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25-003690.pdf

McLaughlin Family Trust, Petitioner V Township Of Woodstock, Respondent · 25-003690-TT

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Page 1

RECEIVED 

THOMAS A. KUZMIAK, P.L.L.C. 

DEC 01 2025 

) 

2222 Ford Avenue 

MICHIGAN TAX TRIBUNAL 

Thomas A. Kuzmiak 

‘Wyandotte, MI 48192 

Katherine M. 

Kuzmiak 

Attorney at Law 

Attorney at Law 

Tom@kuzmiaklaw.com 

(734) 283-3350 

Katherine@kuzmiaklaw.com 

(734) 283-7330 facsimile 

November 20, 2025 

Michigan Tax Tribunal 

611 W. Ottawa Street 

Lansing, MI 48933 

26076117-1 

11/26/25 

Re: 

Case No. 25-003690 

Dear Sir/Madam: 

Enclosed herewith please find the following: 

A. 

Check for $25.00 to cover the filing fee for Motion for Reconsideration in the Small 

Claims Division. 

B. 

Motion for Reconsideration. 

Please process in your normal and usual manner. 

Thank you in advance for your anticipated cooperation. 

Ve 

THOMAS A. KU 

TAK:ds

Page 2

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

McLAUGHLIN FAMILY TRUST, 

Petitioner, 

Vs. 

MTT Docket # 25-003690 

Hon. Patricia L. Halm 

WOODSTOCK TOWNSHIP, 

Respondent. 

THOMAS A. KUZMIAK, PLLC 

THOMAS A. KUZMIAK, P30464 

Attorney for Petitioner 

2222 Ford Avenue 

Wyandotte, MI 48192 

(734) 283-3350 

/ 

MOTION FOR RECONSIDERATION 

NOW 

COMES 

the 

Petitioner, 

JOHN 

McLAUGHLIN, 

Trustee 

of 

the 

McLAUGHLIN 

FAMILY 

TRUST, 

by 

and 

through 

his 

Attorney, 

THOMAS 

A. 

KUZMIAK, PLLC, and does herein file 

a Motion for Reconsideration of the Order of 

Dismissal and does herein state as follows: 

1. 

That 

the 

Petitioner 

did 

file 

a 

Property 

Tax Appeal 

challenging 

the 

assessments for tax year 2025. 

2. 

That the Michigan Tax Tribunal Small Claims Division did enter an Order 

of Dismissal premised on the following: 

A. 

That an Appeal of the March BOR Decision must be filed by July 

31%, but that, in this case, the Appeal was filed on August 25, 2025. 

B. 

That the pleadings did not reflect a qualified error as specified in 

MCL 211.53(B)(6).

Page 3

Assessor for Woodstock Township determined that the parcels in question had a valid and 

qualified easement. 

B. 

That the Petitioner does herein state that there does not exist an 

easement and that said parcels are landlocked, which would dramatically impact valuation 

of the respective parcels. 

C. 

That the determination that an easement existed by the Assessor for 

Woodstock Township is an error, as no such recorded easement exists and there 

is no 

independent access for ingress and egress to the affected parcels. 

WHEREFORE, the Petitioner does herein pray that this Honorable Tribunal grant a 

reconsideration of the application and grant the relief as requested. 

Ni dd a 

THOMAS A. KUZMIAK, PLLC 

THOMAS A. KUZMIAK, P30464 

Attorney for Petitioner 

2222 Ford Avenue 

Wyandotte, MI 48192 

(734) 283-3350 

Dated: November 20, 2025

Page 4

THOMAS A. KUZMIAK, P.L.L.C. 

ATTORNEY AT LAW 

2222 FORD AVENUE 

WYANDOTTE, MICHIGAN 48192 

METROPLEX MI 480 

21 NOV — 

‘US POSTAGE 

Ee

Sg 

zrasz 

§ 

0006078761 

FIRST- CL; 

Michigan Tax Tribunal 

611 

W. 

Ottawa Street 

Lansing, 

MI 

48933 

sl ls le llega

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