTIONS OR OUTSTANDING DISCOVERY ISSUES, IF ANY: A. Motions: None at this time. B. Discovery: None at this time 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: • KAKIA STEPHEN, Supervisor Residential, Office of the Chief Financial Officer, Office of the Assessor, City of Detroit, Coleman A Young Municipal Center, 2 Woodward Avenue, Suite 804, Detroit, Michigan 48226. Ms. Stephen may be called to testify regarding any testimony necessary for Respondent to make its case, and rebuttal testimony as necessary. • Any and all witnesses listed by Petitioner. • Any and all necessary rebuttal witnesses. • Any and all custodians of the records. As provided by TTR 237, 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 X. DISCLOSURE AND TAXATION OF COSTS: Respondent reserves the right to request costs. CITY OF DETROIT /s/ Kevin C. Richard By: Kevin C. Richard (P43417) City of Detroit Law Department
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MTT Docket No.: 24-004068 Respondent’s Prehearing Statement, Page 5 of 5 Coleman A. Young Municipal Center 2 Woodward Avenue, Suite 500 Detroit, MI 48226 Date: September 18, 2025 (313) 237-3061 Failure to file and exchange this prehearing statement, as required by the Tribunal, shall result in the commencement of the prehearing conference as a show cause hearing. See TTR 231 and 237. See also MCL 205.732.