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Maple Orchard Spbr, LLC Petitioner Vs. Township Of West Bloomfield Respondent · 26-000796-TT

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STATE OF MICHIGAN 

DEPART ENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

MAPLE ORCHARD SPBR, LLC, 

 

 

 

Petitioner, 

 

v 

 

WEST BLOOMFIELD TOWNSHIP, 

 

 

 

Respondent. 

 

 

 

MTT Docket No. 26-000796 

 

 

_____________________________________________________________________________/ 

 

JEROME P. PESICK (P29039) 

JASON C. LONG (P59244) 

WILLIAMS, WILLIAMS, RATTNER & 

PLUNKETT, P.C. 

Attorneys for Petitioner 

380 N. Old Woodward Avenue, Suite 300 

Birmingham, MI 48009 

(248) 642-0333 

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 

_____________________________________________________________________________/ 

 

ANSWER TO PETITION 

AND 

AFFIRMATIVE DEFENSES 

 

ANSWER 

 

Respondent, West Bloomfield Township, by and through its attorneys, Hallahan & 

Associates, P.C., responds to the allegations made in Petitioner’s Petition as follows: 

The Parties 

1. 

Respondent lacks knowledge or information sufficient to respond to the truth of the 

allegations set forth in Paragraph 1 and, therefore, leaves Petitioner to its proofs. 

 

2. 

Respondent admits the allegations in Paragraph 2. 

 

The Subject Property 

 

3. 

Respondent denies that the address identified in Paragraph 3 matches the address 

identified on the 2026 assessment records for parcel no. X-18-27-476-095. Respondent lacks the 

knowledge or information sufficient to respond to the truth of the remaining allegations set forth 

in Paragraph 3 and, therefore, leaves Petitioner to its proofs.

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2

 

 

4. 

Respondent admits the allegations in Paragraph 4. 

 

5. 

Respondent admits the allegations in Paragraph 5. 

 

The 2026 Assessment 

 

6. 

Respondent admits the allegations in Paragraph 6. 

 

7. 

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 

2026 

$4,771,220 

$2,385,610 

$2,385,610 

 

8. 

 Respondent contends that the values for the property identified above are: 

 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$4,771,220 

$2,385,610 

$2,385,610 

 

9. 

 The values in dispute for the property identified above are: 

 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$0 

$0 

$0 

 

10. 

Respondent acknowledges Petitioner’s belief as to a dispute in the subject 

property’s valuation but denies Petitioner’s contentions of value have merit and further denies 

Petitioner is entitled to relief. Respondent admits there is no issue relating to “additions” or 

“losses” but denies Petitioner has a right to raise such issues at a later date. 

 

11. 

 Respondent denies the allegations in Paragraph 11, including subparts (a)-(d), for 

the reason that the same are untrue. In further answer, the assessed, state equalized and/or taxable 

values do not exceed permitted amounts, do not exceed the percentage of 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. 

 

12. 

Respondent admits the subject property’s assessment is uniform but denies it 

overestimated the subject property’s value or otherwise misapplied the General Property Tax Act. 

 

Conclusion and Request for Relief 

 

13. 

Respondent acknowledges the relief requested by Petitioner in the final paragraph 

of its Petition but denies that Petitioner is entitled to said relief for the reasons set forth above.

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WHEREFORE, Respondent, West Bloomfield Township, requests the Tribunal dismiss 

the Petition, affirm Respondent’s assessed and taxable values, subject to county and state 

equalization, and award Respondent its costs and attorney fees. 

 

HALLAHAN & ASSOCIATES, P.C. 

 

/s/Laura M. Hallahan______________ 

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: July 30, 2026 

 

 

 

(248) 731-3089 

 

 

 

AFFIRMATIVE DEFENSES 

 

Respondent, West Bloomfield Township, asserts the following affirmative defenses: 

1. 

Petitioner fails to allege specific and sufficient facts to set forth a cause of action 

against Respondent and to support its claim for relief. 

2. 

The Tribunal is charged with finding a property’s true cash value to determine the 

property’s lawful assessment. Alhi Development Co v Orion Twp, 110 Mich App 764, 767 (1981). 

3. 

Petitioner has the burden of establishing the property’s true cash value. See 

MCL 205.737(3) and Kern v Pontiac Twp, 93 Mich App 612 (1974). 

4. 

Petitioner has failed to allege specific and sufficient facts to establish fraud, error 

of law, discrimination, application of wrong principles, or illegality on the part of Respondent or 

its agents. 

5. 

Petitioner has failed to allege that the mode and method of assessing the subject 

property fails to conform to the mode and method applied in the case of all other properties in 

Respondent’s taxing unit for the year in question. 

6. 

Petitioner has failed to show that any factor other than fifty percent (50%) was 

applied to the true cash value of Petitioner’s property, as well as all others, to arrive at the 

respective assessments appearing on the roll, and also fails to allege specific and sufficient facts 

to support its allegations that the property’s taxable value is improper. 

7. 

Petitioner asks the Tribunal to grant it preference by application of a self-chosen 

method of assessment contrary to the intent, purpose and law of this State.

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8. 

Petitioner, in essence, asks the Tribunal to grant it an illegal preference by 

application of a method of assessment different from that employed in the assessment of other 

properties in Respondent’s taxing unit. 

9. 

Petitioner, in essence, seeks by petition to challenge the process of county and state 

equalization as to which it has no legal standing and cannot maintain a cause of action. 

10. 

Any decrease in the value of Petitioner’s property was a result of its own intentional 

acts and/or negligence and cannot be allowed to reduce Petitioner’s otherwise equitable tax burden. 

11. 

Respondent has properly and lawfully assessed Petitioner’s property and 

established its taxable value in accordance with statutory and constitutional requirements. 

12. 

Petitioner has failed to pursue its appeal in a timely fashion. 

13. 

Respondent reserves the right to raise additional affirmative defenses as the same 

may become known to it during the course of these proceedings. 

 

HALLAHAN & ASSOCIATES, P.C. 

 

 

/s/ Laura M. Hallahan_______________ 

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: July 30, 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: 

 

Jerome P. Pesick 

jpesick@wwrplaw.com 

 

Jason C. Long 

jlong@wwrplaw.com 

 

I declare that the statement above is true to the best of my information, knowledge and belief. 

 

 

/s/ Kelsea M. Melcher_______________ 

Dated: July 30, 2026 

Kelsea M. Melcher

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