Michigan

135 River LLC Petitioner Vs. City Of Mt Clemens Respondent

Petitioner: 135 River LLC
Respondent: City Of Mt Clemens

Case overview

Docket number: 26-001276-TT
Status: Ready Schedule
CaseType: ET Property
Division: ET
County: Macomb
Judge: No judge assigned

Docket history

Line #	Subject	Filer	Line Ref	Enter Date/Post Mark	Fee	Related Item
5	Answer was received	RESP	Not recorded	08/21/2026	Not recorded	Download
Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Download
4	Proof of service of petition was received.	PET	Not recorded	08/03/2026	Not recorded	Download
Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Download
3	Petition has been verified	PET	1	07/31/2026	Not recorded	Download
Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Download
2	Notice of Docket Number ET	Not recorded	Not recorded	07/31/2026	Not recorded	Download
1	A petition was received.	PET	Not recorded	05/22/2026	$600.00	Download
Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Download

Documents

Answer to Petition 26-001276.pdfRead complete document text →

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

135 River LLC, 

 

 

 

Petitioner, 

 

v 

 

City of Mount Clemens, 

 

 

 

Respondent. 

 

 

 

MTT Docket No. 26-001276 

 

Parcel No. 05-11-1-102-015 

_____________________________________________________________________________/ 

 

BRIAN E. ETZEL (P54905) 

WILLIAMS, WILLIAMS, RATTNER & 

PLUNKETT, P.C. 

Attorney for Petitioner 

380 N. Old Woodward Ave., Suite 300 

(248) 642-0333 

 

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 

_____________________________________________________________________________/ 

 

ANSWER TO PETITION 

AND 

AFFIRMATIVE DEFENSES 

 

ANSWER 

 

Respondent, City of Mount Clemens, by and through its attorneys, Hallahan & 

Associates, P.C., responds to the allegations made in Petitioner’s Petition as follows: 

The Parties 

1. 

Respondent lacks the information and knowledge necessary to respond to the 

truth of the assertions in Paragraph 1 and leaves Petitioner to its proofs. 

 

2. 

Respondent admits the allegations in Paragraph 2. 

 

The Subject Property 

 

3. 

Respondent admits the allegations in Paragraph 3 as to the address and parcel 

number, but leaves Petitioner to its proofs as to the ownership issue.

Page 2

Entire Tribunal Property Tax Answer

Page 2 of 5

Respondent admits the allegations in Paragraph 4.

Respondent admits the allegations in Paragraph 5.

The 2024 Assessment

Respondent admits the allegations in Paragraph 6.

The values for the property identified above as established by Respondent’s

Board of Review for the 2026 tax year are:

Parcel No.

True Cash Value

Assessed Value

Taxable Value

05-11-13-102-015

$3,050,800

$1,525,400

Respondent contends that the values for the property identified above for the 2026

tax year are:

Parcel No.

True Cash Value

State Equalized Value

Taxable Value

05-11-13-102-015

$3,050,800

$1,525,400

The values in dispute for the property identified above for the 2026 tax year are:

Parcel No.

True Cash Value

State Equalized Value

Taxable Value

05-11-13-102-015

10.

Respondent acknowledges Petitioner’s beliefs as the issues relevant to this appeal

but denies said issues have merit. Respondent further denies Petitioner has the right to raise

issues not identified in its Petition at a later date. Moreover, Respondent denies Petitioner is

entitled to any relief.

11.

Respondent denies the allegations in Paragraph 11, including subsections (a)-(d),

for the reason that the same are untrue. The assessed, state equalized and/or taxable values do not

exceed permitted amounts, do not exceed the percentage for true cash value permitted by law,

were correctly determined and are based upon correct application of proper principles, and the

values and Respondent’s mode of assessment are non-discriminatory and constitutional.

12.

Respondent admits the subject property was uniformly assessed. Respondent

denies that the subject property’s values were in any way overestimated

Conclusion and Relief Requested

Page 3

Entire Tribunal Property Tax Answer 

Page 3 of 5 

 

WHEREFORE, Respondent City of Mount Clemens requests the Tribunal dismiss the 

Petition, affirm Respondent’s assessed and taxable values, subject to county and state 

equalization, and award Respondent its costs and attorney fees. 

HALLAHAN & ASSOCIATES, P.C. 

 

/s/Laura M. Hallahan______________ 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

Dated: August 21, 2026 

(248) 731-3089 

 

 

 

AFFIRMATIVE DEFENSES 

 

Respondent, City of Mount Clemens, asserts the following affirmative defenses: 

1. 

Petitioner fails to allege specific and sufficient facts to set forth a cause of action 

against Respondent and to support its claim for relief. 

2. 

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). 

3. 

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). 

4. 

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 Respondent or 

its agents.

Page 4

Entire Tribunal Property Tax Answer 

Page 4 of 5 

 

5. 

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 

Respondent’s taxing unit for the year in question. 

6. 

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 fails to allege specific and sufficient facts 

to support its allegations that the property’s taxable value is improper. 

7. 

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. 

8. 

Petitioner, in essence, asks the Tribunal to grant it an illegal preference by 

application of a method of assessment different from that employed in the assessment of other 

properties in Respondent’s taxing unit. 

9. 

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. 

10. 

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

Page 5

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EntireTribunalCaseISAnswer.pdfRead complete document text →

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MTT DOCKET NO. 26-001276

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government

City Of Mt Clemens (MACOMB)

First Name

M.I.

Last Name

Home Address (No., Street, P.O. Box or Rural Route)

City or Town

State

ZIP Code

Telephone Number

E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail)

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Laura

M.I.

Last Name

Hallahan

Firm Name (if any)

Hallahan & Associates PC

Address (No., Street, P.O. Box or Rural Route)

1750 S. Telegraph Road, Suite 202

City or Town

Bloomfield Hills

State

 Michigan

ZIP Code

48302

Telephone Number

248-731-3089

E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail)

mtt@hallahanlaw.com

Electronic Signature *Typing your name below will serve as your signature

Respondent or Authorized Attorney/Representative’s Signature: 

Seth A. O'Loughlin

/s/

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Proof of Service-Petition-Notice of Docket Number.pdfRead complete document text →

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

135 RIVER, LLC, 

Docket No. 26-001276 

Parcel No. 05-11-13-102-015 

Petitioner, 

v. 

CITY OF MOUNT CLEMENS, 

Respondent. 

Brian E. Etzel (P54905) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

Attorneys for Petitioner 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

bee@wwrplaw.com 

PROOF OF SERVICE OF PETITION AND NOTICE OF DOCKET NUMBER

Page 2

PROOF OF SERVICE OF PETITION AND NOTICE OF DOCKET NUMBER 

Sarah Conner states that she served copies of the Entire Tribunal Property Tax Petition, Notice 

of Docket Number and this Proof of Service, on the persons listed below, by placing copies of those 

documents in a duly stamped, addressed envelope and placing the envelope in the United States mail 

on August 3, 2026. 

PERSONS SERVED: 

VIA CERTIFIED MAIL 

City of Mount Clemens 

Office of the Assessor 

One Crocker Blvd. 

Mount Clemens, MI 48043 

City of Mount Clemens 

Office of the City Clerk 

One Crocker Blvd. 

Mount Clemens, MI 48043 

VIA FIRST CLASS US MAIL 

Macomb County Clerk 

County Clerk's Office 

120 N. Main Street 

Mt. Clemens, MI 48043 

Macomb County 

Director of Equalization 

1S. Main, 6" FL. 

Mt. Clemens, MI 48043 

Mount Clemens Community 

School District 

Secretary of the School Board 

167 Cass Avenue 

Mount Clemens, MI 48043 

State Treasurer 

Michigan Department of Treasury 

Austin Building 

430 W. Allegan 

Lansing, MI 

48922 

adc (rime 

= Sarah Conner

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SubsequentFiling.pdfRead complete document text →

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760

PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906

MICHIGAN TAX TRIBUNAL

Docket Number: 26-001276

Is this case currently pending in the Small Claims Division? No

Party Filing Document 

Petitioner

Files

Document Type: Proof of Service: Petition

Attachment File Name: Proof of Service-Petition-Notice of Docket Number

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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Petition - Manoj Mt. Clemens.pdfRead complete document text →

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

 

135 RIVER, LLC, 

 

 

 

 

 

Docket No. 26- 

 

 

 

 

 

 

 

 

Parcel No. 05-11-13-102-015 

Petitioner, 

 

 

 

 

 

 

 

 

 

 

v. 

 

CITY OF MOUNT CLEMENS, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Brian E. Etzel (P54905) 

 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

Attorneys for Petitioner 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

bee@wwrplaw.com 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

Petitioner 135 RIVER, LLC, by and through its attorneys, Williams, Williams, Rattner & 

Plunkett, PC, states as follows for its Entire Tribunal Property Tax Petition. 

The Parties 

1. 

Petitioner 135 RIVER, LLC is a Michigan limited liability company whose address 

is 380 N Old Woodward Avenue, Suite 300, Birmingham, MI 48009. 

2. 

Respondent City of Mount Pleasant is a Michigan municipal corporation with its 

primary offices located at One Crocker Blvd, Mount Clemens, MI 48043.

Page 2

The Subject Property 

3. 

Petitioner owns property identified as Parcel No. 05-11-13-102-015 and commonly 

known as 135 North River Road, Mount Clemens, MI (the “Subject Property”). 

4. 

The Subject Property is located in Macomb County and is within the Mount 

Clemens Community school district. 

5. 

Respondent possesses jurisdiction to assess and collect property taxes for the 

Subject Property. 

The 2026 Assessment 

6. 

For the 2026 tax year, Respondent classified the Subject Property as commercial 

improved property. 

7. 

For the 2026 tax year, Respondent established the Subject Property’s assessment 

for property taxes as follows: 

True Cash Value 

Assessed Value 

Taxable Value 

 3,050,800 

 1,525,400 

 1,525,400 

 

8. 

Petitioner contends that a lawful assessment of the Subject Property for the 2026 

tax year cannot exceed the following amounts: 

True Cash Value 

Assessed Value 

Taxable Value 

 1,800,000 

 900,000 

 900,000 

 

9. 

The amounts in dispute therefore are as follows: 

True Cash Value 

Assessed Value 

Taxable Value 

 1,250,800 

 625,400 

 625,400 

 

10. 

This Petition presents issues involving the Subject Property’s valuation for 

assessment purposes. Petitioner does not believe that this Petition presents any issues arising out 

of “additions” or “losses” as the General Property Tax Act, MCL 211.1 et seq. (the “GPTA”),

Page 3

defines those terms, but reserves its right to assert issues involving losses should information 

supporting such issues become available. 

11. 

The Subject Property’s 2026 assessment (a) violates the Michigan Constitution, the 

GPTA, and other Michigan law, (b) is based on erroneous principles and information, (c) is based 

on the misapplication of valuation principles, and (d) otherwise violates Petitioner’s rights. 

12. 

Petitioner does not assert that the Subject Property’s 2026 assessment is not 

uniform aside from the lack of uniformity resulting from Respondent overestimating the Subject 

Property’s values. 

Conclusion and Request for Relief 

WHEREFORE, Petitioner respectfully requests that this honorable Tribunal enter 

judgment revising the Subject Property’s 2026 assessment to be consistent with the values set forth 

in Paragraph 8 of this Petition and granting Petitioner all other relief to which it is entitled under 

Michigan law. 

 

 

 

 

 

Respectfully Submitted, 

 

 

 

 

 

 

WILLIAMS, WILLIAMS, RATTNER 

 

 

 

 

 

& PLUNKETT, PC 

 

 

 

 

 

 

 

By: /s/ Brian E. Etzel 

 

 

 

 

 

 

 

 

 Brian E. Etzel (P54905) 

Dated: May 22, 2026 

 

 

Attorneys for Petitioner

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EntireTribunalCaseISPetition.pdfRead complete document text →

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Petitioner

MTT DOCKET NO. 

 

Section 1: Petitioner’s Contact Information

Filer type: 

Organization 

Local Unit of Government

First Name

M.I.

Last Name/Company Name

135 RIVER, LLC

Home Address (No., Street, P.O. Box or Rural Route)

380 N Old Woodward Avenue, Suite 300

City or Town

Birmingham

State

Michigan

ZIP Code

48009

Telephone Number

2486420333

E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail)

beetzel@wwrplaw.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Brian

M.I.

E

Last Name

Etzel

Firm Name (if any)

Williams Williams Rattner & Plunkett PC

Address (No., Street, P.O. Box or Rural Route)

380 N. Old Woodward Ave., Ste. 300

City or Town

Birmingham

State

Michigan

ZIP Code

48009

Telephone Number

2486420333

E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail)

BEEtzel@wwrplaw.com

 

Section 3: Issue 

Please designate one: 

Valuation 

 

Section 4: Subject Property Information 

How many parcels are you 

appealing?

1

Property Address (No., Street, City, ST, ZIP) [If multiple, list first property’s address]

135 North River Road

Mount Clemens

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48043

Taxing Authority (City or Township)

City Of Mt Clemens (MACOMB) 

County

Macomb

If you are appealing more than one parcel, are they contiguous or adjoining? 

(*If no, you must file separate appeals for each non-contiguous or non-adjoining parcel.)

N/A

 

 

Section 5: Check which of the following you are appealing (check all that apply) 

True Cash and Taxable Values

If “Other”, please explain:

 

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

05-11-13-102-015

Classification of Property: Real (check one)

Commercial (check one)

Current Assessed Value (also known as State Equalized Value) as established by the Board of Review:

1525400

Current Taxable Value as established by the Board of Review:

1525400

What do you believe is the fair market value (also known as True Cash Value)?

1800000

Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value).

900000

If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value.

900000

Fee Information

The filing fee is based on the greater of State Equalized Value or Taxable Value in contention. If you are appealing more than one parcel, the parcel with the 

highest State Equalized Value or Taxable Value in contention will be used to determine your filing fee, plus $25.00 will be added for each additional parcel being 

appealed.

If the State Equalized Value or Taxable Value in contention is: Your filing fee is:

 

 $100,000.00 and under $250.00

 $100,000.01 to $500,000.00 $400.00

 $Over $500,000.00 $600.00

* Plus $25.00 for each additional parcel, not to exceed a total filing fee of $2,000.00.

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

A fee of $250.00 is required for the filing of a Special Assessment Appeal.

A fee of $250.00 is required for the filing of an Equalization Tax Appeal.

A fee of $250.00 is required for the filing of a Non-Property Tax Appeal.

A fee of $150.00 is required for the filing of a Classification Tax Appeal

Electronic Signature *Typing your name below will serve as your signature

Petitioner or Attorney/Authorized Representative’s Signature: 

/s/ Brian E. Etzel

Payment Information

Amount: 600

Success: True

Message: ""

Waiver Code:

Transaction Number: 26052286578439

Supporting Waiver Documents:

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ET_Notice_of_Docket_Number.2026-07-31_17-30-50.pdfRead complete document text →

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760

PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906

135 RIVER LLC,

Petitioner,

MICHIGAN TAX TRIBUNAL

MTT Docket No.: 26-001276

City Of Mt Clemens,

Respondent.

NOTICE OF DOCKET NUMBER

TAKE NOTICE that an Entire Tribunal petition has been filed and the above-noted

docket number has been assigned to that petition. This docket number shall be noted

on the petition and the petition shall be served within 45 days of the issuance of

this notice, as required by TTR 227 and MCL 205.735a, even if the petition was served

when filed. A proof of service shall also be filed with the Tribunal within 45 days of the

issuance of this notice evidencing the service of the petition.

If you submitted a proof of service with the petition, you must still serve the petition and

file a second proof of service including the docket number, pursuant to this notice.

Failure to serve the petition and file a proof of service within 45 days of the issuance of

the notice may result in the dismissal of this case.

Under TTR 235(1), “[t]he respondent shall file an answer or responsive motion within 28

days after the date of service of the petition with noted docket number.” Failure to do so

will result in Respondent being placed in default.

The docket number also needs to be noted on all other documents submitted in this

case. Further, the assignment of the docket number does not mean that the Tribunal

has authority over the petition or that the petition complies with statutory requirements

or the Tribunal’s rules.

By: Tribunal Clerk

Entered: July 31, 2026

PROOF OF SERVICE

I certify that a copy of the foregoing was sent on the entry date indicated above to the

parties or their attorneys or authorized representatives, if any, utilizing either the mailing

or email addresses on file, as provided by those parties, attorneys, or authorized

representatives.