Motion to set aside default.pdf

Daniel Zuckerbrod, Petitioner Vs. City Of Southfield, Respondent · 24-004053-TT

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STATE OF MICHIGAN 

 

IN THE MICHIGAN TAX TRIBUNAL 

 

Daniel Zuckerbrod, 

 

 

 

Petitioner, 

 

vs. 

 

City of Southfield, 

 

 

 

Respondent. 

 

Docket no. 24–004053 

____________________________________________________________________/ 

 

DEAN & FULKERSON, P.C. 

Thomas P. Christy (P55593) 

Attorneys for Petitioner 

100 West Big Beaver Road, Suite 650 

Troy, Michigan 48084 

248–362–1300/fax –1358 

tchristy@dflaw.com 

 

HALLAHAN & ASSOCIATES 

Laura M. Hallahan (P42101) 

Seth A. O’Loughlin (P80257) 

Kelsea M. Melcher (P85821) 

Attorneys for Respondent 

1750 South Telegraph Road, Suite 202 

Bloomfield Hills, Michigan 48302 

248–731–3089 

lhallahan@hallahanlaw.com 

____________________________________________________________________/ 

 

MOTION TO SET ASIDE DEFAULT 

The petitioner states for his motion: 

1. On April 4, 2025, the tribunal entered a default for failure to file proof of 

service of the severed petition in this case. 

2. On April 18, 2025, the petition filed a proof of service. 

3. On May 27, 2025, the tribunal found that the proof of service did not 

reflect adequate service and extended the time to cure the default. 

4. On June 6, 2025, the petitioner filed a proof of service showing proper 

service.

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5. On June 23, 2025, the tribunal noted that the petitioner failed to file a 

motion with the revised proof of service and extended the time to cure the default 

to file this motion. 

6. The petitioner now moves to set aside the April 4, 2025 default in its 

entirety. 

 

 

Dated: July 7, 2025 

Respectfully submitted, 

 

DEAN & FULKERSON, P.C. 

 

By: /s/ Thomas P. Christy (P55593) 

Attorneys for Petitioner 

100 West Big Beaver Road, Suite 650 

Troy, Michigan 48084 

248–362–1300/fax –1358 

tchristy@dflaw.com 

 

PROOF OF SERVICE 

Thomas P. Christy states that on July 7, 2025, he served a copy of this 

document upon Laura Hallahan by e-mail at lhallahan@hallahanlaw.com as 

permitted by TTR 221(11). I declare that the above statements are true to the 

best of my information, knowledge, and belief. 

 

Dated: July 7, 2025 

/s/ Thomas P. Christy

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