25-001843.pdf
The Huntington National Bank, Petitioner Vs. Township Of Lansing Charter, Respondent · 25-001843-TT
Text extracted from the reviewed PDF, organized by page. OCR and reading order may contain errors; confirm details in the PDF below.
Page 1
U.S. MAIL ADDRESS P.O. Box 2575, EAST LANSING, MI 48826-2575 PHONE: (517) 484-8000 FAX: (517) 484-0041 ALL OTHER SHIPPING LAW FIRM y P.C. 2900 WEST ROAD, SUITE 400 EAST LANSING, MI 48823-6386 JEFFREY J. SOLES KATHERINE WOLF BROADDUS CRISTINA T. PATZELT KATHRYN R. CHURCH GORDON W. VANWIEREN, JR. (OF COUNSEL) MICHAEL D. GRESENS DANIEL R. MARTIN PHILIP G. CLARK MARY.JO D. BANASIK LISA L. SWEM (OF CouNsEL) CHRISTOPHER J. IAMARINO JENNIFER K. STARLIN PIOTR M. MATUSIAK CATHLEEN M. DooLeY ROY H. HENLEY (OF COUNSEL) RAYMOND M. DAViS TIMOTHY T. GARDNER, JR. JESSICA E. MCNAMARA KELLY 5. BowMAN BRADFORD W. SPRINGER (OF COUNSEL) MicHELE R. EADDY IAN F. KOFFLER RYAN J. MURRAY BRIAN D. BAA KIRK C. HERALD FREDRIC G. HEIDEMANN ERIN H. WALZ AUSTIN W. MUNROE RECEIVED ROBERT A. DIETZEL RYAN J. NICHOLSON MACKENZIE D. FLYNN MICHAEL D. GRESENS SEP 1 9 2025 (517) 374-8838 \ mgresens @thrunlaw.com September 15, 2025 MICHIG Michigan Tax Tribunal AN TAX TRIBUNAL ATTN: Chief Clerk P.O. Box 30232 Lansing, Michigan 48909 Re: The Huntington National Bank v Charter Township of Lansing MTT Docket No. 25-001843-TT Parcel No. 33-21-01-02-301-011 Dear Chief Clerk: Enclosed for filing with the Michigan Tax Tribunal in the above-referenced matter please find an original and one (1) copy of the following: 1. Respondent Charter Township of Lansing's Appearance and Notice of Appearance; A Respondent Charter Township of Lansing's Answer to Petition and Affirmative Defenses; and 3. Proof of Service upon Petitioner’s counsel/representative and other interested parties. Please do not hesitate to contact me if you have any questions regarding this matter. Very truly yours, Mithael D. Gresens MDG/keh Enclosures cc: Michelle M. Silvey, Esq. Dr. Deyanira Nevarez Martinez, Secretary, Lansing School District Ms. Maggie Sanders, Supervisor, Charter Township of Lansing
Page 2
STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL The Huntington National Bank, Petitioner, v. Charter Township of Lansing, Respondent. THRUN LAW FIRM, P.C. Attorneys for Respondent Charter Township of Lansing BY: Michael D. Gresens (P52026) 2900 West Road, Suite 400 East Lansing, Michigan 48823 Office Phone: (517) 374-8838 email: mgresens @thrunlaw.com MTT Docket No. 25-001843-TT Parcel No. 33-21-01-02-301-011 Michelle (Mikki) Silvey (P69494) Alex Morse DUCHARME, MCMILLEN & ASSOCIATES, INC. Representatives for Petitioner 9229 Delegates Row, Suite 375 Indianapolis, IN 46240 Office Phone: (317) 689-6467 Mobile Phone: (917) 488-7825 email: msilvey @dmaine.com ANSWER TO PETITION NOW COMES the Respondent, Charter Township of Lansing (the “Township” or “Respondent”), by and through its attorneys of record, and for its Answer to Petitioner The Huntington National Bank’s Petition, asserts the following: 1. Respondent admits the allegations contained in Paragraph 1 of the Petition.
Page 3
- 4. To the extent that Paragraph 4 of the Petition asserts facts, Respondent neither admits nor denies the allegations contained in Paragraph 4 of the Petition, as it lacks knowledge or information sufficient to form a belief as to those allegations, and leaves Petitioner to its proofs. To the extent that Paragraph 4 of the Petition asserts legal conclusions and/or statements, Respondent neither admits nor denies the allegations in Paragraph 4 of Petitioner’s Petition, as no response is required. 5. Respondent admits the allegations contained in Paragraph 5 of the Petition. 6. Respondent admits the allegations contained in Paragraph 6 of the Petition. 7. Respondent admits the allegations contained in Paragraph 7 of the Petition. 8. Respondent admits the allegations contained in Paragraph 8 of the Petition. 9. Respondent admits the allegations contained in Paragraph 9 of the Petition. 10. To the extent that Paragraph 10 of the Petition asserts facts, Respondent neither admits nor denies the allegations contained in Paragraph 10 of the Petition, as it lacks knowledge or information sufficient to form a belief as to those allegations, and leaves Petitioner to its proofs. To the extent that Paragraph 10 of the Petition asserts legal conclusions and/or statements, Respondent neither admits nor denies the allegations in Paragraph 10 of Petitioner’s Petition, as no response is required. 11. Respondent denies the allegations regarding the Petitioner’s assertions regarding the property’s fair market value, true cash value, and taxable value that are contained in Paragraph 11 of Petitioner’s Petition for the reason that same are untrue. The valuations that have been assigned by Respondent to Petitioner's property at issue, as evidenced by the Respondent’s 2025
Page 4
the relevant facts. To the extent that Paragraph 11 of the Petition asserts legal conclusions and/or statements, Respondent neither admits nor denies the allegations in Paragraph 11 of Petitioner’s Petition, as no response is required. 12. Respondent admits the allegations contained in Paragraph 12 of the Petition. 13. Respondent admits the allegations contained in Paragraph 13 of the Petition. 14. Respondent denies the allegations regarding the Petitioner’s assertions regarding the property’s fair market value, true cash value, and taxable value that are contained in Paragraph 14 of Petitioner’s Petition for the reason that same are untrue. The valuations that have been assigned by Respondent to Petitioner's property at issue, as evidenced by the Respondent’s 2025 Property Records (assessment cards) for the parcel, prepared by the Respondent’s Assessing Department and which are attached hereto and incorporated herein by reference as Attachment A, are proper, valid, accurate, consistent and in compliance with Michigan law, and supported by the relevant facts. To the extent that Paragraph 14 of the Petition asserts legal conclusions and/or statements, Respondent neither admits nor denies the allegations in Paragraph 14 of Petitioner’s | Petition, as no response is required. / 15. Respondent denies the allegations regarding the Petitioner’s assertions regarding the property’s fair market value, true cash value, and taxable value that are contained in Paragraph 15 of Petitioner’s Petition for the reason that same are untrue. The valuations that have been assigned by Respondent to Petitioner's property at issue, as evidenced by the Respondent’s 2025 Property Records (assessment cards) for the parcel, prepared by the Respondent’s Assessing Department and which are attached hereto and incorporated herein by reference as Attachment
Page 5
statements, Respondent neither admits nor denies the allegations in Paragraph 15 of Petitioners Petition, as no response is required. 16. Respondent denies the allegations regarding the Petitioner’s assertions regarding the property’s fair market value, true cash value, and taxable value that are contained in Paragraph 16 of Petitioner’s Petition for the reason that same are untrue. The valuations that have been assigned by Respondent to Petitioner's property at issue, as evidenced by the Respondent’s 2025 Property Records (assessment cards) for the parcel, prepared by the Respondent’s Assessing Department and which are attached hereto and incorporated herein by reference as Attachment A, are proper, valid, accurate, consistent and in compliance with Michigan law, and supported by the relevant facts. To the extent that Paragraph 16 of the Petition asserts legal conclusions and/or statements, Respondent neither admits nor denies the allegations in Paragraph 16 of Petitioner’s Petition, as no response is required. a. Respondent denies the allegations regarding the Petitioner’s assertions regarding the property’s fair market value, true cash value, and taxable value that are contained in Paragraph 16(a) of Petitioner’s Petition for the reason that same are untrue. The valuations that have been assigned by Respondent to Petitioner's property at issue, as evidenced by the Respondent’s 2025 Property Records (assessment cards) for the parcel, prepared by the Respondent’s Assessing Department and which are attached hereto and incorporated herein by reference as Attachment A, are proper, valid, accurate, consistent and in compliance with Michigan law, and supported by the relevant facts. To the extent that Paragraph 16(a) of the Petition asserts legal conclusions and/or statements, Respondent neither admits nor denies the allegations in Paragraph 16(a) of Petitioners
Page 6
16(b) of Petitioner’s Petition for the reason that same are untrue. The valuations that have been assigned by Respondent to Petitioner's property at issue, as evidenced by the Respondent’s 2025 Property Records (assessment cards) for the parcel, prepared by the Respondent’s Assessing Department and which are attached hereto and incorporated herein by reference as Attachment A, are proper, valid, accurate, consistent and in compliance with Michigan law, and supported by the relevant facts. To the extent that Paragraph 16(b) of the Petition asserts legal conclusions and/or statements, Respondent neither admits nor denies the allegations in Paragraph 16(b) of Petitioners Petition, as no response is required. c. Respondent denies the allegations regarding the Petitioner’s assertions regarding the property’s fair market value, true cash value, and taxable value that are contained in Paragraph 16(c) of Petitioner’s Petition for the reason that same are untrue. The valuations that have been assigned by Respondent to Petitioner's property at issue, as evidenced by the Respondent’s 2025 Property Records (assessment cards) for the parcel, prepared by the Respondent’s Assessing Department and which are attached hereto and incorporated herein by reference as Attachment A, are proper, valid, accurate, consistent and in compliance with Michigan law, and supported by the relevant facts. To the extent that Paragraph 16(c) of the Petition asserts legal conclusions and/or statements, Respondent neither admits nor denies the allegations in Paragraph 16(c) of Petitioner's Petition, as no response is required. d. Respondent denies the allegations regarding the Petitioners assertions regarding the property’s fair market value, true cash value, and taxable value that are contained in Paragraph 16(d) of Petitioner’s Petition for the reason that same are untrue. The valuations that have been
Page 7
A, are proper, valid, accurate, consistent and in compliance with Michigan law, and supported by the relevant facts. To the extent that Paragraph 16(d) of the Petition asserts legal conclusions and/or statements, Respondent neither admits nor denies the allegations in Paragraph 16(d) of Petitioner’s Petition, as no response is required. WHEREFORE, Respondent Charter Township of Lansing respectfully requests that the Michigan Tax Tribunal enter an Order that: (A) AFFIRMS the taxable values, assessed values, true cash values, and state equalized values that are at issue with respect to the subject property, as determined by the Township's Assessor; (B) DISMISSES the Petitioners’ Petition; and (C) AWARDS Respondent Charter Township of Lansing its costs, including reasonable attorney fees, so wrongfully incurred in defending this action. Respectfully Submitted, THRUN LAW FIRM, P.C. Attorneys for Respondent Charter Township of Lansing Dated: September 15, 2025 em = 2] Michael D. Gresens (P52026) BUSINESS ADDRESS: 2900 West Road, Suite 400 East Lansing, Michigan 48823 Office phone: (517) 484-8000 Fax: (517) 484-0041 Mobile phone: (517) 290-7686 mgresens @thrunlaw.com
Page 8
STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL The Huntington National Bank, Petitioner, Vv. Charter Township of Lansing, Respondent. THRUN LAW FIRM, P.C. Attorneys for Respondent Charter Township of Lansing BY: Michael D. Gresens (P52026) 2900 West Road, Suite 400 East Lansing, Michigan 48823 Office Phone: (517) 374-8838 email: meresens @thrunlaw.com MTT Docket No. 25-001843-TT Parcel No. 33-21-01-02-301-011 Michelle (Mikki) Silvey (P69494) Alex Morse DUCHARME, MCMILLEN & ASSOCIATES, INC. Representatives for Petitioner 9229 Delegates Row, Suite 375 Indianapolis, IN 46240 Office Phone: (317) 689-6467 Mobile Phone: (917) 488-7825 email: msilvey @dmainc.com AFFIRMATIVE DEFENSES TO PETITION NOW COMES the Respondent, Charter Township of Lansing (the “Township” or “Respondent™), by and through its attorneys of record, and for its Affirmative Defenses, states as follows: 1. The Petitioner’s Petition fails to satisfactorily state any cause of action upon which
Page 9
4. Some or all of Petitioner’s claims are barred by the applicable statute of limitations. 5. Petitioner’s Petition does not comply with the pleading requirements of TTR 240 and other rules and regulations related to matters before the Michigan Tax Tribunal. 6. Petitioner failed to exhaust its administrative remedies prior to filing its Petition. 7. Petitioner’s claims are moot. 8. Petitioner fails to allege specific and sufficient facts to set forth a cause of action against the Township and to support its claim for relief. 9. 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). 10. 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). 11. 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 the Township or its agents. 12. 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 the Township’s taxing unit for the year in question. 13. 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 fail to allege specific and sufficient facts to support its allegations that the property’s taxable value is improper. 14. 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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16. 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. 17. 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. 18. The Township has properly and lawfully assessed Petitioner's property and established its taxable value in accordance with statutory and constitutional requirements. 19. Petitioner has failed to pursue its appeal in a timely fashion. 20. The Township reserves the right to amend its Affirmative Defenses to add new defenses, as the same become known to the Township in the course of investigation and/or discovery. WHEREFORE, Respondent Charter Township of Lansing respectfully requests that the Michigan Tax Tribunal enter an Order that: (A) AFFIRMS the taxable values, assessed values, true cash values, and state equalized values that are at issue with respect to the subject property, as determined by the Townships Assessor; (B) DISMISSES the Petitioner’s Petition; and (C) AWARDS Respondent Charter Township of Lansing its costs, including reasonable attorney fees, so wrongfully incurred in defending this action.
Page 11
ATTACHMENT A
Page 12
Printed
on
07/30/2028
Parcel Number:
33-21-01-02-301-011
Jurisdiction:
LANSING CHARTER TWF
County:
INGHAM
Grantor
Grantee
Sale
Sale
‘Terms
of
Sale
Price!
Pate
:
INF REAL
EST.
BANK
367,303.
02/15/2001
03-2FX*'S LENGTH
{
Property Address
1Class: COMMERCIAL-IMPROV |
Building Permitis
2017
LAKE
SING
RD
neo
ANSING PUBLIC SCHOOL
DIST
Ounzr's Name/address
T-G2E
BANK
h
2025
Est
TCV 490,823 TCV/T#A:
LANSING
RD
=
1A
5
[+3
=
of o
[9
©
©
v3
V
=
EY
©
Ist
] ©
&
|%
£2 a
N
ok
Hy
"1
|»
.T
PART
OF Ni
LANSING
MT
48912
®i mproved
Vacant
Land Value Estimates
for
ANS
l
Public
Factors
*
;
Improvements
Description
frontage
Depth
front
pth
1
DIS Haag
| OFF LAKE LA
37,026,000
S§¢
Ft
5.58
200
LOTATION
vel Road
i
17524
SqFt
0.00000
180
]
TON NAT'L BANK
iPavesd
Road
1.25 Total Acres
Total
Est.
Land Velus
=
PC
BOX
162334
|
1808
OX 43218-2334
Land Improvemsnt Cost Estimates
Description
Rate
Size
%
Scod
Cash value
Description
D/%/P:
Asphalt
Paving
3.03
18500
44
25,897
-
Total Estimated Land Improvements True Cash Values
=
28,397
curb
istreet Lights
[Standard Urilicies
Flvengss
H
{Underground Utils.
ry
z (=O
Q "
r
4
ow
= wo
[TN
OF
C/L
OF
#.
1.25%
2
Commants/I
2020
ROLL
- PARKING
Topography of
Site
‘Wetland
The Equal
r.
Copyright
(c}
1929
~ 20C3
Licensed To:
Township
of
Lansing,
County
of Ingham,
Michigan
H
iTleod
Plzin
Zand!
Tribunal’
;
Value,
Othar
Who
when
“hat
143,200,
{
EER
147,300]
i
703,200]
135, 800
:
;
i
103,300
118,200
351, 200]
]
i
201,781C
Tew
Information
herein deemed reliable
but
not guarantesd**~Page 13
Commercial /Industrial Building/Section
1 of
1
Parcel Number:
33-21-01-02-301-011
Printed on
07/30/2025
Desc.
of Bldg/Section:
<<<
Calculator Cost Computations
>>>>>
Calculator Occupancy:
Banks
-
Branch
Class:
C
Quality:
Average
~
Class:
C
Construction Cost
Stories:
1
Story Height:
12
Perimeter:
184
Floor Area:
1,851
.
Overall Building Height:
12
Gross Bldg Area:
1,851
IHigh
{
[Above Ave.
[X [ave.
[
[Tow
Stories Above Grd:
1
¥+
++
Calculator Cost Data
++
+%
Base Rate
for Upper Floors
= 236.16
Average Sty Hght
:
12
Quality: Average
.
A
A
Bsmnt Wall Hght
Heat#1:
Package Heating
& Cooling
100]
{10}
Heating system:
Package Heating
& Cooling
Cost/SqgFt:
29.27
109%
Heat#2:
Package Heating
& Cooling
0¢
{Adjusted Square Foot Cost
for Upper Floors
= 265.43
Depr. Table
+2
Ave. SqFt/Story:
1851
Effective Age
:
37
Ave.
Perimeter:
184
Total Floor Area:
1,851
Base Cost
New of Upper Floors
=
491,311
Physical Good:
47
Has Elevators:
Func.
3%Good
:
100
Reproduction/Replacement Cost
=
491,311
Economic $Good:
100
¥+* Basement Info **w
Eff.Age:37
Phy.3%Good/Abnr.Phy./Func./Econ./Overall $Good:
47 /100/100/100/47.0
.
of
iat
=
1580
J¥ear Built
prea:
Total
Depreciated Cost
230,916
erimeter:
Remodeled
Type: Finished Basement
<<<<
Segregated Cost Computations
C53»
12}0verall Bldg
Heat:
Forced Air Furnace
Costs taken from Segregated Cost Section
5:
Offices,
Banks,
Hospitals
Height
Cost
#
or
Height Storys
* Mezzanine Info
*
Item Desciption
Col.
Rate
SqFt
Adi.
Adj.
Cost
Comments:
Area
#1:
N
Type #1: Office
(No Rates)
(39) Miscellaneous
Area
$2:
Canopies
& Marquees:
Type
B2:
Office
(No Rates)
Steel Frame
1
Up
43.35
1190
1.000
1.000
47,685
* Sprinkler Info
*
Total Cost
of Lump-Sum Items
=
47,685
Area:
Total Cost New
=
47,685
Type: Average
<<<<< Calculations
too long.
See Valuation printout
for complete pricing.
>>>>>
(1) Excavation/Site Prep:
{7}
Interior:
(11)
Electric and Lighting:
(39)
Miscellaneous:
(2)
Foundation:
[Footings
(8)
Plumbing:
1100
Steel
Frame
=
Outlets:
Fixtures:
X Poured Conc
i
[Bzick/Stone]
[Block
Many
Average
Few
Above Ave.
Typical
None
|{X
[Few
X
[Few
.
Average
Average
Total Fixtures
Urinals
Many
Many
(3) Frame:
3-Piece Baths
Rash Bowls
Unfinished
Unfinished
2-Piece Baths
Water Heaters
i
5
x
Typical
Typical
Shower Stalls
Wash Fountains
Toilets
Water Softeners
Flex Conduit
Incandescent
Rigid Conduit
Fluorescent
(4)
Floor Structure:
Armored Cable
Mercury
{40}
Exterior Wall:
Non-Metalic
Sodium Vapor
.
{57
Sprinklers:
Bus Duct
Transformer
[Thickness
[psmos Insul.
{13)
Roof Structure:
Slope=0
{8)
Floor Cover:
(10)
Heating and Cooling:
X
[Gas
Coal
Hand Fired
0il
Stoker
Boiler
(14)
Roof Cover:
{6} Ceilings
bem:
*** Information herein deemed reliable but not guaranteed***Page 14
Parcel Number: 33-21-01-02-301-011, Commercial/Industrial Building 1 Printed on 07/30/2025 3 remote Feller stations | 13 Canopy 25 48 1S Brk on Blk 35 over Craw Space 18 13 bi 19 Sketch by Spex IVWindous™ ald Information herein deemed reliable but not guaranteed
Page 15
07/30/2025
Valuation Report
09:02
AM
DB:
Lansing Twp 2025
33-21~01-02~301-011
2025 Est.
T.C.V.
CITIZENS BANK
Property Class:
201
2017 LAKE LANSING RD
Map
4:
1-02E
LANSING CHARTER TWP
LANSING,
MI
48912
Land Value Estimates
for Land Table 02-00.02-00
SEC
2 OFF LK LANS
*
Factors
*
Description
Frontage
Depth
Front
Depth
Rate
3Adj.
Reason
Value
OFF LAKE LANS
SEC2
37,026.000
sq
Ft
5,58
200
LOCATION
206,431
ROW
17424 sqFt
0.00000
100
[+]
1.25 Total Acres
Total
Est.
Land Value
=
206,431
Land Improvement Cost Estimates
Description
Rate
5ize
% Good
Cash value
D/W/P:
Asphalt Paving
3.03
19500
44
25,997
Total Estimated Land Improvements True Cash Value
=
25,997
Cost Estimates
for Commercial/Industrial Building/Section:
1
Built
1980
Costs are taken from the Banks
- Branch cost schedules.
Lge
Calculator Cost Computations
>>>
Class:
C
Quality:
Average
Stories:
1
Story Height:
12
Perimeter:
184
Overall Building Height:
12
i
Base Rate
for Upper Floors
= 236.16
(10)
Reating system:
Package Heating
& Cooling
Cost/Sqgrt:
29.27
100%
Adjusted Square
Foot Cost
for Upper Floors
= 265.43
Total
Floor Area:
1,851
Base Cost
New of Upper Floors
=
491,311
Reproduction/Replacement Cost
=
491,311
Eff .Rge:37
Phy. %Good/Abnr.Phy./Func./Econ.
/Overall $Good:
47 /100/100/100/47.0
Total Depreciated Cost
=
230,916
E3234
Segregated Cost Computations
>>>»
Costs taken from Segregated Cost Section
5:
Offices,
Banks,
Hospitals
Cost
ff
or
Height Storys
Item Desciption
Col.
Rate
SqFt
Adj.
Adj.
Cost
{39)
Miscellaneous
Canopies
& Marquees:
Steel
Frame
1
Up
13.35
1100
1.000
1.000
47, 685
Total Cost
of Lump~Sum Items
=
47,685
Total Cost
New
=
47,685
Architectural Multiplier:
1.00
Reproduction/Replacenment Cost
=
47,685
EEf.Age: 37
Phy. $Good/Bbnr.
Phy. /Func. /Econ, /Overall $Good:
47 /100/100/100/47.0
Total Depreciated Cost
=
22,412
ECF
(02-00
201
SEC
2 COMMERCIAL)
1.020
=> TCV of Bldg:
1
=
258,395
Replacement Cost/Floor Area= 291.19
Est.
TCV/Floor Area= 139.60Page 16
STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL The Huntington National Bank, Petitioner, v. Charter Township of Lansing, Respondent. THRUN LAW FIRM, P.C. Attorneys for Respondent Charter Township of Lansing BY: Michael D. Gresens (P52026) 2900 West Road, Suite 400 East Lansing, Michigan 48823 Office Phone: (517) 374-8838 email: mgresens @thrunlaw.com MTT Docket No. 25-001843-TT Parcel No. 33-21-01-02-301-011 Michelle (Mikki) Silvey (P69494) Alex Morse DUCHARME, MCMILLEN & ASSOCIATES, INC. Representatives for Petitioner 9229 Delegates Row, Suite 375 Indianapolis, IN 46240 Office Phone: (317) 689-6467 Mobile Phone: (917) 488-7825 email: msilvey @dmainc.com APPEARANCE
Page 17
APPEARANCE TO: Michigan Tax Tribunal ATTN: Chief Clerk Ottawa Building 611 W. Ottawa th 4" Floor Lansing, Michigan 48933 PLEASE ENTER our Appearance as attorneys for Respondent Charter Township of Lansing in the above-entitled cause. Respectfully Submitted, THRUN LAW FIRM, P.C. Attorneys for Respondent Charter Township of Lansing Dated: September 15, 2025 y: Michael D. Gresens (P52026) N BUSINESS ADDRESS: 2900 West Road, Suite 400 East Lansing, Michigan 48823 Phone: (517) 374-8838 Fax: (517) 484-0041 mgresens @thrunlaw.com
Page 18
STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL The Huntington National Bank, Petitioner, v. Charter Township of Lansing, Respondent. THRUN LAW FIRM, P.C. Attorneys for Respondent Charter Township of Lansing BY: Michael D. Gresens (P52026) 2900 West Road, Suite 400 East Lansing, Michigan 48823 Office Phone: (517) 374-8838 email: mgresens @thrunlaw.com MTT Docket No. 25-001843-TT Parcel No. 33-21-01-02-301-011 Michelle (Mikki) Silvey (P69494) Alex Morse DUCHARME, MCMILLEN & ASSOCIATES, INC. Representatives for Petitioner 9229 Delegates Row, Suite 375 Indianapolis, IN 46240 Office Phone: (317) 689-6467 Mobile Phone: (917) 488-7825 email: msilvey @dmainc.com 1aine.com NOTICE OF APPEARANCE
Page 19
NOTICE OF APPEARANCE TO: Michelle (Mikki) Silvey Alex Morse DUCHARME, MCMILLEN & ASSOCIATES, INC. 9229 Delegates Row, Suite 375 Indianapolis, IN 46240 PLEASE TAKE NOTICE that we have this day entered our Appearance on behalf of Respondent Charter Township of Lansing regarding the above-entitled matter. Respectfully Submitted, THRUN LAW FIRM, P.C. Attorneys for Respondent Charter Township of Lansing Dated: September 15, 2025 Michael D. Gresens (P52026) BUSINESS ADDRESS: 2900 West Road, Suite 400 East Lansing, Michigan 48823 Phone: (517) 374-8838 Fax: (517) 484-0041 mgresens@thrunlaw,.com
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS / MICHIGAN TAX TRIBUNAL The Huntington National Bank, Petitioner, v. Charter Township of Lansing, Respondent. THRUN LAW FIRM, P.C. Attorneys for Respondent Charter Township of Lansing BY: Michael D. Gresens (P52026) 2900 West Road, Suite 400 East Lansing, Michigan 48823 Office Phone: (517) 374-8838 email: mgresens @thrunlaw.com MTT Docket No. 25-001843-TT Parcel No. 33-21-01-02-301-011 Michelle (Mikki) Silvey (P69494) Alex Morse DUCHARME, MCMILLEN & ASSOCIATES, INC. Representatives for Petitioner 9229 Delegates Row, Suite 375 Indianapolis, IN 46240 Office Phone: (317) 689-6467 Mobile Phone: (917) 488-7825 email: msilvey @dmainc.com email: amorse @dmaine.com PROOF OF SERVICE STATE OF MICHIGAN ) ss COUNTY OF INGHAM ) Katrina E. Hankamp, being first duly sworn, deposes and says that on the 15th day of September, 2025, she served a copy of the Respondent's Appearance and Notice of Appearance,
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Michelle (Mikki) Silvey DUCHARME, MCMILLEN & ASSOCIATES, INC. 9229 Delegates Row, Suite 375 Indianapolis, IN 46240 Ms. Rosemary Anger Ingham County Equalization Director Courthouse, P.O. Box 319 Mason, Michigan 48854 Dr. Deyanira Nevarez Martinez, Board Secretary Lansing School District 519 West Kalamazoo Street Lansing, Michigan 48933 Ms. Maggie Sanders, Supervisor Charter Township of Lansing 3209 West Michigan Avenue Lansing, Michigan 48917 Ms. Rachel Eubanks, State Treasurer Michigan Department of Treasury 430 West Allegan Street, 1st Floor Lansing, Michigan 48922 Ms. Barb Byrum Ingham County Clerk Courthouse 341 S. Jefferson Mason, Michigan 48854 Mr. John Wolenberg, Secretary Ingham Intermediate School District 2630 W. Howell Road Mason, Michigan 48854 Mr. Scott Cunningham, Township Assessor Charter Township of Lansing 3209 West Michigan Avenue Lansing, Michigan 48917 Ms. Cortney Lightheart, Clerk Charter Township of Lansing 3209 West Michigan Avenue Lansing, Michigan 48917 Ms. LaShunda Thomas, Board Secretary Lansing Community College 411 N. Grand Avenue Lansing, Michj n 48933 Subscribed and sworn to before me in Ingham County, Michigan on September 15, 2025 Carrie L. Watts, Notary Public
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Hp rege HT Fy fy 1 <4 HRU T) Tt IRL 2900 WEST ROAD, SU P.O. Box 257 EAST LANSING, MICHIGAN TO: Michigan Tax Tribu ATTN: Chief Clerk P.O. Box 30232 Lansing, Michigan p b> FIRS p p a» BR a & &