26-000457.pdf

Dundee Place Apartments, LLC; Dundee Place Apartments II, LLC; Dundee Place Petitioner Vs. Township Of Dundee Respondent · 26-000457-TT

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RECEIVED 

JUN 2 2 2026 

LAW OFFICES 

PETRANGELO BONDY & CROSSLEY 

PROFESSIONAL CORPORATION 

212 EAST FIRST STREET 

MONROE, MICHIGAN 

48161 

MICHIGAN TAX TRIBUNAL 

TELEPHONE (734) 241-6470 

TELEFACSIMILE (734) 241-3849 

June 18, 2026 

Samantha Welton, Chief Clerk 

Michigan Tax Tribunal 

PO Box 30232 

Lansing, MI 48909 

Re: 

Dundee Place Apartments, LLC; Dundee Place Apartments Il, LLC; Dundee Place 

Apartments lll, LLC; and Dundee Place Apartments IV, LLC vs. Dundee Township 

MTT Docket No. 26-000457 

Dear Ms. Welton: 

Enclosed please find Respondent Dundee Township's Answer to Petitioners’ Petition 

and Affirmative Defenses in the above named matter along with a Proof of Service. 

Very truly yours, 

PETRANGELO BONDY & CROSSLEY 

Professional Corporation 

Kerry LMBondy 

KLB/smr

PETRANGELO BONDY & CROSSLEY. PROFESSIONAL CORPORATION 

STATE OF MICHIGAN 

DEPARTMENT OF CONSUMER AND INDUSTRY SERVICES 

MICHIGAN TAX TRIBUNAL 

DUNDEE PLACE APARTMENTS, LLC; 

DUNDEE PLACE APARTMENTS iI, LLC; 

DUNDEE PLACE APARTMENTS Hil, LLC; and 

DUNDEE PLACE APARTMENTS IV, LLC, 

Petitioners, 

vs. 

Docket No. 26-000457 

DUNDEE TOWNSHIP, 

Respondent. 

JASON C. LONG (P59244) 

KERRY L. BONDY (P42786) 

JEROME P. PESICK (P29039) 

PETRANGELO BONDY & CROSSLEY, P.C. 

WILLIAMS, WILLIAMS, RATTNER & PLUNKETT, P.C. 

Attorney for Respondent 

Attorneys for Petitioner 

212 E. First St. 

380 N. Old Woodward Ave., Ste. 300 

Monroe, MI 48161 

Birmingham, Ml 48009 

(734) 241-6470 

(248) 642-0333 

RESPONDENT'S ANSWER TO PETITION 

NOW COMES Respondent Dundee Township by and through its attorney, Kerry L. Bondy 

in answer to Petitioners’ Petition and states as follows: 

1. 

Respondent neither admits nor denies the allegation contained in paragraph 1 

of the Petition for the reason that Respondent lacks knowledge or information sufficient to 

form a belief as to the truth or falsity of the allegation. 

2, 

Respondent admits the allegations contained in paragraph 2 of the Petition.

PETRANGELO BONDY & CROSSLEY. PROFESSIONAL CORPORATION 

4. 

Respondent admits the allegations contained in paragraph 4 of the Petition. 

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. 

Respondent denies the allegation contained in paragraph 10 of the Petition for 

the reason that it is untrue. 

11. 

Respondent neither admits nor denies the allegation contained in paragraph 

11 of the Petition for the reason that Respondent lacks knowledge or information sufficient to 

form a belief as to the truth or falsity of the allegation. 

12, 

Respondent neither admits nor denies the allegation contained in paragraph 

12 of the Petition for the reason that Respondent lacks knowledge or information sufficient to 

form a belief as to the truth or falsity of the allegation. 

13. 

Respondent denies the allegation contained in paragraph 13 of the Petition for 

the reason that it is untrue. 

14. 

Respondent neither admits nor denies the allegation contained in paragraph 

14 of the Petition for the reason that Respondent lacks knowledge or information sufficient to 

form a belief as to the truth or falsity of the allegation. 

WHEREFORE, Respondent Dundee Township hereby requests that this Honorable 

Tribunal dismiss the Petition filed 

in the above named matter, affirm the assessment of 

Respondent and award costs and attorney fees-to Respondent as appropriate. 

PETRANGELO|BOMDY 

& CROSSLEY, P.C. 

June 18, 2026 

: 

{C

PETRANGELO BONDY & CROSSLEY. PROFESSIONAL CORPORATION 

AFFIRMATIVE DEFENSES 

NOW COMES Respondent Dundee Township and for its Affirmative Defenses states as 

follows: 

1. 

The appropriate methods of assessing the Subject Properties were used and those 

methods conform to the methods used to assess similarly situated property in the State. 

2. 

Upon information and 

belief, Petitioners are four separate and distinct entities 

which separately own the four individual properties which are the subject of the appeal as of 

the applicable tax day and therefore this Tribunal does not have jurisdiction to hear this appeal 

as to four separately owned parcels pursuant to MCL 205.735(a) et seq. 

3 

Petitioners 

lack standing 

te file the 

Petition 

as to 

properties for which 

the 

Petitioners are not the record owner. 

4. 

Respondent reserves the right to raise additional affirmative defenses as they 

become known. 

WHEREFORE, Respondent Dundee Township requests that 

this Honorable Tribunal 

dismiss the Petition filed in the above named matter, affirm the assessments of Respondent and 

award costs and attorney fees to Respondent as appropriate. 

PETRANGELO BONDY & CROSSLEY, P.C. 

June 18, 2026 

\Cs~ <M 

By: 

Kerry |. Bondy 

ery 

for Respoldent 

answerdundeeplacepd

PETRANGELO BONDY & CROSSLEY. PROFESSIONAL CORPORATION 

STATE OF MICHIGAN 

DEPARTMENT OF CONSUMER AND INDUSTRY SERVICES 

MICHIGAN TAX TRIBUNAL 

DUNDEE PLACE APARTMENTS, LLC; 

DUNDEE PLACE APARTMENTS II, LLC; 

DUNDEE PLACE APARTMENTS lI, LLC; and 

DUNDEE PLACE APARTMENTS IV, LLC, 

Petitioners, 

vs. 

Docket No. 26-000457 

DUNDEE TOWNSHIP, 

Respondent. 

JASON C. LONG (P59244) 

KERRY L. BONDY (P42786) 

JEROME P. PESICK (P29039) 

PETRANGELO BONDY & CROSSLEY, P.C. 

WILLIAMS; WILLIAMS, RATTNER & PLUNKETT, P.C. 

Attorney for Respondent 

Attorneys for Petitioner 

212 E. First St. 

380 N. Old Woodward Ave., Ste. 300 

Monroe, M1 48161 

Birmingham, M1 48009 

(734) 241-6470 

(248) 642-0333 

PROOF OF SERVICE 

On June 18, 2026, 

| served a copy of Dundee Township's Answer to Petitioners’ Petition 

and Affirmative Defenses in the above named matter upon the following individuals: 

Jason C. Long 

Jerome P. Pesick 

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

Attorneys for Petitioner 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

Annamarie Osment

PETRANGELO BONDY & CROSSLEY. PROFESSIONAL CORPORATION 

Dundee Community Schools 

School Board Secretary 

420 Ypsilanti 

Dundee, M148131 

Secretary of School Board 

Monroe County Intermediate School District 

1101S. Raisinville Rd. 

Monroe, MI 48161 

State Treasurer 

Michigan Department of Treasury 

Treasury Building 

430 W. Allegan St. 

Lansing, MI 48922 

by sending a copy of said document to the individuals above at the address above by U.S. mail 

with postage prepaid. 

ND 

June 18, 2026 

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Sharon M. Ringel 

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