25-002950.pdf

Lake Forest Trail Holdings LLC, Petitioner Vs. Township Of Green Oak, Respondent · 25-002950-TT

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RECEIVED 

Since 1973 

WERT aos\wIWIR| P 

MICHIGAN Tax TRIB yy, Wise Willams Rtrer & Plurk, BC. 

Attorneys and Counselors 

380 North Old Woodward Avenue 

Suite 300 

August 21, 2025 

Birmingham, Michigan 48009 

Tel: (248) 642-0333 

Fax: (248) 642-0856 

Clerk 

Michigan Tax Tribunal 

P.O. Box 30232 

Lansing, MI 48909 

RE: 

Lake Forest Trail Holdings, LLC v. Green Oak Twp. 

Michigan Tax Tribunal Docket No. 25-002950 

Dear Clerk: 

Enclosed with this letter for filing with the Tribunal are Petitioner's Motion 

for Reconsideration of Order of Dismissal dated August 20, 2025, and 

a Proof of 

Service. 

Also enclosed are a check for the motion fee and extra copies of the filings. 

Please time-stamp the extra copies and return them to me in the stamped, addressed 

envelope enclosed. 

Thank you and please contact me with any questions or concerns. 

» 

’ 

Sincerely, 

- 

<9 

= 

{ 

~~ 

£7 

{ 

= 

: 

) 

/ 

[ Jason C. Long ot 

ce! 

Jerome P. Pesick, Esq.

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

LAKE FOREST TRAIL HOLDINGS, LLC, 

Petitioner, 

MOAHR Docket No. 25-002950 

v. 

TOWNSHIP OF GREEN OAK, 

Respondent. 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

Attorneys for Petitioner 

Proof of Service

Proof of Service 

Monica Athanas states that she personally served the Entire Tribunal Property 

Tax Petition, Notice of Docket Number, Order of Dismissal, and Petitioner's Motion for 

Reconsideration of Order of Dismissal dated August 20, 2025, on the persons identified 

below, by the means specified, on August 21, 2025. 

Certified Mail 

First-Class Mail 

Clerk 

Clerk 

Secretary of School Board 

Green Oak Township 

Livingston County 

Brighton Area Schools 

10001 Silver Lake Road 

Brighton, MI 48116 

Assessor 

Green Oak Township 

10001 Silver Lake Road 

Brighton, MI 48116 

200 E. Grand River 

Howell, MI 48843 

Director of Equalization 

Livingston County 

304 E Grand River Ave 

Howell, MI 48843 

125 South Church Street 

Brighton, MI 48116 

State Treasurer 

Michigan Dep't of Treasury 

Austin Building 

430 W. Allegan 

Lansing, MI 48922 

Stephanie Simon Morita, Esq. 

Rosati, Schultz, Joppich 

& Amtsbuechler, PC 

27555 Executive Dr., Ste. 250 

Farmington Hills, MI 48331 

A 

Mohica Athanas 

q 

This Proof of Service was signed and sworn before me on August 21, 2025. 

Su,

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

LAKE FOREST TRAIL HOLDINGS, LLC, 

Petitioner, 

MOAHR Docket No. 25-002950 

v. 

TOWNSHIP OF GREEN OAK, 

Respondent. 

Jerome P, Pesick (P29039) 

Jason C. Long (P59244) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

Attorneys for Petitioner 

Petitioner's Motion for Reconsideration 

of Order of Dismissal dated August 20, 2025 

Petitioner Lake Forest Trail Holdings, LLC, by and through its attorneys, 

Williams, Williams, Rattner & Plunkett PC, states as follows for its Motion for 

Reconsideration of Order of Dismissal dated August 20, 2025: 

1. 

This is an appeal involving the unlawful “uncapping” of the 2024 taxable 

value of Petitioner's real property located in Green Oak Township, Livingston County 

(the “Subject Property”).

year 2024 (the “2024 Valuation Appeal”). See Ex. A, Petitioner's “2024 Valuation 

Petition.” 

3. 

On May 22, 2025, Petitioner filed a Petition in Docket No. 25-001257 

challenging the Subject Property's true cash, assessed, and taxable values for tax 

year 2025 (the “2025 Valuation Appeal”). See Ex. B, Petitioner's “2025 Valuation 

Petition.” 

4. 

On June 30, 2025, Respondent issued a Notice of Uncapping explaining 

that Respondent had retroactively uncapped the Subject Property’s taxable value for 

tax year 2024 due to an alleged “transfer of ownership” that occurred in September 

2023. See Ex. C, Notice of Uncapping. Pursuant to MCL 211.27b(6), Petitioner had 

35 

days from 

the 

date 

of Respondent's 

Notice 

of Uncapping 

to challenge 

the 

uncapping by filing an appeal with the Tribunal. 

5. 

On July 30, 2025, Petitioner timely filed its Petition in this appeal 

challenging Respondent's unlawful uncapping of the Subject Property's taxable value 

for tax year 2024 on the grounds that the purported “transfer of ownership” was 

between commonly controlled entities under MCL 211.27a(7)(m), and therefore did 

not qualify as a “transfer of ownership” as that term is defined in MCL 211.27a(6). 

See Ex. D, Petitioner’s “2024 Uncapping Petition.” 

6. 

Petitioner's 

2024 

Uncapping 

Petition 

also 

restated 

Petitioner's

Petitioner 

has 

separately 

appealed 

the 

Subject 

Property's 

valuation for assessment purposes for tax years 2024 and 2025, 

which are pending under MTT Docket Nos. 24-000956 and 25- 

001257, respectively. The primary purpose of this Petition is to 

challenge 

the 

unlawful uncapping 

of the 

Subject 

Property's 

taxable value for tax year 2024, which was then carried forward 

to 

tax 

year 

2025. 

Petitioner 

incorporates 

by 

reference 

its 

contentions of value in the pending appeals to preserve all related 

claims. See Ex. D, Petitioner's 2024 Uncapping Petition. 

7. 

On August 20, 2025, the Tribunal issued an Order of Dismissal in this 

appeal, stating that the issue in this case is already pending in another appeal: 

The Tribunal has reviewed the file in the above-captioned case 

and finds that: The issue 

in this case 

is already pending in 

another case and, as such, this appeal is duplicative and shall be 

dismissed. 

Therefore, 

IT 

IS 

ORDERED 

that 

the 

case 

is 

DISMISSED. This order resolves all pending issues and closes the 

case. See Ex. E, Order of Dismissal dated August 20, 2025. 

8. 

Petitioner's challenge to Respondent's unlawful uncapping for tax year 

2024 in this appeal, however, is a distinct claim from the valuation claims made in 

Petitioner's valuation appeals for tax years 2024 and 2025. Petitioner's uncapping 

claim is therefore not “already pending in another case” and is not “duplicative.” 

WHEREFORE, Petitioner respectfully requests that this honorable Tribunal 

enter an Order granting Petitioner's Motion for Reconsideration of Order of Dismissal 

dated August 20, 2025, thereby reinstating this appeal. 

Respectfully submitted by: 

WILLIAMS, WILLIAMS, RATTNER

Exhibit A

RET, 

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

JMF Properites LLC 

Petitioner(s) 

, 

MICHIGAN TAX TRIBUNAL 

MTT Docket No. 

Green Oak Charter Township 

Respondent(s) 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

1. 

Property Parcel No: 4716-03-105-028 

(If more than one parcel is at issue, attach a completed Multiple Parcel! Pefition 

Form addressing all other parcels at issue.) 

2. 

The property identified above is X__real ___ personal. 

3. 

If more than one parcel of real property is under appeal, are the properties 

contiguous? ___Yes __ No. 

(If no, separate Petitions are required for each non- 

contiguous parcel.) 

4. 

Are all of the parcels of personal property located on a parcel of real property 

under appeal? ___ Yes __ No. 

(If no, separate Petitions are required for each 

parcel of personal property not located on a parcel of real property under 

appeal.) 

5. 

If parcels of personal property are under appeal, when were the personal 

property statements filed by parcel number (attach additional page if necessary): 

6. 

The property identified above is classified as 201 Commercial-Improved

MTT Docket No. 

Page 2 of 4 

8. 

10. 

11. 

12. 

13. 

If a protest was required and no protest was made, list the separate and specific 

facts upon which Petitioner reliss to invoke the Tribunal’s authority over the 

assessment or assessments at issue (attach additional page if necessary): 

N/A 

If the appeal was not submitted by the deadline for the filing of an appeal for the 

classification or classifications of the properties at issue (i.e., May 31 or July 31 

of the tax year involved), list the separate and specific facts upon which 

Petitioner relies to invoke the Tribunal's authority over the assessment or 

assessments at issue (attach additional page if necessary): 

N/A 

The property or properties at issue are located in Livingston 

County. The 

property or properties’ address is: 

11395 Izik's Way, Green Oak Charter Township, MI 

The assessment or assessments at issue were established by the (applicable 

local governmental unit): GreenOakCharterTwp 

Petitioner's legal residence or principal office address is: 

1700 W. Big Beaver Road 

Ste 120 

Troy, Ml 48084 

This appeal involves issues relating to the (check all that are applicable): 

Xx 

the property or properties’ true cash and taxable values 

the property or properties’ taxable value only 

If the property or properties’ taxable value is at issue, is there a 

dispute as to the value of an addition or loss? __Yes__No 

uniformity of the property or properties’ assessment

MTT Docket No. 

Page 3 of 4 

15. 

If more than the current tax year is being appealed, list the separate and specific 

facts upon which Petitioner relies to invoke the Tribunals authority over the prior 

tax year or vears (attach additional page if necessary): 

N/A 

16. 

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 

2024 

1,211,786 

701,500 

605,893 

17. 

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

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2024 

780,000 

390,000 

390,000 

18. 

The values in dispute for the property identified above are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2024 

431,786 

311500 

215,893 

19. 

Petitioner requests the following relief (attach additional page if necessary): 

Reduction of True Cash Value, State Equialized Value, Taxable Value. 

The Subject Property is one parcel, thal includes 26 aparimemnt unils for lease. The property is 25% complete as of the date of 

the Board of Review Decision in 2024. 

All comparables, local and neighborhood apartments fave a taxable value between 

$50,000 and $60,000 per unit. No apartment unlt in the State of MI has a $200,000 per unit taxable value. The assessor was 

provided wilh comparables. Comparables indicate: $60,000 SEV/unit * 26 units = $1,660,000 SEV; the project is 25% = 

$390,000 SEV. True Case Value: $380,000 *2 = $780,000.

MTT Docket No. 

Page 4 of 4 

Signature of Petitioner's Authorized Representative or, if none, Petitioner: 

A 

Th 

Printed Name of Petitioner's Authorized Representative or, if none, Petitioner: 

Mic HAPL FR eAR 

Email Address; michael@fairviewco.com 

Mailing Address: 

1700 W. Big Beaver Road, 

Ste 120 

Troy, MI 48084 

Telephone Number: 248-770-3677 

Date: 5-1-2024

Exhibit B

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

Lake Forest Trail Holdings, LLC, 

Docket No. 25- 

Petitioner, 

Parcel No. 4716-03-105-028 

v. 

Charter Township of Green Oak, 

Respondent. 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

Attorneys for Petitioner 

Entire Tribunal Property Tax Petition 

Petitioner Lake Forest Trail Holdings, LLC, by and through its attorneys, 

Williams, Williams, Rattner & Plunkett, PC, states as follows for its Entire Tribunal 

Property Tax Petition. 

The Parties 

1. 

Petitioner Lake Forest Trail Holdings, LLC 

is 

a Michigan limited

2. 

Respondent the Charter Township of Green Oak is a Michigan township 

with its principal offices located at 10001 Silver Lake Road, Brighton, MI 48116 

The Subject Property 

3. 

Petitioner owns property identified as Parcel No. 4716-03-105-028 and 

commonly known as 11395 Izik's Way, Brighton, Michigan 48116 

(the “Subject 

Property”). 

4. 

The Subject Property is located in Livingston County and is within the 

Brighton Area School District. 

5. 

Respondent possesses jurisdiction to assess and collect property taxes 

for the Subject Property. 

The 2025 Assessment 

6. 

For the 2025 tax year, Respondent classified the Subject Property as 

commercial real property. 

7. 

Tor the 2025 tax year, Respondent established the Subject Property’s 

assessment for property taxes as follows: 

True Cash Value 

Assessed Value 

Taxable Value 

5,472,400 

2,736,200 

2,464,830 

8. 

Petitioner contends that a lawful assessment of the Subject Property for 

the 2025 tax year cannot exceed the following amounts: 

True Cash Value 

Assessed Value 

Taxable Value

10. 

This Petition presents issues involving the Subject Property’s valuation 

for assessment purposes. Petitioner does not believe that this Petition presents any 

issues arising out of “additions” or “losses” as the General Property Tax Act, MCL 

211.1 et seq. (the “GPTA”), defines those terms, but reserves its right to assert issues 

involving losses should information supporting such issues become available. 

11. 

The 

Subject Property's 2025 assessment 

(a) violates the Michigan 

Constitution, the GPTA, and other Michigan law, (b) is based on erroneous principles 

and information, (c) is based on the misapplication of valuation principles, and (d) 

otherwise violates Petitioner’s rights. 

12. 

Petitioner does not assert that the Subject Property's 2025 assessment 

is 

not uniform 

aside 

from 

the 

lack 

of uniformity 

resulting 

from Respondent 

overestimating the Subject Property’s values. 

Conclusion and Request for Relief 

WHEREFORE, Petitioner respectfully requests that this honorable Tribunal 

enter judgment revising the Subject Property’s 2025 assessment to be consistent with 

the values set forth in Paragraph 8 of this Petition and granting Petitioner all other 

relief to which it is entitled under Michigan law. 

Respectfully Submitted, 

WILLIAMS, WILLIAMS, RATTNER & 

PLUNKETT, PC

Exhibit C

EN OAK CHARTER Togy, 

J1 SILVER LAKE ROAD, BRIGHTON, y] 4g 

wt pou: 810-231-1333 + FAX 810-231 50g, 

t 

June 30, 2025 

Lake Forest Trail Holdings, LLC 

1700 W Big Beaver Rd, Suite 120 

Troy, MI 48084-3523 

RE: Parcels 4716-03-105-028 

2024 Taxable Value Uncapping 

2025 Taxable Value Revised for Uncapping 

This letter is being sent in accordance with the authority identified in Section 27b of the General Property 

Tax Act (P.A. 206 of 1893, as amended). 

A correction has been made in the Taxable Value of the subject 

real property parcel for the 2024 and 2025 tax years. These changes are due to failure on the part of the 

transferee (grantee) 

to timely 

file 

the Property Transfer Affidavit {form L-4260), along with other 

requested documents. 

On September 25, 2024, 

| sent you an email regarding a deed 

| received from the Register of Deeds 

recorded under document number 2023R-016657. See enclosed email and recorded deed. 

In this email 

| requested a copy of your Schedule-C tax filing and immediately received a response from you by phone 

to discuss this matter. 

After that conversation 

| expected to receive your Schedule-C document, along 

with operating statements and a Property Transfer Affidavit, form L-4260. While 

| received a copy of your 

operating statements, 

| have not received the Property Transfer Affidavit or Schedule-C filing requested. 

Therefore, according to the statute your property is being uncapped. See enclosed form 3214, Assessor 

Affidavit Regarding “Uncapping” of Taxable Value for the 2024 and 2025 tax years for the correction of 

the taxable value, 

You may appeal this decision to the Michigan Tax Tribunal (MTT) within 35 days of receiving this notice of 

the increase in the Property's taxable value. Please contact the MTT at https://www.michigan.gov/taxtrib 

or by calling 517-335-9760 for further guidance. 

If | can be of assistance, please email me directly at christina.yaeger@greenoaktwp.com. 

Regards, 

Che i She \| 

Fe

Michigan Department of Treasury 

3214 (Rev. 8-09) 

Assessor Affidavit Regarding "Uncapping” of Taxable Value 

The changes in Taxable Value recorded on this affidavit are related to the "Uncapping” of Taxable Value due to a failure on the part of the 

iransferee (buyer) to timely file the Property Transfer Affidavit {form L-4260). 

in accordance with the authority identified in Section 27b of the General Property Tax Act (P.A. 206 of 1893, as amended), a correction 

has been made in the Taxable Value of the following described Real/Personal property: 

4716-03-105-028 

(Parcel Identification Number} 

located in the City of/ Township of/Village of 

Green Oak Township 

County 

Livingston 

. 

This is a correction to the 

2024 Assessment/Tax Roll. 

{Tax Year) 

Correction of Taxable Value Due to Transfer of Ownership 

School Code 

47010 

HOMESTEAD AND QUALIFIED AGRICULTURAL 

NON-HOMESTEAD AND NON-QUALIFIED AGRICULTURAL 

Before Correction 

Amount of 

Increase/Decrease 

Corrected 

Before Correction 

Amount of 

Increase/Decrease 

Corrected 

State Equalized Valuation 

701,500 

Taxable Valuation 

605893 

98,571 

701,500 

Correction of Taxing Unit Levy 

Taxing Unit 

HOMESTEAD AND QUALIFIED AGRICULTURAL 

NON-HOMESTEAD AND NON-QUALIFIED AGRICULTURAL 

Before Correction 

Amount of 

increase/Decrease 

Corrected 

Before Correction 

Amount of 

increase/Decrease 

Corrected 

County 

intermediate School District 

Community College 

State Education Tax 

Local Schoo! Operating 

Local School Supplemental (<=18) 

Local School Supplemental (>=18) 

Local School Enhancement 

Local Scheol Debt 

City/Township/Village 

Other 

Total 

NOTE: The levy section of this affidavit does not include collections fees, penalties, and interest. These must be added to the bill, when applicable, by the treasurer. 

1 

Christina Yaeger 

the above information is true, to the best of my knowledge. 

, being the certified assessor for the City/Twp of 

Green Oak Township 

, do hereby swear or affirm that 

Signaturgof Certified Assessor 

No. 

ere Ra 

Date 

Qa ne 

BO 005 

Certification 

A-0L% 

Copies to: Property Owner, Equalizhtion Department, County Treasurer, and the Treasurers of all other affected Taxing Units.

Michigan Department of Treasury 

3214 (Rev. 8-08) 

County 

Assessor Affidavit Regarding "Uncapping” of Taxable Value 

Livingston 

The changes in Taxable Value recorded on this affidavit are related to the "Uncapping" of Taxable Value due to a faiture on the part of the 

transferee (buyer) to timely file the Property Transfer Affidavit (form L-4260). 

In accordance with the authority identified in Section 27b of the General Property Tax Act (P.A. 206 of 1893, as amended), a correction 

has been made in the Taxable Value of the following described Real/Personal property: 

. 

4716-03-105-028 

located in the City of Township of/Village of 

Green Oak Township 

. 

This is a correction to the 

{Parcel identification Number) 

2025 Assessment/Tax Roll. 

(Tex Year) 

Correction of Taxable Value Due to Transfer of Ownership 

HOMESTEAD AND QUALIFIED AGRICULTURAL 

NON-HOMESTEAD AND NON-QUALIFIED AGRICULTURAL 

Scheel Code 

47010 

- 

Amount of 

Amount of 

Before Correction 

Increase/Decrease 

Corrected 

Before Correction 

Increase/Decrease 

Corrected 

State Equalized Valuation 

2,736,200 

Taxable Valuation 

2,464,830 

Correction of Taxing Unit Levy 

Taxing Unit 

HOMESTEAD AND QUALIFIED AGRICULTURAL 

NON-HOMESTEAD AND NON-QUALIFIED AGRICULTURAL 

Amount of 

Amount of 

Before Correction 

Increase/Decrease 

Corrected 

Before Correction 

Increase/Decrease 

Corrected 

County 

intermediate School District 

Community College 

State Education Tax 

Local School Operating 

Local School Supplemental (<=18) 

Local School Supplemental (>=18) 

Local School Enhancement 

Local Schoo! Debt 

City/Township/Village 

Other 

Total 

NOTE: The levy section of this affidavit does not include collections fees, penalties, and interest. These must be added to the bill, when applicable, by the treasurer. 

i 

Christina Yaeger 

, being the certified assessor for the City/Twp of 

Green Oak Township 

. do hereby swear or affirm that 

the above information is true, to the best of my knowledge. 

Signatureaf 

Certified Assessor 

Date 

Certification 

No. 

Ns de 

lg ac 

RD 20 

2028 

a_ Aal¥ 

Copies to: Property Owner] Equalidation Department, County Treasurer, and the Treasurers of all other affected Taxing Units.

Yaeger, Christina 

Ll 

From: 

Yaeger, Christina 

Sent: 

Wednesday, September 25, 2024 12:53 PM 

To: 

Michael Furnari 

Subjeci: 

Lake Forest Trails Name Change 

Hi Michael, 

I reviewed the documents you submitted for your tribunal case and noticed you changed the name of the 

ownership 3/20/2023. found a deed 2023R-016657 dated 9/6/2023 transferring from JMF Properties, LLC to Lake 

Forest Trail Holdings, LLC. {need a copy of your schedule-C showing the relationship between these two 

entities. This request is not part of the tribunal case, and the requested information should be directed back 

to 

me. 

Please let me know if you have any questions. 

Thank you, 

Christina 

LIAR 

Tae 

i 

iy 

LH 

eer 

Christina L Yaeger, MAAO(3), MCPPE 

Township Assessor 

Assessing Dept, Green Oak Township 

10001 Silver Lake Rd 

Brighton, Mi 48116 

810-231-1333 x105 

christina.yaeger@greenoakiwp.com 

www. greenoakiwp,com

2023R-016657 

RECORDED ON 

09/07/2023 08:30:29 AM 

BRANDON DENBY 

REGISTER OF DEEDS 

LIVINGSTON COUNTY, MI 48843 

RECORDING: 26.00 

REMON: 4.00 

PAGES: 5 

QUITCLAIM DEED 

TRANSFER 

~~ TAX EXEMPT 207.505(a) and 207.526() 

Tax No.: 

For One and 00/100 Dollar ($1.00), IMF Properties, LLC, 

a Michigan limited liability 

company (the “Grantor”), whose address is 30140 Orchard Lake Road, Farmington Hills, 

MI 48334, does hereby Remise, Release and Quitclaim to Lake Forest Trail Holdings, LLC 

a Michigan limited liability company (the “Grantee”), whose address 

is 1700 West Big 

Beaver Road, Sute 120, Troy, MI 48084, all its interest in and to the following described real 

property in the township of Green Oak, County of Livingston, State of Michigan: 

Parcel 1: 

Commencing at the Northwest corner of Section 3, Town 

1 North, Range 6 East, 

Green Oak Township, Livingston County, Michigan, thence South 01 degrees 56 

minutes 49 seconds West, 150.73 feet along the West line of said Section 3 (as 

monumented); thence South 80 degrees 27 minutes 46 seconds East, 574.87 feet 

along the North line (and its extension) of "SUPERVISOR'S PLAT OF 

RICHARD'S SUBDIVISION", as recorded in Liber 3 of Plats, Page 30, Livingston 

County Records to the Northeast corner of said Subdivision; thence North 13 

degrees 01 minutes 58 seconds East, 50.75 feet along the East line of said 

Subdivision extended Northerly to the centerline of Grand River Avenue; thence 

the following 2 courses along the centetline of Grand River Avenue; Easterly 

286.43 feet along the arc of a 28,647.90 foot radius curve to the left, through a 

central angle of 00 degrees 34 minutes 22 seconds and having a chord bearing of 

South 81 degrees 20 minutes 40 seconds East, 286.43 feet and South 81 degrees 37

thence South 08 degrees 35 minutes 38 seconds West, 58.14 feet; thence South 11 

degrees 33 minutes 36 seconds West, 29.99 feet; thence North 78 degrees 26 

minutes 24 seconds West, 20.26 feet; thence South 

11 degrees 31 minutes 03 

seconds West, 44.56 feet; thence South 78 degrees 26 minutes 24 seconds East, 

20.23 feet; thence South 11 degrees 33 minutes 36 seconds West, 16.60 feet; thence 

35.28 feet along the arc of a 43.02 foot radius curve to the right, through a central 

angle of 46 degrees 59 minutes 36 seconds and having a chord bearing South 38 

degrees 19 minutes 12 seconds West, 34.30 feet; thence 134.60 feet along the arc of 

a 51.25 foot radius curve to the left, through a central angle of 150 degrees 28 

minutes 22 seconds and having a chord bearing South 09 degrees 40 minutes 41 

seconds Bast, 99.12 feet; thence South 40 degrees 13 minutes 07 seconds West, 

81.37 feet; thence South 22 degrees 45 minutes 11 seconds East, 472.33 feet; 

thence North 84 degrees 59 minutes 49 seconds West, 242.29 feet; thence North 18 

degrees 17 minutes 46 seconds West, 240.92 feet; thence Notth 71 degrees 42 

minutes 14 seconds East, 24.00 feet; thence North 18 degrees 17 minutes 46 seconds 

West, 259.06 feet; thence North 10 degrees 35 minutes 51 seconds East, 181.71 

feet; thence North 04 degrees 15 minutes 11 seconds East, 286.37 feet; thence South 

81 degrees 37 minutes 53 seconds East, 181.23 feet to the point of beginning. 

The ABOVE PARCEL was combined from the legal description below, which 

was formerly known as: 

Units 1,2,3,4,5,6,7,8,9,10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 

23, 24, 25, and 26 of LAKE FOREST TRAILS II, a Condominium according 

to the Master Deed recorded 

in Instrument No.2021R-023473, Livingston 

County 

Records, 

and 

designated 

as 

Livingston 

County 

Condominium 

Subdivision Plan No. 442, as amended, together with rights in the general 

common elements and the limited common elements as shown on the Master Deed 

and as described in Act 59 of the Public Acts of 1978, as amended. 

Parcel 2: 

Perpetual, non-exclusive access easement reserved in First Amendment to the

Commonly known as: 1zik’s Way and Langfeld Spur, Brighton, MI 48116 

Parcel 1.D.: 

4716-03-105-028 which is part of the original parent parcel numbers: 

4716-03-105-001, 4716-03-105-002, 4716-03-105-003, 4716-03-105-004, 4716-03-105-005, 

4716-03-105-006, 4716-03-105-007, 4716-03-105-008, 4716-03-105-009, 4716-03-105-010, 

4716-03-105-011, 4716-03-105-012, 4716-03-105-013, 4716-03-105-014, 4716-03-105-015, 

4716-03-105-016, 4716~03-105-017, 4716-03-105-018, 4716-03-105-019, 4716-03-105-020, 

4716-03-105-021, 4716-03-105-022, 4716-03-105-023, 4716-03-105-024, 4716-03-105-025, 

4716-03-105-026, and 4716-03-105-027. 

Date: September 6, 2023 

GRANTOR: 

JME 

Properties, 

LLC, 

a 

Michigan 

limited 

liability company 

MICHAEL 8S. FURNARI LIVING TRUST 

Dated October 7, 2021 

Byy, — 

(Sm 

Michael S. Furnari 

It’s: Trustee 

CAROLINA 

FURNARI LIVING TRUST 

Dated 

Qttober~j 

2021 

. 

By: 

[FPN 

" 

123 

Carolina 

Furnart 

It’s: Trustee 

[Notary signature on following page]

STATE OF MICHIGAN 

) 

EE] 

1 

COUNTY OF DM\edy 

) 

On sagt 

oghypelore me, a Notary Public in and for said State, personally appeared 

MICHAEL 8. FURNARI, Trustee of MICHAEL 8. FURNARI! LIVING TRUST, and CAROLINA 

FURNARYI, Trustee, of CAROLINA FURNARI LIVING TRUST, Members on behalf of IMF 

PROPERTIES LLC (or proved to me on the basis of satisfactory evidence) to be the persons whose 

names are subscribed to the within instrument and acknowledged to me that they executed the 

same in their authorized capacities, and that by their signatures on the instrument, the persons, or 

the entity upon behalf of which the persons acted, executed the instrument, 

Witness my hand and official seal. 

Notary 

Public 

County, Michigan 

Acting in 

County 

My commission expires 

MELISSA SPRANGER 

Notary Public, Genesae County, Mi 

My Commission Expires 

07) 

28 

Acting in the county EIEN

Instrument drafted and without opinion by: | After recording, return to: 

Joseph W. Thomas, Attorney at law 

Grantee, Lake Forest Trail Holdings, LLC 

Thomas Legal Group PLC 

1700 W. Big Beaver Rd., Suite 120 

801 W. Big Beaver Rd., Ste. 401 

Troy, M1 48084 

Troy, MI 48084 

(248) 613-4100

Exhibit D

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

LAKE FOREST TRAIL HOLDINGS, LLC, 

Docket No. 25- 

Petitioner, 

Parcel No. 4716-03-105-028 

v. 

TOWNSHIP OF GREEN OAK, 

Respondent. 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

Attorneys for Petitioner 

Entire Tribunal Property Tax Petition 

Petitioner Lake Forest Trail Holdings, LLC, by and through its attorneys, 

Williams Williams Rattner & Plunkett, PC, states as follows for its Entire Tribunal 

Property Tax Petition. 

The Parties 

1. 

Petitioner Lake 

Forest Trail Holdings, LLC, 

is 

a Michigan limited 

liability company, with its registered offices located at 801 W. Big Beaver Road, Suite

The Subject Property 

3. 

Petitioner owns property identified as Parcel No. 4716-03-105-028 and 

commonly known 

as 

11395 Izik's Way, Brighton, Michigan 48116 

(the “Subject 

Property”). 

4, 

The Subject Property is located in Livingston County and is within the 

Brighton Area School District. 

5. 

The Subject Property was designed for and is used for multi-family 

housing purposes. 

6. 

Respondent possesses jurisdiction to assess and collect property taxes for 

the Subject Property. 

The 2024 and 2025 Property Tax Assessments 

7. 

For tax years 2024 and 2025, Respondent classified the Subject Property 

as commercial real property. 

8. 

For tax years 2024 and 2025, Respondent initially established the 

Subject Property’s assessment in the following amounts: 

Year 

TCV 

AV 

Tv 

2024 

1,403,000 

701,600 

605,893 

2025 

5,472,400 

2,736,200 

2,464,830 

9. 

On June 30, 2025, Respondent uncapped the Subject Property's 2024 

taxable value to equal its 2024 assessed value on the basis that the Subject Property

Year 

TCV 

AV 

TV 

2024 

1,403,000 

701,500 

701,500 

2025 

5,472,400 

| 2,736,200 

2,663,401 

10. 

This Petition presents issues involving whether the Subject Property 

experienced a “transfer of ownership” as the General Property Tax Act, MCL 211.1 et 

seq. (the “GPTA”), defines that term. Petitioner does not believe that this Petition 

presents any issues arising out of “additions” or “losses” as the GPTA defines those 

terms, but reserves 

its right to assert issues involving losses should information 

supporting such issues become available. 

11. 

The Subject Property's tax year 2024 and 2025 assessments (a) violate 

the Michigan Constitution, the GPTA, and other Michigan law, 

(b) are based on 

erroneous principles and information, (c) are based on the misapplication of valuation 

principles, and (d) otherwise violate Petitioner's rights. 

Count I: Erroneous Uncapping 

12. 

For tax year 2024, Respondent uncapped the Subject Property's taxable 

value to equal its 2024 assessed value, then carried that uncapping forward to tax 

year 2025 (Notice of Uncapping attached as Exhibit A). 

13. 

The Subject Property did not experience a transaction that qualifies as a 

“transfer of ownership” during calendar year 2023 as that term 

is defined in the 

GPTA.

for tax years 2024 and 2025, as provided under Const 1963, art 9, 

§ 3, the GPTA, and 

other law. 

15. 

Respondent’s uncapping of the Subject Property's taxable value for tax 

year 2024, which was then carried to tax year 2025, is therefore an error. 

16. 

The amount of taxable value in dispute based on Respondent’s erroneous 

increase in the Subject Property’s taxable value for tax years 2024 and 2025 are as 

follows! 

Year | TV in Dispute 

2024 

95,607 

2025 

98,571 

Count II: Overestimation of Value 

17. 

Alternatively, 

Petitioner contends that 

a lawful assessment 

of the 

Subject Property for tax years 2024 and 2025 cannot exceed the following amounts! 

Year 

TCV 

AV 

TV 

2024 

780,000 

390,000 

390,000 

2025 | 

2,000,000 

1,000,000 

1,000,000 

18. 

The amounts in dispute based on Respondent’s overestimation of value 

for the Subject Property for tax years 2024 and 2025 are therefore as follows: 

Year 

TCV 

AV 

Tv 

2024 

623,000 

311,600 

311,500 

2025 | 

3,472,400 

1,736,200 

1,563,401

Conclusion and Request for Relief 

WHEREFORE, Petitioner respectfully requests that this honorable Tribunal 

enter judgment revising the Subject Property’s 2024 and 2025 assessment to limit the 

increase in the Subject Property’s taxable value as set forth in §14, or alternatively 

revising the assessment to be consistent with the values set forth in 17, and granting 

Petitioner all other relief to which it is entitled under Michigan law. 

Respectfully Submitted, 

WILLIAMS WILLIAMS RATTNER 

& PLUNKETT, PC 

By: // Jevowme P. Pesick 

Jerome P. Pesick (P29039) 

Dated: July 30, 2025 

Attorneys for Petitioner

Exhibit A

EN DAK CHARTER TOWgyp 

b 

01 SILVER LAKE ROAD, BRIGHTON, M| 43) 

10 

prone; 810-241-1343 

+ 

FAX 810-231-5080 

1 

June 30, 2025 

Lake Forest Trail Holdings, LLC 

1700 W Big Beaver Rd, Suite 120 

Troy, Ml 48084-3523 

RE: Parcels 4716-03-105-028 

2024 Taxable Value Uncapping 

2025 Taxable Value Revised for Uncapping 

This letter is being sent in accordance with the authority identified in Section 27b of the General Property 

Tax Act {P.A. 206 of 1893, as amended). 

A correction has been made in the Taxable Value of the subject 

real property parcel for the 2024 and 2025 tax years. These changes are due to failure on the part of the 

transferee (grantee) to timely 

file the Property Transfer Affidavit (form 1-4260), along with other 

requested documents, 

On September 25, 2024, 

| sent you an email regarding a deed 

| received from the Register of Deeds 

recorded under document number 2023R-016657. See enclosed email and recorded deed. 

In this email 

1 requested a copy of your Schedule-C tax filing and immediately received a response from you by phone 

to discuss this matter. 

After that conversation 

| expected to receive your Schedule-C document, along 

with operating statements and a Property Transfer Affidavit, form L-4260. While 

| received a copy of your 

operating statements, 

| have not received the Property Transfer Affidavit or Schedule-C filing requested. 

Therefore, according to the statute your property is being uncapped. See enclosed form 3214, Assessor 

Affidavit Regarding “Uncapping” of Taxable Value for the 2024 and 2025 tax years for the correction of 

the taxable value, 

You may appeal this decision to the Michigan Tax Tribunal (MTT) within 35 days of receiving this notice of 

the increase in the Property's taxable value. Please contact the MTT at https://www,michigan.gov/taxtrib 

or by calling 517-335-9760 for further guidance. 

If 

| can be of assistance, please email me directly at christina.yaeger@greenoakiwp.com. 

Regards, 

¢ harsh -— cs ©

Michigan Department of Treasury 

3214 (Rev, 8-09) 

Assessor Affidavit Regarding "Uncapping” of Taxable Value 

The changes in Taxable Value recorded on this affidavit are related to the *Uncapping” of Taxable Value due to a failure on the part of the 

transferee (buyer) to timely file the Property Transfer Affidavit (form L-4260) 

County 

Livingston 

In accordance with the authority identified in Section 27b of the General Property Tax Act (P.A. 206 of 1893, as amended), a correction 

has been made in the Taxable Value of the following described Real/Personal property: 

4716-03-105-028 

{Parcel Identification Number) 

located in the City off Township of/Village of 

Green Oak Township 

. 

This is a correction to the 

2024 Assessment/Tax Roll. 

{Tax Year) 

Correction of Taxable Value Due to Transfer of Ownership 

School Code 

47010 

HOMESTEAD AND QUALIFIED AGRICULTURAL 

NON-HOMESTEAD AND NON-QUALIFIED AGRICULTURAL 

Before Correction 

Amount of 

Increase/Decrease 

Corrected 

Before Correction 

Increase/Decrease 

Amount of 

Corrected 

State Equalized Valuation 

Taxable Valuation 

701,500} 

605883 

701,500] 

98,571 

Correction of Taxing Unit Levy 

HOMESTEAD AND QUALIFIED AGRICULTURAL 

. 

. 

NON-HOMESTEAD AND NON-QUALIFIED AGRICULTURAL 

Taxing Unit 

Amount of 

Amount of 

Before Correction 

Increase/Decrease 

Corrected 

Before Correction 

Increase/Decrease 

Corrected 

County 

Intermediate School District 

Community College 

State Education Tax 

Local School Operating 

Local School Supplemental (<=18) 

Local School Supplemental (»=18) 

Local School Enhancement 

Local School Debt 

City/Township/Village 

Cther 

Total 

NOTE: The levy section of this affidavit does not include collections fees, penalties, and interest. These must be added to the bill, when applicable, by the treasurer. 

| 

Christina Yaeger 

the above information is true, to the best of my knowledge. 

, being the certified assessor for the City/Twp of 

Green Oak Township 

do hereby swear or affirm that 

Signature~of Certified Assessor 

Dl 

GN EN I 

Date 

NY TO A025 

Certification Abe 

Copies to: Property Owner, Equalization Department, County Treasurer, and the Treasurers of all other affected Taxing Units.

Michigan Department of Treasury 

3214 (Rev. 8-08) 

Assessor Affidavit Regarding "Uncapping” of Taxable Value 

The changes in Taxable Value recorded on this affidavit are related fo the "Uncapping” of Taxable Value due to a failure on the part of the 

transferee (buyer) to timely file the Property Transfer Affidavit (form L-4260). 

In accordance with the authority identified in Section 27b of the General Property Tax Act (P.A. 206 of 1833, as amended), a correction 

has been made in the Taxable Value of the following described Real/Personal property: 

4716-03-105-028 

{Parcel Identification Number) 

located in the City off Township of/Village of 

Green Oak Township 

County 

Livingston 

. 

This is a correction to the 

2025 Assessment/Tax Rofl. 

(Tax Year) 

Correction of Taxable Value Due to Transfer of Ownership 

Schoct Code 

47010 

HOMESTEAD AND QUALIFIED AGRICULTURAL 

NON-HOMESTEAD AND NON-QUALIFIED AGRICULTURAL 

Before Correction 

Amount of 

increase/Decrease 

Corrected 

Before Correction 

Amount of 

Increase/Decrease 

Corrected 

State Equalized Valuation 

Taxable Valuation 

2,736,200 

2,464,830 

98,571 

2,563,401 

Correction of Taxing Unit Levy 

HOMESTEAD AND QUALIFIED AGRICULTURAL 

Taxing Unit 

NON-HOMESTEAD AND NON-QUALIFIED AGRICULTURAL 

Amount of 

Amount of 

Before Correction 

Increase/Decrease 

Corrected 

Before Correction 

increase/Decrease 

Corrected 

County 

Intermediate School District 

Community College 

State Education Tax 

Local School Operating 

Local School Supplemental (<=18) 

Local School Supplemental (>=18) 

Local School Enhancement 

Local Schoo! Debt 

City/Township/Village 

Other 

Total 

NOTE: The levy section of this affidavit does not include collections fees, penalties, and interest. These must be added to the bill, when applicable, by the treasurer. 

| 

Christina Yaeger 

the above information is true, to the best of my knowledge. 

, being the certified assessor for the City/Twp of 

Green Oak Township 

, do hereby swear or affirm that 

Signaturgaf Certified Assessor 

ve 

ha Foo 

\g act 

Date 

Certification 

A-aaL¥% 

Copies to: Property Owner] Equalidation Department, County Treasurer, and the Treasurers of all other affected Taxing Units.

Yaeger, Christina 

From: 

Yaeger, Christina 

Sent: 

Wednesday, September 25, 2024 12:53 PM 

To: 

Michael Furnari 

Subject: 

Lake Forest Trails Name Change 

Hi Michael, 

I reviewed the documents you submitted for your tribunal case and noticed you changed the name of the 

ownership 3/20/2023. 

| found a deed 2023R-016657 dated 9/6/2023 transferring from JMF Properties, LLC to Lake 

Forest Trail Holdings, LLC. 

I need a copy of your schedule-C showing the relationship between these two 

entities. This request is not part of the tribunal case, and the requested information should be directed back to 

me. 

Please let me know if you have any questions. 

Thank you, 

Christina 

EEE LR 

Ths 

gil TITRE 

| iy 

Era 

A] 

HL 

~~. 

Christina L Yaeger, MAAO(3), MCPPE 

Township Assessor 

Assessing Dept, Green Oak Township 

10001 Silver Lake Rd 

Brighton, Mi 48116 

810-231-1333 x105 

christina.yaeger@greenoaktwp.com 

www, greenoaktwp.com

2023R-016657 

RECORDED ON 

09/07/2023 08:30:29 AM 

BRANDON DENBY 

REGISTER OF DEEDS 

LIVINGSTON COUNTY, MI 48843 

RECORDING: 26.00 

! 

REMON: 4.00 

PAGES: 5 

QUITCLAIM DEED 

TRANSFER 

TAX EXEMPT 

207.505(a) and 207.526(2) 

~~ Tax No.: 

For One and 00/100 Dollar ($1.00), JMF Properties, LLC, 

a Michigan limited liability 

company (the “Grantor™), whose address is 30140 Orchard Lake Road, Farmington Hills, 

MI 48334, does hereby Remise, Release and Quitelaim to Lake Forest Trail Holdings, LLC 

a Michigan limited liability company (the “Grantee”), whose address is 1700 West Big 

Beaver Road, Sute 120, Troy, MI 48084, all its interest in and to the following described real 

property in the township of Green Oak, County of Livingston, State of Michigan: 

Parcel 1: 

Commencing at the Northwest corner of Section 3, Town 

1 North, Range 6 East, 

Green Oak Township, Livingston County, Michigan, thence South 01 degrees 56 

minutes 49 seconds West, 150.73 feet along the West line of said Section 3 (as 

monumented); thence South 80 degrees 27 minutes 46 seconds East, 574.87 feet 

along the North line (and its extension) of "SUPERVISOR'S PLAT OF 

RICHARD'S SUBDIVISION", as recorded in Liber 3 of Plats, Page 30, Livingston 

County Records to the Northeast corner of said Subdivision; thence North 13 

degrees 01 minutes 58 seconds East, 50.75 fest along the East line of said 

Subdivision extended Northerly to the centerline of Grand River Avenue; thence 

the following 2 courses along the centerline of Grand River Avenue; Easterly 

286.43 feet along the arc of a 28,647.90 foot radius curve to the left, through a 

central angle of 00 degrees 34 minutes 22 seconds and having a chord bearing of

thence South 08 degrees 35 minutes 38 seconds West, 58,14 feet; thence South 11 

degrees 33 minutes 36 seconds West, 29.99 feet; thence North 78 degrees 26 

minutes 24 seconds West, 20.26 feet; thence South 

11 degrees 31 minutes 03 

seconds West, 44.56 feet; thence South 78 degrees 26 minutes 24 seconds East, 

20.23 feet; thence South 11 degrees 33 minutes 36 seconds West, 16.60 feet; thence 

35.28 feet along the arc of a 43.02 foot radius curve to the right, through a central 

angle of 46 degrees 59 minutes 36 seconds and having a chord bearing South 38 

degrees 19 minutes 12 seconds West, 34.30 feet; thence 134.60 feet along the arc of 

a 51.25 foot radius curve to the left, through a central angle of 150 degrees 28 

minutes 22 seconds and having a chord bearing South 09 degrees 40 minutes 41 

seconds Bast, 99.12 feet; thence South 40 degrees 13 minutes 07 seconds West, 

81.37 feet; thence South 22 degrees 45 minutes 11 seconds East, 472,33 feet; 

thence North 84 degrees 59 minutes 49 seconds West, 242.29 feet; thence North 18 

degrees 17 minutes 46 seconds West, 240.92 feet; thence North 71 degrees 42 

minutes 14 seconds East, 24.00 feet; thence North 18 degrees 17 minutes 46 seconds 

West, 259.06 feet; thence North 10 degrees 35 minutes 51 seconds East, 181.71 

feet; thence North 04 degrees 15 minutes 11 seconds East; 286.37 feet; thence South 

81 degrees 37 minutes 53 seconds East, 181.23 feet to the point of beginning. 

The ABOVE PARCEL was combined from the legal description below, which 

was formerly known as: 

Units 1,2,3,4,5,6,7,8,9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 

23, 24, 25, and 26 of LAKE FOREST TRAILS II, a Condominium according 

to the Master Deed recorded 

in Instrument No.2021R-023473, Livingston 

County 

Records, 

and 

designated 

as 

Livingston 

County 

Condominium 

Subdivision Plan No. 442, as amended, together with rights in the general 

common elements and the limited common elements as shown on the Master Deed 

and as described in Act 59 of the Public Acts of 1978, as amended. 

Parcel 2: 

Perpetual, non-exclusive access easement reserved in First Amendment to the

Commonly known as: Izik’s Way and Langfeld Spur, Brighton, M1 48116 

Parcel 1.D.: 

4716-03-105-028 which is part of the original parent parcel numbers: 

4716-03-105-001, 4716-03-105-002, 4716-03-105-003, 4716-03-105-004, 4716-03-105-005, 

4716-03-105-006, 4716-03-105-007, 4716-03-105-008, 4716-03-105-009, 4716-03-105-010, 

4716-03-105-011, 4716-03-105-012, 4716-03-105-013, 4716-03-105-014, 4716-03-105-015, 

4716-03-105-016, 4716-03-105-017, 4716-03-105-018, 4716-03-105-019, 4716-03-105-020, 

4716-03-105-021, 4716-03-105-022, 4716-03-105-023, 4716-03-105-024, 4716-03-105-025, 

4716-03-105-026, and 4716-03-105-027. 

Date: September 6, 2023 

GRANTOR: 

JMF 

Properties, 

LLC, 

a 

Michigan 

limited 

liability company 

MICHAEL S. FURNARI LIVING TRUST 

Dated October 7, 2021 

Michael S. Furnari 

It’s: Trustee 

CAROLINA 

FURNARI LIVING TRUST 

Dated 

October, 

2021. 

\ 

By: 

(Lanny 

Carolina Furnari” 

It’s: Trustee 

[Notary signature on following page]

STATE OF MICHIGAN 

) 

EE] 

\ 

COUNTY 

OF DMA) 

On Spits & Wpefore me, a Notary Public in and for said State, personally appeared 

MICHAEL S. FURNARI, Trustee of MICHAEL S. FURNARI LIVING TRUST, and CAROLINA 

FURNARI, Trustee, of CAROLINA FURNARI LIVING TRUST, Members on behalf of IMF 

PROPERTIES LLC (or proved to me on the basis of satisfactory evidence) to be the persons whose 

names are subscribed to the within instrument and acknowledged to me that they executed the 

same in their authorized capacities, and that by their signatures on the instrument, the persons, or 

the entity upon behalf of which the persons acted, executed the instrument. 

Witness my hand and official seal. 

Notary 

Public 

County, Michigan 

Acting in 

County 

My commission expires 

MELISSA SPRANGER 

Notary Public, Genesaa County, Mi 

My Commission Expires. 

07/1 

28 

Acting in the county i)

Instrument drafted and without opinion by: | After recording, return to: 

Joseph Ww. Thomas, Attorney at law 

Grantee, Lake Forest Trail Holdings, LLC 

Thomas Legal Group PLC 

1700 W. Big Beaver Rd., Suite 120 

801 W. Big Beaver Rd., Ste. 401 

Troy, MI 48084 

Troy, MI 48084 

(248) 613-4100

Exhibit E

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON 1. BROWN, DPA 

GOVERNOR 

DIRECTOR 

LANSING 

Lake Forest Trail Holdings LLC, 

Petitioner, 

MICHIGAN TAX TRIBUNAL 

ENTIRE TRIBUNAL 

v 

MTT Docket No. 25-002950 

Township Of Green Oak, 

Respondent. 

ORDER OF DISMISSAL 

The Tribunal has reviewed the file in the above-captioned case and finds that: 

The issue in this case is already pending in another case and, as such, this appeal is 

duplicative and shall be dismissed. 

Therefore, 

IT IS ORDERED that the case is DISMISSED. 

This order resolves all pending issues and closes the case. 

APPEAL RIGHTS 

If you disagree with the final decision in this case, you may file a motion for 

reconsideration with the Tribunal or a claim of appeal with the Michigan Court of 

Appeals. 

A motion for reconsideration must be filed with the Tribunal with the required filing fee 

within 21 days from the date of entry of the final decision. Because the final decision 

closes the case, the motion cannot be filed through the Tribunal’s web-based e-filing 

system; it must be filed by mail or personal service. The fee for the filing of such 

motions is $50.00 in the Entire Tribunal and $25.00 in the Small Claims Division, unless 

the Small Claims decision relates to the valuation of property and the property had a 

principal residence exemption of at least 50% at the time the petition was filed or the 

decision relates to the grant or denial of a poverty or disabled veterans exemption and, 

if 50, there is no filing fee. You are required to serve a copy of the motion on the 

opposing party by mail or personal service or by email if the opposing party agrees to

MTT Docket No. 25-002950 

Page 2 of 2 

the claim is filed more than 21 days after the entry of the final decision, 

it is an “appeal 

by leave.” A copy of the claim of appeal must be filed with the Tribunal to certify the 

record on appeal. There is no certification fee. 

) 

ey 

EEA 

By, 

alicia 

A 

Hale 

Patricia L. Halm, Tribunal Chair 

Entered: August 20, 2025 

PROOF OF SERVICE 

| certify that a copy of the foregoing was sent on the entry date indicated above to the 

parties or their attorneys or authorized representatives, 

if any, utilizing either the mailing 

or email addresses on file, as provided by those parties, attorneys, or authorized 

representatives. 

By: Tribunal Clerk

RECEIVED 

AUG 27 2025 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

LAKE FOREST TRAIL HOLDINGS, LLC, 

Petitioner, 

MOAHR Docket No. 25-002950 

v. 

TOWNSHIP OF GREEN OAK, 

Respondent. 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

380 N. 01d Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

Attorneys for Petitioner 

Proof of Service

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

LAKE FOREST TRAIL HOLDINGS, LLC, 

Petitioner, 

MOAHR Docket No. 25-002950 

v. 

TOWNSHIP OF GREEN OAK, 

Respondent. 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

Attorneys for Petitioner 

Petitioner's Motion for Reconsideration 

of Order of Dismissal dated August 20, 2025 

Petitioner Lake Forest Trail Holdings, LLC, by and through its attorneys, 

Williams, Williams, Rattner & Plunkett PC, states as follows for its Motion for 

Reconsideration of Order of Dismissal dated August 20, 2025: 

1. 

This is an appeal involving the unlawful “uncapping” of the 2024 taxable 

value of Petitioner's real property located in Green Oak Township, Livingston County 

(the “Subject Property”).

w/w RP 

Williams Williams Rattner & Plunkett, P.C. 

Attorneys and Counsglors 

380 North Old Woodward Avenue, Suite 300 

Birmingham, Michigan 48009 

Williams, Williams, Rattner & Plunkett, P.C. 

Attn: Jason C. Long, Esq. 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009

W{W|R 

|P 

Williams Williams Rattner & Plunket

Attorneys and Counselors 

380 North Old Woodward Avenue, 

Birmingham, Michigan 48009 

TO: 

Clerk 

Michigan Tax

PQ. Box 302

l.ansing, Vil 

02 ots BW Kuv 

A 

A 

LA 

AS

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