Associated Bank - Motion re City of Southfield.pdf
Associated Bank Na, Petitioner Vs. City Of Southfield, Respondent · 25-001973-TT
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127479.000001 4916-9518-2219.1 DYKEMA GOSSETT PLLC • 39577 Woodward Avenue, Suite 300, Bloomfield Hills, Michigan 48304 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL ASSOCIATED BANK N.A., Petitioner, v. CITY OF SOUTHFIELD, Respondent. MTT Docket No. 25-001973 Parcel ID No. 76-24-22-201-019 Douglas J. Fryer (P51765) DYKEMA GOSSETT PLLC Attorneys for Petitioner 39577 Woodward Avenue, Suite 300 Bloomfield Hills, MI 48304 (248) 203-0700 dfryer@dykema.com Laura M. Hallahan (P42101) Seth A. O’Loughlin (P80257) Kelsea M. Melcher (P85821) HALLAHAN & ASSOCIATES, P.C. Attorneys for Respondent 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302 (248) 731-3089 lhallahan@hallahanlaw.com soloughlin@hallahanlaw.com PETITIONER’S MOTION TO WITHDRAW PETITION Petitioner Associated Bank, N.A. (“Petitioner”), for its motion to withdraw Petition pursuant to TTR 237(4), states as follows: 1. On May 30, 2023, Petitioner filed its Entire Tribunal Property Tax Petition (the “Petition”), seeking a reduction in the true cash and taxable values for the subject property. 2. On September 18, 2025, Respondent City of Southfield (“Respondent”) filed its Answer to Petition, denying the requested relief. 3. TTR 237(4) provides: A petition may be withdrawn upon a motion filed by the petitioner before the answer or first responsive motion has been filed with the tribunal. Once the answer or first responsive motion has been filed, a petition may be withdrawn upon motion filed by petitioner only if the
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DYKEMA GOSSETT PLLC • 39577 Woodward Avenue, Suite 300, Bloomfield Hills, Michigan 48304 other parties do not object to the withdrawal for substantive reasons. For purposes of this subrule, a request for costs is not a substantive reason. 4. By its motion, Petitioner requests that this Tribunal enter an order providing that the Petition is withdrawn, and that the case is therefore closed. 5. On January 23, 2026, Petitioner’s counsel contacted Respondent’s counsel and advised of its intent to file a motion to withdraw its Petition. Respondent’s counsel advised that Respondent does not object to the withdrawal. As such, withdrawal of the Petition at this time fully comports with TTR 237(4). WHEREFORE, Petitioner requests that the Tribunal grant its motion to withdraw the Petition and close the case. January 29, 2026 Respectfully Submitted, By: /s/ Douglas J. Fryer Douglas J. Fryer (P51765) DYKEMA GOSSETT PLLC 39577 Woodward Avenue, Suite 300 Bloomfield Hills, MI 48304 (248) 203-0700 dfryer@dykema.com
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DYKEMA GOSSETT PLLC • 39577 Woodward Avenue, Suite 300, Bloomfield Hills, Michigan 48304 CERTIFICATE OF SERVICE I hereby certify that on January 29, 2026, I served the foregoing Motion, upon counsel for Respondent, via email and first class mail, as follows: Laura M. Hallahan (P42101) HALLAHAN & ASSOCIATES, P.C. Attorneys for Respondent 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302 lhallahan@hallahanlaw.com I declare that the statement above is true to the best of my information, knowledge and belief. By: /s/ Denise Shiemke Denise Shiemke Assistant to Douglas J. Fryer Dykema Gossett PLLC