Joint Motion for Abeyance.pdf
Comerica Ahoc LLC, Petitioner Vs. City Of Auburn Hills, Respondent · 25-001845-TT
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STATE OF MICHIGAN MICHIGAN TAX TRIBUNAL COMERICA AHOC LLC, Petitioner, v CITY OF AUBURN HILLS, Respondent. MTT Docket No. 25-001845 Parcel No. 02-14-25-226-001 _____________________________________________________________________________/ MARK T. MCMERRELL RYAN LLC Representative for Petitioner 600 Superior Avenue E, Suite 1810 Cleveland, OH 44114 (216) 685-9448 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 _____________________________________________________________________________/ JOINT MOTION TO HOLD APPEAL IN ABEYANCE PENDING MTT DOCKET NO. 24-002164 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 commercial property located in Oakland County—parcel no. 02-14-25-226-001. 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. 24-002164—an appeal concerning the 2024 tax year. 3. The above captioned 2025 appeal is ready to be placed on a Prehearing General Call and Order of Procedure.
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2 4. However, as of the filing of the above captioned Motion, the 2024 reiteration (MTT docket no. 24-002164) has not yet been resolved. The 2024 reiteration is proceeding in accordance with the March 16-31, 2026 Prehearing General Call with valuation disclosures and prehearing statements due November 17, 2025. Accordingly, the 2024 reiteration will likely not proceed to hearing until the spring of next year and a Final Opinion and Judgment will likely not be rendered until Fall 2026 at the earliest. 5. A Final Opinion and Judgment from the Tribunal regarding MTT docket no. 24- 002164 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- 002164 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 joint Motion to hold the above captioned appeal in abeyance pending the resolution of its 2024 iteration, MTT docket no. 24-002164. WHEREFORE, the parties respectfully request the Tribunal enter an Order holding the above captioned appeal in abeyance pending the resolution of MTT docket no. 24-002164.
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3 Respectfully submitted, /s/Mark T. McMerrell (w/permission) /s/Laura M. Hallahan MARK T. MCMERRELL RYAN LLC Representative for Petitioner Dated: October 17, 2025 LAURA M. HALLAHAN (P42101) SETH A. O’LOUGHLIN (P80257) KELSEA M. MELCHER (P85821) HALLAHAN & ASSOCIATES, P.C. Attorneys for Respondent Dated: October 17, 2025