Amee L OLeary, Petitioner V City Of Lansing, Respondent

Page 1

Page 1 of 2 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

 

 

AMEE L OLEARY, 

 

Petitioner, 

 

v. 

 

 

 

Case No. 25-003705-TT 

SMALL CLAIMS DIVISION 

 

CITY OF LANSING, 

 

Respondent. 

 

 

Amee L Oleary 

In Pro Per 

1986 Navaho Trial 

Okemos, MI 48864 

(517) 719-5676 

ameeoleary@mac.com 

 

 

Gregory S. Venker (P81780) 

Matthew D. Staples (P84571) 

Attorney for Respondent 

124 W. Michigan Ave., 5th Floor 

Lansing, MI 48933 

(517) 483-4320 

CityAtty@lansingmi.gov 

matthew.staples@lansingmi.gov 

 

WITHDRAWAL OF APPEARANCE OF PATRICK J. ABOOD AS COUNSEL OF 

RECORD FOR RESPONDENT 

 

PLEASE TAKE NOTICE that Patrick J. Abood hereby withdraws his Appearance in the 

captioned matter as counsel of record for Respondent. 

Attorney Matthew D. Staples and the Office of the City Attorney remain as counsel of 

record for Respondent. 

Date: August 17, 2026 

 

 

 

 

/s/ Patrick J. Abood 

 

 

 

Patrick J. Abood (P86987) 

 

/s/ Matthew D. Staples 

 

 

 

 

 

 

 

 

 

 

Matthew D. Staples (P84571) 

Attorneys for Respondent 

124 W. Michigan Avenue, 5th Floor

Page 2

Page 2 of 2 

 

Lansing MI 48933 

(517) 483-4320 

 

 

 

 

 

 

 

 

matthew.staples@lansingmi.gov 

 

PROOF OF SERVICE 

 

This is to certify that on August 17, 2026, I filed the Withdrawal of Appearance of Patrick 

J. Abood as Counsel of Record for Respondent with the Michigan Tax Tribunal, via electronic 

filing system and sent hard copies of the same to: Amee L OLeary, via first class mail to: 1986 

Navaho Trail, Okemos, MI 48864. 

 

I declare that the statements above are true to the best of my information, knowledge, and 

belief. 

Date: August 17, 2026 

 

 

 

 

/s/ Matthew D. Staples 

 

 

 

 

 

 

 

 

 

 

Matthew D. Staples (P84571) 

Attorneys for Respondent 

124 W. Michigan Avenue, 5th Floor 

Lansing MI 48933

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

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: 25-003705

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

Party Filing Document 

Respondent

Files

Document Type: Motion to Withdraw Counsel

Attachment File Name: PJA withdrawal - Amee L O'Leary

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

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

Amee L OLeary,

Petitioner,

MICHIGAN TAX TRIBUNAL

SMALL CLAIMS DIVISION

v 

MTT Docket No. 25-003705

City Of Lansing,

Respondent.

NOTICE OF FILING

TAKE NOTICE that a Small Claims answer has been filed and the electronic copy of the 

answer can be reviewed by utilizing the Docket Lookup on the Tribunal’s website. 

Unless Respondent was defaulted, this case is ready to be scheduled for a Small 

Claims hearing and will be scheduled in the normal course of scheduling. You will 

receive a Notice of Hearing from the Tribunal by e-mail if you have identified an email 

address in the petition or other documentation. The Notice of Hearing will inform you of 

the date, time, and location of your hearing (note that your hearing will likely be 

conducted by telephone). Please read the Notice of Hearing as it includes important 

information.

EVIDENCE: Parties are required to submit all evidence to the Tribunal and send a copy 

to the opposing party at least 21 days before the hearing date even if the documents 

had been submitted to the local Board of Review or the Michigan Department of 

Treasury. If the documents are not timely submitted to the Tribunal and served on the 

opposing party, the documents may be excluded. Documents may be filed with the 

Tribunal by mail or through the Tribunal’s e-filing system. Documents may be sent to the 

opposing party by mail or by e-mail, if the parties agree to service by e-mail.

Users who file documents with the Michigan Tax Tribunal are advised that filed 

documents are public records and will appear for public viewing on the Tax 

Docket Lookup. Users who file documents are responsible for ensuring sensitive or 

personal identifying information is withheld or redacted. See TTR 209. If a user wishes 

to file a document for consideration by the Michigan Tax Tribunal and prevent its 

publication on the Tax Docket Lookup, the user MUST file a Motion for Protective Order 

under MCR 2.302(C)(8). If a Protective Order is issued, documents covered by the 

Order will not be published. Documents filed prior to the issuance of a Protective Order 

will be published.

The responsibility for excluding or redacting personal identifying information (PII) from 

all documents filed with or offered to the Tribunal rests solely with the parties and 

their attorneys. The Tribunal is not responsible for or required to review, redact, or 

screen documents at the time of filing for PII whether filed electronically or on paper. A 

party, representative, or interested person (i.e. third party not part of an appeal) may 

request that the Tribunal redact PII contained in a previously-filed document by

Page 2

MTT Docket No. 25-003705

Page 2 of 6

submitting a Request for Redactions. The Request for Redactions form will be 

available on the Entire Tribunal and Small Claims pages of our website. 

Alternate Dispute Resolution Options

INFORMAL SETTLEMENT CONFERENCE: Parties have the option of handling this 

case through an informal settlement conference. An informal settlement conference 

is a meeting between the parties and/or their representatives to discuss the issues in a 

case in an effort to settle the case. This process may be an alternative to a hearing with 

a judge and may result in the parties’ filing a Joint Stipulation for Entry of Consent 

Judgment. Visit the Tribunal’s ADR webpage for more information.

NOTE: The parties may not request an informal settlement conference to discuss an 

appeal of a principal residence exemption that was denied by either the Michigan 

Department of Treasury or a County. Also, state taxes levied by the Michigan 

Department of Treasury, such as income taxes, are not subject to the informal 

settlement conference process.

MEDIATION: Parties have the option of handling this case through mediation. 

Mediation is a voluntary process where a mediator facilitates communication between 

the parties, assists in identifying issues, and helps explore solutions to promote a 

mutually acceptable settlement. This process may be an alternative to a hearing with a 

judge and may result in the parties’ filing a Joint Stipulation for Entry of Consent 

Judgment. Visit the Tribunal’s ADR webpage for more information.

If you have any questions, please contact the Tribunal by phone at (517) 335-9760 or 

email taxtrib@michigan.gov.

By: Tribunal Clerk

Entered: December 15, 2025

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.

By: Tribunal Clerk

Page 3

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

Amee L OLeary,

Petitioner,

MICHIGAN TAX TRIBUNAL

SMALL CLAIMS DIVISION

v 

MTT Docket No. 25-003705

City Of Lansing,

Respondent.

NOTICE OF FILING

TAKE NOTICE that a Small Claims answer has been filed and the electronic copy of the 

answer can be reviewed by utilizing the Docket Lookup on the Tribunal’s website. 

Unless Respondent was defaulted, this case is ready to be scheduled for a Small 

Claims hearing and will be scheduled in the normal course of scheduling. You will 

receive a Notice of Hearing from the Tribunal by e-mail if you have identified an email 

address in the petition or other documentation. The Notice of Hearing will inform you of 

the date, time, and location of your hearing (note that your

Page 4

M

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

Page 1

Resolution #2025-231 

By the Committee of the Whole 

Resolved by the City Council of the City of Lansing 

WHEREAS, 

the 

City 

of Lansing 

desires 

to encourage 

and 

support shopping 

and 

commercial activity 

in the Principal Shopping District area by public improvement to 

develop, 

redevelop, 

promote economic 

activity, 

and 

provide 

for the maintenance, 

security, and operation of the Principal Shopping District by such public improvement 

which especially benefits any property within a district; and 

WHEREAS, the City of Lansing desires to encourage promotional efforts, business 

recruitment in all zones and physical improvements and maintenance services (in zone 

"A") of the Principal Shopping District; and 

WHEREAS, the City of Lansing has determined that this should be provided through 

special assessment zones established for the purpose of financing Principal Shopping 

District activities; and 

WHEREAS, the City of Lansing has determined that the cost of providing such services 

should be recovered by a special assessment against properties especially benefited as 

authorized by Act No. 120 of the Public Acts of 1961, as amended, and Chapters 812 and 

1026 of the Lansing Code of Ordinances; and 

WHEREAS, 

the 

City 

of Lansing 

has 

reviewed 

the 

proposed 

special assessment 

boundaries; and 

WHEREAS, the City of Lansing has also reviewed the proposed services within the 

boundaries with an estimated cost of these services; and 

WHEREAS, a public hearing was held on September 22, 2025, in the Tony Benavides 

Lansing City Council Chamber, 10" Floor City Hall, Lansing, Michigan to consider the 

establishment of the Principal Shopping District special assessment roll; and 

WHEREAS, notice to the affected owners of the properties in said district were given at 

least a 12 (twelve) day notice prior to the date of the hearing and 

in accordance with 

Chapter 1026 of the Lansing Code of Ordinances. 

NOW, THEREFORE, BE 

IT RESOLVED that the special assessment zones for the 

Principal Shopping District are established by City Council as follows:

Page 2

S. Capitol Avenue, north along the S. Capitol Avenue center-line to the center-line of W. 

Saginaw Street, east along the W. Saginaw Street center-line to the west right-of-way line 

of N. Washington Avenue, north along the N. Washington Avenue right-of-way line to the 

north right-of-way line of W. Grand River Avenue, east along the W. Grand River Avenue 

right-of-way line to the west right-of-way line of Turner Street, north along the Turner 

Street right-of-way line to the north right-of-way line of Clinton Street, east along Clinton 

Street right-of-way to the east right-of-way line of Center Street, south along the Center 

Street right-of-way line to the north right-of-way line of Liberty Street, east along’ the 

Liberty Street right-of-way line to the centerline of N. Cedar Street, south along the N. 

Cedar Street center-line to the south right-of-way line of East Grand River Avenue, east 

along the E. Grand River Avenue right-of-way line to the west right of-way line of N. Larch 

Street, 

south 

along 

the 

N. 

Larch 

Street 

right-of-way 

line 

to 

the center-line 

of 

E. 

Shiawassee Street, east along the E. Shiawassee Street center-line to the west right-of- 

way line of the Conrail right-of-way, south along the Conrail right-of-way line to the south 

right-of-way line of E. Michigan Avenue, west along the E. Michigan Avenue right-of-way 

to the east right-of-way line of S. Larch Street, south along the S. Larch Street right-of- 

way line to the center-line of E. Kalamazoo Street, then west along E. Kalamazoo Street 

center-line to the center-line of S. Larch Street, then south along the S. Larch Street 

center-line to the north right-of-way line of St. Joseph Street (extended), west along the 

St. Joseph Street right-of-way line (extended) to the Point of Beginning. 

The Principal Shopping District, as described herein, shall contain zones as described 

below: 

Zone A: Beginning at the intersection of the center-line of W. Shiawassee Street and the 

centerline of N. Capitol Avenue, the "Point of Beginning -A", east along the center-line of 

Shiawassee Street to the west right-of-way line of the Conrail right-of-way, south along 

the Conrail right-of-way line to the center-line of E. Michigan Avenue, west along the 

center-line of E. Michigan Avenue to the center-line of S. Cedar Street, south along the 

S. Cedar Street center-line to the center-line of E. Kalamazoo Street, west along the E. 

Kalamazoo Street center-line to the center-line of Museum Drive, northwesterly along the 

center-line 

of Museum 

Drive 

to 

the 

north 

line 

of 

Impression 

Five 

Condominium 

(extended), west along the said north line of Impression Five Condominium (extended) to 

the center-line of the Grand River, southeasterly along the center of the Grand River to 

the center-line of E. Kalamazoo Street, continuing along the center-line of E. Kalamazoo 

Street to the center-line of Grand Avenue, south along the Grand Avenue center-line to 

the center-line of W. Lenawee Street, west along the W. Lenawee Street center-line to 

the west right-of-way line of S. Capitol Avenue, north along the west right-of-way line of 

S. Capitol Avenue to W. Washtenaw street, west along the centerline of W. Washtenaw 

Street to the centerline of Townsend Street, north along the centerline of Townsend Street

Page 3

east along the W. Grand River right-of-way line to the west right-of-way line of Turner 

Street, north along the Turner Street right-of-way line to the north right-of-way line of 

Clinton Street, east along the Clinton Street right-of-way line to the east right-of-way line 

of Center Street, south along the Center Street right-of-way line to the north right-of-way 

line of Liberty Street, east along the Liberty Street right-of-way line to the center, line of 

N. Cedar Street, south along the N. Cedar Street center-line to the centerline of E. Maple 

Street, west along E.

Page 4

Ra

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

PROPERTY TAX APPEAL ANSWER FORM

SPECIAL ASSESSMENT

MOAHR DOCKET NO. 25-003705

Section 1: Respondent’s Contact Information

Unit of Government

City Of Lansing (INGHAM)

Section 2: Respondent’s Attorney/Authorized Representative’s Contact Information

First Name

Patrick

M.I.

James

Last Name

Abood

Firm Name (if any)

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

124 W. Michigan Ave.

5th Floor, City Hall

City or Town

Lansing

State

Michigan

ZIP Code

48933

Telephone Number

517-483-4327

Fax Number

E-mail Address

patrick.abood@lansingmi.gov

Section 3: Subject Property Information

Parcel Identification Number(s):

33-01-01-09-404-013

If multiple parcels are being appealed are they contiguous or adjoining?

N/A

Taxing Authority (City or Township)

City Of Lansing (INGHAM)

County

Ingham

Section 4: Explain Your Answer to this Appeal

Pursuant to Michigan Tax Tribunal Rule (TTR) 277(3), you MUST submit a copy of the notice giving rise to the appeal (e.g. the special assessment confirmation 

roll) with this Small Claims Answer if applicable. If you do not submit this document, you may be held in default.

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

 Petitioner is the owner of parcel number 33-01-01-09-404-013, commonly known as 1115 Center Street, Lansing, MI 48906. The City of Lansing has an 

established Principal Shopping District. It is undisputed that Petitioner's parcel falls within Lansing’s Principal Shopping District and is subject to any special 

assessment that is levied. Under City of Lansing Ordinance 1026.08, Lansing City Charter, and MCLA 128.981 et seq a special assessment may be levied for a 

Principal Shopping District project and/or to provide for the maintenance, security, or operation of the District. Petitioner has been the owner of the parcel since 

2005. Since 2005, there have been numerous special assessments for the Principal Shopping District, that Petitioner has paid. At issue here is the calendar year 2025 

special assessment. This special assessment was for Principal Shopping District public improvements and services to benefit the properties within the boundaries of 

the Principal Shopping District, including Petitioner. A Notice of Public Hearing was sent to all property owners, in accordance with the Lansing City Charter and 

MCLA 211.741, who are within the boundaries of the Principal Shopping District. A properly noticed public hearing was held on September 22, 2025, at 7:00 p.m. 

in Lansing City Council Chambers located at 124 W. Michigan Ave, 10th Floor, Lansing, Michigan 48933. In response to the Notice of Public Hearing, Petitioner 

filed a written objection to the special assessment and attended the Hearing. The Hearing was held and Lansing City Council adopted Resolution #2025-231 to levy 

the special assessment for the Principal Shopping District. The Special Assessment Roll was confirmed on September 29, 2025. Petitioner filed a Property Tax 

Appeal Petition of the special assessment on 10/29/2025. Petitioner’s Petitioner acknowledges that they had knowledge of the hearing, objected to the hearing, and 

attended the hearing. Petitioners have not been deprived of any due process related to the Respondent levying and confirming this special assessment. 

Section 5: Jurisdictional Issues

Did Petitioner protest the special assessment at the hearing held to confirm the special assessment roll?

Yes

What was the date of the hearing held to confirm the special assessment roll?

09/29/2025

How many years is the special assessment being levied?

1

What is the total amount of the special assessment being levied (per parcel)?

481.49

What is the basis for the special assessment? Identify the applicable statutory provision.

The basis for the special assessment falls under City of Lansing Ordinance 1026.08, the Lansing City Charter, and MCLA 128.981 et seq.

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

Respondent or Attorney/Authorized Representative’s Signature: 

/s/ Patrick J. Abood (P86987)

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

 

 

AMEE L OLEARY, 

 

Petitioner, 

 

v. 

 

 

 

Case No. 25-003705-TT 

SMALL CLAIMS DIVISION 

 

CITY OF LANSING, 

 

Respondent. 

 

 

Amee L Oleary 

In Pro Per 

1986 Navaho Trial 

Okemos, MI 48864 

(517) 719-5676 

ameeoleary@mac.com 

 

 

Gregory S. Venker (P81780) 

Matthew D. Staples (P84571) 

Patrick J. Abood (P86987) 

Attorney for Respondent 

124 W. Michigan Ave., 5th Floor 

Lansing, MI 48933 

(517) 483-4320 

CityAtty@lansingmi.gov 

 

APPEARANCE 

 

NOW COMES, the City Attorney for the City of Lansing, Michigan, by and through 

Patrick J. Abood, Assistant City Attorney, and the Office of the City Attorney, and hereby enters 

his Appearance for and on behalf of Respondent City of Lansing in the above-captioned matter. 

Respectfully Submitted, 

Dated: November 25, 2025 

By: /s/Patrick J. Abood 

Patrick J. Abood (P86987) 

Attorney for Respondent 

124 W. Michigan Ave., 5th Floor 

Lansing, MI 48933 

(517) 483-4320

Page 2

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

AMEE L OLEARY, 

Petitioner, 

Case No. 25-003705-TT 

SMALL CLAIMS DIVISION 

v. 

CITY OF LANSING, 

Respondent. 

Amee L Oleary 

Gregory S. Venker (P81780) 

In Pro Per 

Matthew D. Staples (P84571) 

1986 Navaho Trail 

Patrick J. Abood (P86987) 

Okemos, MI 48864 

(517) 719-5676 

ameeoleary@mac.com 

Attorney for Respondent 

124 W. Michigan Ave., 5" Floor 

Lansing, MI 48933 

(517) 483-4320 

CityAtty@lansingmi.gov 

PROOF OF SERVICE 

This is to certify that on November 25, 2025, Respondent an Appearance and this Proof of 

Service to the Michigan Tax Tribunal, via electronic filing system. I further state that on November 

25, 2025, and sent hard copies of Appearance and this Proof of Service to: Amee L OLeary, via 

first class mail to: 1986 Navaho Trail, Okemos, MI 48864. 

I declare that the statements above are true to the best of my information, knowledge, and 

belief. 

Date: 28/2025" 

[C7 

/Patrick J. Abood (P86987)

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

Page 1

Principal Shopping District Special Assessment Protest 

Date: October 28, 2025 

Parcel #: 33-01-01-09-404-013 

Property Address: 1115 Center Street, Lansing, MI 48906 

Owners: Daniel S. O’Leary & Amee L. O’Leary 

Petition Form 

Petition Form to be Filed Electronically via Michigan Tax Tribunal Portal. 

Statement of Facts 

The subject property at 1115 Center Street, Lansing, Michigan is a 27,021 sq. ft. warehouse 

facility used exclusively for wholesale distribution. The building has no retail storefront and 

has never received walk-in customer traffic. The business sells to retailers, not to the public. 

The operations of the property do not rely on or benefit from pedestrian shopping activity. 

 

The Principal Shopping District (PSD) special assessment is designed to fund activities 

intended to increase retail shopping traffic, enhance the consumer experience, and support 

the commercial retail corridor in Old Town. These improvements do not confer a special or 

specific benefit to the subject property due to its wholesale use, non-retail operations, and 

private industrial access patterns. 

 

The property has been continuously owned by the same family since approximately 1980, 

first by the prior generation and now by the current owners since 2005. Throughout that 

time, the special assessment has been imposed, although the property’s use has not 

changed. The owners have consistently maintained that the assessment provides no direct 

benefit to the property and should not apply to a warehouse with no retail function. The 

special assessment has averaged approximately $500 per year, in addition to hefty property 

taxes. 

 

In 2023, the owner submitted a formal written protest to the PSD special assessment roll. In 

2024, the owner personally attended the public hearing but was never called to speak, 

despite signing in and remaining for the full duration of the meeting. In 2025, the owner 

again submitted a written protest on September 19, 2025, and received acknowledgment 

that the protest was entered into the hearing record. However, the owner has not received 

any written response addressing the concerns raised although requested. 

 

Based on use, access patterns, and the nature of the business, the property does not receive 

a special benefit that is different from the benefit to the general public, and therefore should 

not be subject to the Principal Shopping District special assessment. 

Exhibit Index 

Exhibit A – Property Photos (Provided by Owner) 

Exhibit B – Crime/Security Incident Summary 

Exhibit C – Record of Prior Protests

Page 2

1115 Center Front View 

 

 

View from Grand River Avenue 

 

 

 

 

 

 

 

Rear of Building 

View 

from City Lot 

Top View 

of Building 

 bordered 

In Red

 

Exhibit A- Property Photos

Page 3

Left: Homeless baggage in the immediate area 

outside our building, and close to the adjacent 

abandoned building. 

Below: Used needles left behind on our property.

Attempted Break in 2020

Page 4

Exhibit B – Crime and Security Summary 

The following incidents have occurred at or near the subject property in recent years, 

illustrating the ongoing safety and security issues that affect the area and its lack of benefit 

from retail-oriented improvements: 

 

• Attempted Break-In – May 2020 

• Employee Carjacked – February 2023 (Police Report #2351901483) 

• Breaking & Entering / Office Ransacked – November 2024 (Police Report #2451910696) 

• Abandoned Building at 308 N. Cesar Chavez – Homeless Activity and Opioid Use – 

December 2023 (Report #E23-13475) 

 

These incidents demonstrate that the area continues to face challenges unrelated to retail 

development, further supporting that the property derives no special benefit from the 

assessment. 

Exhibit C – Record of Prior Protests 

The property owners have consistently objected to the Principal Shopping District Special 

Assessment over multiple years: 

 

• 2023 – Written protest submitted to City Clerk (no written response received) 

• 2024 – Attended public hearing, signed in, not called to speak 

• 2025 – Written protest submitted on September 19, 2025, acknowledged as received but 

unanswered 

 

This ongoing pattern of unanswered appeals demonstrates a lack of engagement with 

property owners directly affected by the assessment. 

Closing Statement 

This property has been subject to an annual retail improvement assessment for 

many years without receiving a single direct or measurable benefit. It remains a 

wholesale warehouse facility surrounded by industrial operations and security 

concerns — conditions entirely inconsistent with a retail district. Despite repeated 

written protests and attendance at hearings, no substantive response or 

consideration has been given. 

We strongly urge the Michigan Tax Tribunal to correct this ongoing inequity by 

removing this property from inclusion in the Principal Shopping District special 

assessment going forward. 

 

/s/ Daniel S. O’Leary 

/s/ Amee L. O’Leary 

Owners 

Dated: October 28, 2025

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

PROPERTY TAX APPEAL PETITION FORM

SPECIAL ASSESSMENT

MOAHR DOCKET NO. 

Section 1: Petitioner’s Contact Information

Filer Type: Individual 

First Name

Amee

M.I.

L

Last Name/Company Name

OLeary

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

1986 Navaho Trail

City or Town

Okemos

State

Michigan

ZIP Code

48864

Telephone Number

517-719-5676

Fax Number

E-mail Address

ameeoleary@mac.com

Section 2: Petitioner’s Attorney/Authorized Representative’s Contact Information

First Name

M.I.

Last Name

Firm Name (if any)

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

City or Town

State

Michigan

ZIP Code

Telephone Number

Fax Number

E-mail Address

Pursuant to Michigan Tax Tribunal Rule (TTR) 277(3), you MUST submit a copy of the notice giving rise to the appeal (e.g. a copy of the resolution confirming 

the special assessment roll) with this Small Claims Petition, if applicable. If you do not submit this document, you may be held in default.

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Section 3: Subject Property Information

How many parcels are you appealing?

1

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.

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

1115 Center St

Lansing

Michigan

48906

Parcel Identification Number(s):

33-01-01-09-404-013

Taxing Authority (City or Township)

City Of Lansing (INGHAM)

County 

Section 4: Explain the Reason for this Appeal

The property at 1115 Center Street is a wholesale warehouse facility with no retail storefront, no customer traffic, and no participation in any retail activity. Despite 

this, it continues to be assessed annually under the Principal Shopping District (PSD) special assessment, which is expressly intended to fund improvements that 

enhance retail visibility, pedestrian traffic, and consumer experience. This property receives no measurable or direct benefit from those improvements. It is 

surrounded by industrial operations and persistent security issues that remain unaddressed by the PSD. After years of written protests and participation in public 

hearings with no acknowledgment or relief, the owners are appealing to the Michigan Tax Tribunal to correct this inequitable assessment and remove this property 

from future PSD assessment rolls.

Section 5: Jurisdictional Issues

Did you protest the special assessment at the hearing held to confirm the special assessment roll? Yes

If Yes, what was the date of the hearing held to confirm the special assessment roll?

9/22/25

If No, explain:

Fee Information

A fee of $100.00 is required for the filing of a Special Assessment Appeal.

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

Petitioner or Attorney/Authorized Representative’s Signature: 

/s/ Amee L OLeary

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

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

Amee L OLeary,

Petitioner,

MICHIGAN TAX TRIBUNAL

SMALL CLAIMS DIVISION

v 

MTT Docket No. 25-003705

City Of Lansing,

Respondent.

NOTICE OF DOCKET NUMBER

TAKE NOTICE that a Small Claims petition has been filed and the above-noted docket 

number has been assigned to that petition. The assignment of the docket number does 

not mean that the Tribunal has authority over the petition or that the petition complies 

with the Tribunal’s rules. The docket number needs to be included on all documents 

submitted in this case.

Respondent shall file an answer to the petition within 28 days of the issuance of a 

copy of this Notice to Respondent. Tribunal answer forms are available on our 

website at www.michigan.gov/taxtrib. Respondents must utilize the appropriate answer 

form. Failure to file the answer within the 28-day time frame may result in the 

placement of Respondent in default, as provided by TTR 281. Further, an electronic 

copy of the petition can be reviewed by utilizing the Docket Lookup Search on the 

Tribunal’s website.

By: __Tribunal Clerk_____

Entered: November 4, 2025

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.

By: Tribunal Clerk

Page 2

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

Amee L OLeary,

Petitioner,

MICHIGAN TAX TRIBUNAL

SMALL CLAIMS DIVISION

v 

MTT Docket No. 25-003705

City Of Lansing,

Respondent.

NOTICE OF DOCKET NUMBER

TAKE NOTICE that a Small Claims petition has been filed and the above-noted docket 

number has been assigned to that petition. The assignment of the docket number does 

not mean that the Tribunal has authority over the petition or that the petition complies 

with the Tribunal’s rules. The docket number needs to be included on all documents 

submitted in this case.

Respondent shall file an answer to the petition within 28 days of the issuance of a 

copy of this Notice to Respondent. Tribunal answer forms are available on our 

website at www.michigan.gov/taxtrib. Respondents must utilize the appropriate answer 

form. Failure to file the answer within the 28-day time frame may result in the 

placement of Respondent in default, as provided by TTR 281. Further, an electronic 

copy of the petition can be reviewed by utilizing the Docket Lookup Search on the 

Tribunal’s website.

By: __Tribunal Clerk_____

Entered: November 4, 2025

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.

By: Tribunal Clerk

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

PROPERTY TAX APPEAL PETITION FORM

SPECIAL ASSESSMENT

MOAHR DOCKET NO. 

Section 1: Petitioner’s Contact Information

Filer Type: Individual 

First Name

Amee

M.I.

L

Last Name/Company Name

OLeary

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

1986 Navaho Trail

City or Town

Okemos

State

Michigan

ZIP Code

48864

Telephone Number

517-719-5676

Fax Number

E-mail Address

ameeoleary@mac.com

Section 2: Petitioner’s Attorney/Authorized Representative’s Contact Information

First Name

M.I.

Last Name

Firm Name (if any)

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

City or Town

State

Michigan

ZIP Code

Telephone Number

Fax Number

E-mail Address

Pursuant to Michigan Tax Tribunal Rule (TTR) 277(3), you MUST submit a copy of the notice giving rise to the appeal (e.g. a copy of the resolution confirming 

the special assessment roll) with this Small Claims Petition, if applicable. If you do not submit this document, you may be held in default.

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Section 3: Subject Property Information

How many parcels are you appealing?

1

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.

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

1115 Center St

Lansing

Michigan

48906

Parcel Identification Number(s):

33-01-01-09-404-013

Taxing Authority (City or Township)

City Of Lansing (INGHAM)

County 

Section 4: Explain the Reason for this Appeal

The property at 1115 Center Street is a wholesale warehouse facility with no retail storefront, no customer traffic, and no participation in any retail activity. Despite 

this, it continues to be assessed annually under the Principal Shopping District (PSD) special assessment, which is expressly intended to fund improvements that 

enhance retail visibility, pedestrian traffic, and consumer experience. This property receives no measurable or direct benefit from those improvements. It is 

surrounded by industrial operations and persistent security issues that remain unaddressed by the PSD. After years of written protests and participation in public 

hearings with no acknowledgment or relief, the owners are appealing to the Michigan Tax Tribunal to correct this inequitable assessment and remove this property 

from future PSD assessment rolls.

Section 5: Jurisdictional Issues

Did you protest the special assessment at the hearing held to confirm the special assessment roll? Yes

If Yes, what was the date of the hearing held to confirm the special assessment roll?

9/22/25

If No, explain:

Fee Information

A fee of $100.00 is required for the filing of a Special Assessment Appeal.

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

Petitioner or Attorney/Authorized Representative’s Signature: 

/s/ Amee L OLeary

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.