26-000745.pdf

Tsfr Apple Venture, LLC Petitioner Vs. Township Of Dundee Respondent · 26-000745-TT

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LAW OFFICES 

PETRANGELO BONDY & CROSSLEY 

PROFESSIONAL CORPORATION 

212 EAST FIRST STREET 

i 

MONROE, MICHIGAN 48161 

RECEIVED 

TELEPHONE (734) 241-6470 

| AUG 0 4 2026 

TELEFACSIMILE (734) 241-3849 

TRIBUNAL 

MICHIGAN TAX 

July 27, 2026 

Samantha Welton, Chief Clerk 

Michigan Tax Tribunal 

PO Box 30232 

Lansing, MI 48909 

Re: 

 TSFR Apple Venture, LLC vs. Dundee Township 

MTT Docket No. 26-000745 

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 

0 

Kerry L. Bondy 

KLB/smr 

cc: Bryan Renius, Assessor (via email to dundeetownshipassessing@yahoo.com) 

Dundee Township

PETRANGELO BONDY & CROSSLEY. PROFESSIONAL CORPORATION 

STATE OF MICHIGAN 

DEPARTMENT OF CONSUMER AND INDUSTRY SERVICES 

MICHIGAN TAX TRIBUNAL 

TSFR APPLE VENTURE, LLC, 

Petitioner, 

: 

vs. 

Docket No. 26-000745 

DUNDEE TOWNSHIP, 

Respondent. 

JEROME P. PESICK (P29039) 

KERRY L. BONDY (P42786) 

JASON C. LONG (P59244) 

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, MI 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 Petitioner's 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. 

3. 

Respondent denies the allegation contained in paragraph 3 of the Petition for 

the reason that it is untrue. According to the records on file with the Township of Dundee, 

Dundee 119, LLC is the record owner.

PETRANGELO BONDY & CROSSLEY. PROFESSIONAL CORPORATION 

7. 

Respondent admits the allegations contained in paragraph 7 of the Petition. 

8. 

Respondent denies the allegation contained in paragraph 8 of the Petition for 

the reason that it is untrue. 

9. 

Respondent neither admits nor denies the allegation contained in paragraph 9 

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. 

10. 

Respondent neither admits nor denies the allegation contained in paragraph 10 

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. 

11. 

Respondent denies the allegation contained in paragraph 11 of the Petition for 

the reason that it is untrue. 

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. 

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 BONDY & CROSSLEY, P.C. 

July 27, 2026 

\& ul 

By: 

Kerry 

L. Bondy 

Attorney for Yond ent 

AFFIRMATIVE DEFENSES 

NOW COMES Respondent Dundee Township and for its Affirmative Defenses states 

as follows: 

1. 

Petitioner is not the record owner of the property which is the subject of the

PETRANGELO BONDY & CROSSLEY. PROFESSIONAL CORPORATION 

3. 

According to the records of Dundee Township, Dundee 119, LLC is the record 

owner of the real property at issue in the Petition. 

4, 

Petitioner was not the owner of record of the subject property or a party in 

interest as of the applicable tax day and therefore this Tribunal does not have jurisdiction to 

hear this appeal pursuant to MCL 205.735(a). 

5. 

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. 

6. 

Respondent reserves the right to raise additiona! 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. 

July 27, 2026 

V Ji 

By: Kerry L\Bondy 

| 

Attorney for Respondent 

answerdundeeTSFRpd

PETRANGELO BoNDY & CROSSLEY, PROFESSIONAL CORPORATION 

STATE OF MICHIGAN 

DEPARTMENT OF CONSUMER AND INDUSTRY SERVICES 

MICHIGAN TAX TRIBUNAL 

TSFR APPLE VENTURE, LLC 

Petitioner, 

vs. 

Docket No. 26-000745 

DUNDEE TOWNSHIP, 

Respondent. 

JEROME P. PESICK {P29039) 

KERRY L. BONDY (P42786) 

JASON C. LONG {P59244) 

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, MI 48009 

(734) 241-6470 

(248) 642-0333 

PROOF OF SERVICE 

On July 27, 2026, 

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

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

Jerome P. Pesick 

Jason C. Long 

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

Attorneys for Petitioner 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, M! 48009 

Annamarie Osment 

Monroe County Clerk 

106 E. First Street 

Monroe, M148161

PETRANGELO BONDY & CROSSLEY. PROFESSIONAL CORPORATION 

Dundee Community Schools 

School Board Secretary 

420 Ypsilanti 

Dundee, MI 48131 

Secretary of School Board 

Monroe County Intermediate School District 

1101 S. Raisinville Rd. 

Monroe, M1 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 

20 

¥ 

with postage prepaid. 

July 27,2026 

tsfrPOMpd 

Uhovoe UN 

Sharon M. Ringel

LAW OFFICES 

PETRANGELO BONDY & CROSSLEY 

PROFESSIONAL CORPORATION 

212 EAST FIRST STREET 

MONROE, MICHIGAN 48161 

Samantha Welton, Chief Clerk 

YH 

7] 

Michigan Tax Tribunal 

2 

PO Box 30232 

9207 

£0 9nY 

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Lansing, MI 48909 

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PaAleoay 

|

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