Full record / Joint Motion for Abeyance (25-001696).pdf

Joint Motion for Abeyance (25-001696).pdf

Bc Equities LP, Petitioner Vs. City Of Battle Creek, Respondent · 25-001696-TT

← View full record

Text extracted from the reviewed PDF, organized by page. OCR and reading order may contain errors; confirm details in the PDF below.

Page 1

62356418.1 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

BC EQUITIES LP, 

 

 

 

Petitioner, 

 

v 

 

CITY OF BATTLE CREEK, 

 

Respondent.

 

 

 

MTT Docket No. 25-001696 

 

 

 

_____________________________________________________________________________/ 

 

DANIEL L. STANLEY (P57052) 

HONIGMAN LLP 

Attorneys for Petitioner 

222 N. Washington Square, Suite 400 

Lansing, MI 48933 

(517) 377-0714 

DStanley@honigman.com

C. MARCEL STOETZEL, III (P61912) 

CITY ATTORNEY’S OFFICE 

Attorneys for Respondent 

10 North Division Street, Suite 207 

Battle Creek, MI 49014 

(269) 966-3385 

cmstoetzel@battlecreekmi.gov

_____________________________________________________________________________/ 

 

 

JOINT MOTION TO HOLD APPEAL IN ABEYANCE PENDING 

MTT DOCKET NO. 24-001329 

 

The parties, by and through their respective counsel, state the following in support of the 

above captioned Motion: 

1. 

The above captioned appeal concerns the 2025 valuation of an office property – 

Parcel No. 0253-00-037-1- located in the City of Kalamazoo. 

2. 

With the exception of the tax year at issue, the parties, property, and issues raised 

in the above captioned appeal are, based on the pleadings, in essence identical to those at issue in 

MTT Docket No. 24-001329 – an appeal concerning the 2024 tax year. 

3. 

The above captioned 2025 appeal has been placed on a two-week Prehearing 

General Call commencing July 01, 2026, with valuation disclosures due March 4, 2026.

Page 2

62356418.1 

2

4. 

However, as of the filing of the above captioned Motion, the 2024 matter (MTT 

Docket No. 24-001329) has not yet been resolved. A Prehearing Conference is scheduled for 

December 1-15, 2025, at which time the 2024 matter will be scheduled for hearing. Based on the 

availability of the parties’ expert witnesses, the parties expect the 2024 matter will not be set for 

hearing until early 2026. Accordingly, a Final Opinion and Judgment will likely not be rendered 

until Summer 2026 at the earliest. 

5. 

A Final Opinion and Judgment from the Tribunal regarding MTT Docket No. 24-

001329 could impact this 2025 appeal and the parties’ desire to proceed with this appeal. Thus, it 

could potentially be a waste of time and resources for the parties and the Tribunal to proceed with 

the above captioned appeal when the prior 2024 appeal remains pending. 

6. 

To proceed with this case before a resolution regarding MTT Docket No. 24-

001329 has been reached would likely not constitute an efficient administration of justice. 

7. 

Proceeding with the above captioned appeal will require the parties and the 

Tribunal to expend substantial resources which may ultimately be unnecessary. Placing the above 

captioned appeal in abeyance at this juncture before substantial time and resources have been spent 

– including, but not limited to, the preparation of prehearing statements and valuation disclosures 

– is in the interest of efficiency to all parties involved and judicial economy. 

8. 

As evidenced above, there is good cause for granting this Motion to hold the above 

captioned appeal in abeyance pending the resolution of its 2024 matter, MTT Docket No. 24-

001329. 

WHEREFORE, the parties respectfully request the Tribunal enter an Order holding the 

above captioned appeal in abeyance pending the resolution of MTT Docket No. 24-001329.

Page 3

62356418.1 

3

Respectfully submitted, 

HONIGMAN LLP 

 

/s/ DANIEL L. STANLEY _ 

DANIEL L. STANLEY (P57052) 

Attorneys for Petitioner 

222 N. Washington Square, Suite 400 

Lansing, MI 48933 

(517) 377-0714 

DStanley@honigman.com 

 

 

Dated: October 6, 2025

CITY ATTORNEY’S OFFICE 

 

/s/ C. MARCEL STOETZEL, III __ 

C. MARCEL STOETZEL, III (P61912) 

Attorneys for Respondent 

10 North Division Street, Suite 207 

Battle Creek, MI 49014 

(269) 966-3385 

cmstoetzel@battlecreekmi.gov 

 

Dated: October 6, 2025

PDF reading copy

← View full record