Apex Ultra Worldwide, LLC Petitioner Vs. City Of Lansing Respondent

Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Apex Ultra Worldwide, LLC, 

Docket No. 26-000693 

Petitioner, 

Parcel No. 33-01-01-08-301-032 

Vv. 

City of Lansing, 

Respondent. 

Jerome P. Pesick (P29039) 

Jennifer Hendrix, MMAO 

Jason C. Long (P59244) 

CITY OF LANSING 

WILLIAMS, WILLIAMS, RATTNER 

124 W. Michigan Avenue, 3rd Floor 

& PLUNKETT, PC 

Lansing, MI 48933 

380 N. Old Woodward Ave., Ste. 300 

(517) 483-4136 

Birmingham, MI 48009 

Authorized Representative for 

(248) 642-0333 

Respondent 

Attorneys for Petitioner 

Stipulation for Entry of Consent 

Judgment 

1. 

This appeal is pending in the Entire Tribunal Division. 

2. 

The subject property in this appeal is identified as Parcel No. 33-01-01- 

08-301-032 and is commonly known as 2101 W. Willow Street, Lansing, MI 48917 

(the “Subject Property”). 

3. 

The values for the Subject Property established by Respondent’s March 

Board of Review are as follows:

Page 2

4. 

The values 

for the Subject Property stipulated by the parties 

for 

settlement purposes are as follows: 

Tax Year 

True Cash Value 

| State Equalized Value 

Taxable Value 

2026 

$2,897,300 

$1,448,650 

$1,448,650 

5. 

Special terms and conditions: 

All refunds 

shall be issued payable 

jointly 

to 

Petitioner 

and WWRP, 

P.C., 

and 

shall 

be 

delivered 

to 

Petitioner's 

attorneys as follows: Williams, Williams, Rattner & Plunkett, P.C., Attn: Jerome P. 

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

Wherefore, 

the 

parties respectfully request that this honorable Tribunal 

enter 

a Consent Judgment 

revising 

the 

Subject Property's 

2026 property 

tax 

assessment consistent with the values set forth in this Stipulation. 

/sl Jerome P. Pesick 

Jerome P. Pesick (P29039) 

Attorney for Petitioner 

Jennifer Hendrix 

Authorized Representative for Respondent 

Dated: October7? , 2026

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: 26-000693

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

Party Filing Document 

Joint

Files

Document Type: Stip for Consent Judgment

Attachment File Name: Stipulation signed

Fee Information

Filing Fee: $ 50.00

Payment Information

Payment: $ 50.00

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

NOTICE OF JULY 1- 15, 2027 PREHEARING GENERAL CALL AND ORDER OF 

PROCEDURE

Apex Ultra Worldwide, LLC,

Petitioner,

v

 

 

City Of Lansing,

Respondent.

 MTT Docket No. 26-000693

Please be advised that 26-000693 has been placed on a two-week Prehearing General 

Call commencing July 01, 2027. Unless ordered otherwise, parties will be notified at 

least 28 days before they are scheduled to appear. Scheduling will not necessarily 

occur in the order in which the cases are listed below.

Parties are required to submit a valuation disclosure or written notification that no 

valuation disclosure is required by the dates indicated herein. A “valuation disclosure” 

is defined as documentary or other tangible evidence in a property tax proceeding that a 

party relies upon in support of the party’s contention as to the true cash value of the 

subject property or any portion thereof and contains the party’s value conclusion and 

data, valuation methodology, analysis or reasoning. See TTR 203 and TTR 241.

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

public records and will appear for public viewing on the Tribunal’s Tax Docket 

Lookup. If a user wishes to file a document for consideration by the 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.

In accordance with MCR 1.109(D)(9) and TTR 209, 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 submitting a Request for Redactions. The 

Request for Redactions form is available on the Entire Tribunal and Small Claims pages 

of the Tribunal’s website. 

Please refer to the Tribunal’s FAQs and Glossary of Terms pages on the Tribunal’s 

website for more information.

Page 2

MTT Docket No. 26-000693

Page 2 of 3

IT IS ORDERED that the parties shall:

a. If no valuation disclosure is required, notify the Tribunal and the opposing parties 

in writing within 21 days of entry of this order that no valuation disclosure is being 

filed. The notice shall indicate the reason or reasons why no valuation disclosure 

is required (i.e., exemption claim, etc.).

b. If a valuation disclosure is required, file and exchange their valuation disclosures 

by March 4, 2027. Valuation disclosures will not be admitted into evidence 

unless disclosed and furnished in accordance with this order (even though 

admissible) except upon a finding of good cause by the Tribunal.

IT IS FURTHER ORDERED that the parties shall file and exchange their Prehearing 

Statements by March 4, 2027. Witnesses, with the exception of rebuttal witnesses, will 

not be allowed to testify unless disclosed in the Prehearing Statement and the 

Prehearing Statement is furnished in accordance with this order except upon a finding 

of good cause by the Tribunal. Failure to file the Prehearing Statement may result in 

holding a party or parties in default. See TTR 237. 

IT IS FURTHER ORDERED that “Pre-Valuation Disclosure” discovery is CLOSED on 

March 4, 2027, which means all discovery has been requested, all Motions to Compel 

have been filed, and all requested or ordered discovery has been exchanged by that 

date. Discovery relative to the valuation disclosure prepared for purposes of litigating 

this case or the valuation expert that prepared that valuation disclosure is not permitted 

during “Pre-Valuation Disclosure” discovery.

IT IS FURTHER ORDERED that “Post-Valuation Disclosure” discovery is CLOSED on 

July 1, 2027, which means all discovery has been requested, all Motions to Compel 

have been filed, and all requested or ordered discovery has been exchanged by that 

date. “Post-Valuation Disclosure” discovery is limited to the opposing party’s valuation 

disclosure, the opposing party’s valuation expert, and the witnesses identified on the 

opposing party’s Prehearing Statement.

IT IS FURTHER ORDERED that if this case is not scheduled for a date certain 

prehearing conference during the time frame indicated it may be scheduled for a date 

certain prehearing conference at any time subsequent to the completion date for this 

Prehearing General Call. Parties will, however, be notified in writing approximately one 

week before they are scheduled to appear. 

By:_____________________________________

Patricia L. Halm, Tribunal Chair

Entered: August 3, 2026

Page 3

MTT Docket No. 26-000693

Page 3 of 3

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

Page 4

STATE OF

Page 5

MTT

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

NB

APEX ULTRA WORLDWIDE LLC 

RECEIVED 

JUL 2 3 2026 

MICH 

STATE OF MICHIGAN 

IGAN TAX TRIBUNAL 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

Petitioner 

v 

MOAHR Docket 26-000693 

Parcel No. 33-01-01-08-301-321 

: 

CITY OF LANSING, 

Respondent 

Jennifer Hendrix, MMAO 

i 

City Assessor 

124 W. Michigan Avenue 

3rd Flooy, City Hall 

! 

Lansing, MI 48933 

(517) 483-4136 

Jennifer, czeiszperger@lansingmi.gov 

RESPONDENT, the City of Lansing, through its Assessor, Jennifer Hendrix, hereby responds 

to the allegations made in Petitioner’s Petition as follows: 

1. 

RESPONDENT’S ANSWER TO PETITIONER’S PETITION 

AND AFFIRMATIVE DEFENSES 

Respondent lacks the information and knowledge necessary to respond to the allegations 

in Paragraph 1. 

The owner of record is Apex Ultra Worldwide, LLc and the mailing 

address on record is 2101 W Willow St, Lansing, MI 48917. 

Respondent admits the allegations in Paragraph 2. 

Respondent neither admits nor denies the allegations in Paragraph 3 for reason that they

Page 2

MTT Docket #f 26-000693 

. 

The 2026 values for the property identified above as established by Respondent’s Board 

of Review are: 

Parcel Number 

True Cash Value 

Assessed Value 

Taxable Value 

33-01-01-08-301-032 

$3,695,600 

$1,847,800 

$1,682,096 

. 

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

Parcel Number 

True Cash Value 

Assessed Value 

Taxable Value 

33-01-01-08-301-032 | $3,695,600 

$1,847,800 

$1,682,096 

. 

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

Parcel Number 

True Cash Value | Assessed Value 

| Taxable Value 

33-01-01-08-301-032 

$0 

$0 

$0 

10. Respondent acknowledges Petitioner’s beliefs as to the issues in this appeal but denies 

that those issues have merit and further denies that Petitioner is entitled to any relief. 

Further, the subject property did not have any “additions” or “losses” for the 2026 tax 

yea. 

11. Respondent denies the allegations in Paragraph 11 for the reason that it is untrue, In further 

answer, the assessed, state equalized and/or taxable values do not exceed permitted 

amounts, do not exceed the percentage of 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 constitutional. Further, the subject property did not 

have any “additions” or “losses” for the 2026 tax year. 

12. Respondent denies the allegations in Paragraph 12 for reasons that they are untrue, and 

leaving Petitioner to their strictest proofs. 

WHEREFORE, Respondent City of Lansing respectfully requests that this Honorable Tribunal 

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

equalization., and award Respondent its cost and attorney fees.

Page 3

MTT Docket # 26-000693 

Dated: 

Jdy (5,206 

OFFICE OF THE CITY ASSESSOR 

CITY OF LANSING 

2 Lo 

A ou deny 

Jennifer\Hendrix, MMAO 

City Assessor, City of Lansing 

3d Floor, City Hall 

124 W Michigan Ave 

Lansing, Michigan 48933 

Telephone: (517) 483-4136 

Jennifer.czeiszperger(@lansingmi.gov

Page 4

MTT Docket # 26-000693 

AFFIRMATIVE DEFENSES 

PLEASE TAKE NOTICE that Respondent City of Lansing will rely on the 

following affirmative defenses: 

A. 

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

against the Respondent and to support Petitioner's claim for relief. 

B. 

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). 

C. 

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). 

B. 

Petitioner fails to allege specific and sufficient facts to establish fraud, error of law, 

discrimination, 

and application of wrong principles or illegality on the part of the Respondent or 

its agents, 

C. 

Petitioner fails to allege the mode and method of assessing the subject property 

failed to conform to the mode and method applied in the case of all properties within the 

Respondent’s taxing unit for the tax year in questions, 

D. 

Petitioner fails to allege specific and sufficient facts needed to establish the true 

cash value, assessed and taxable value for the subject property. 

E. 

Petitioner fails to allege specific and sufficient facts to support its allegations that 

the assessed value of the subject property, as equalized, is at a level other than 50% and it also 

fails to allege specific and sufficient facts to support its allegations that the subject property’s

Page 5

MTT Docket # 26-000693 

G. 

Petitioner asks this Tribunal to grant it illegal preference by application of a method 

of assessment different from that utilized in the assessment of other properties in the Respondent’s 

taxing unit, thereby shifting an otherwise equitable tax burden to the City’s remaining taxpayers. 

H. 

Petitioner, in essence, seeks by petition to challenge the process of county and state 

cqualization as to which it has no legal standing and cannot maintain a cause of action. 

L 

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 Petitioner’s otherwise equitable tax burden. 

J. 

Respondent 

has 

properly

Page 6

STATE

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

RECEIVED 

JUL 13 2026 

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

APEX ULTRA WORLDWIDE LLC 

Petitioner 

v 

MOAHR Docket 26-000693 

Parcel No. 33-01-01-08-301-321 

CITY OF LANSING, 

Respondent 

Jennifer Hendrix, MMAO 

City Assessor 

124 W. Michigan Avenue 

3rd Floor, City Hall 

Lansing, MI 48933 

(517) 483-4136 

Jennifer.czeiszperger@lansingmi.gov 

RESPONDENT’S ANSWER TO PETITIONER’S PETITION 

AND AFFIRMATIVE DEFENSES 

RESPONDENT, the City of Lansing, through its Assessor, Jennifer Hendrix, hereby responds 

to the allegations made in Petitioners Petition as follows: 

1. 

Respondent lacks the information and knowledge necessary to respond to the allegations 

in Paragraph 1. 

The owner of record is Apex Ultra Worldwide, LLc and the mailing 

address on record is 2101 W Willow St, Lansing, MI 48917. 

2. 

Respondent admits the allegations in Paragraph 2. 

3. 

Respondent neither admits nor denies the allegations in Paragraph 3 for reason that they

Page 2

MTT Docket # 26-000693 

7. 

The 2026 values for the property identified above as established by Respondent’s Board 

of Review are: 

Parcel Number 

True Cash Value 

| Assessed Value 

Taxable Value 

33-01-01-08-301-032 | $3,695,600 

$1,847,800 

$1,682,096 

8. 

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

Parcel Number 

True Cash Value 

Assessed Value 

Taxable Value 

33-01-01-08-301-032 | $3,695,600 

$1,847,800 

$1,682,096 

9. 

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

Parcel Number 

True Cash Value | Assessed Value 

| Taxable Value 

33-01-01-08-301-032 

$0 

$0 

$0 

10. Respondent acknowledges Petitioner’s beliefs as to the issues in this appeal but denies 

that those issues have merit and further denies that Petitioner is entitled to any relief, 

Further, the subject property did not have any “additions” or “losses” for the 2026 tax 

year. 

11. Respondent denies the allegations in Paragraph 11 for the reason that it is untrue. In further 

answer, the assessed, state equalized and/or taxable values do not exceed permitted 

amounts, do not exceed the percentage of 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 constitutional. Further, the subject property did not 

have any “additions” or “losses” for the 2026 tax year. 

12. Respondent denies the allegations in Paragraph 12 for reasons that they are untrue, and 

leaving Petitioner to their strictest proofs. 

WHEREFORE, Respondent City of Lansing respectfully requests that this Honorable Tribunal 

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

equalization, and award Respondent its cost and attorney fees.

Page 3

MTT Docket # 26-000693 

Dated: 

__{ 

| N22 

OFFICE OF THE CITY ASSESSOR 

by 

F 

LANSING 

ma they 

pes Hee MMAO 

City Assessor, City of Lansing 

3d Bloor, City Hall 

124 W Michigan Ave 

Lansing, Michigan 48933 

Telephone: (517) 483-4136 

Jennifer.czeiszperger@lansingmi.gov

Page 4

MTT Docket # 26-000693 

AFFIRMATIVE DEFENSES 

PLEASE TAKE NOTICE that Respondent City of Lansing will rely on the 

following affirmative defenses: 

A, 

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

against the Respondent and to support Petitioner’s claim for relief. 

B. 

The Tribunal is charged with finding a property’s true cash value to determine the 

property’s lawful assessment. Athi Development Co v Orion Twp, 110 Mich App 764, 767 (1981). 

C. 

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). 

B. 

Petitioner fails to allege specific and sufficient facts to establish fraud, error of law, 

discrimination, and application of wrong principles or illegality on the part of the Respondent or 

its agents. 

C. 

Petitioner fails to allege the mode and method of assessing the subject property 

failed to conform to the mode and method applied in the case of all properties within the 

Respondent’s taxing unit for the tax year in questions. 

D. 

Petitioner fails to allege specific and sufficient facts needed to establish the true 

cash value, assessed and taxable value for the subject property. 

E. 

Petitioner fails to allege specific and sufficient facts to support its allegations that 

the assessed value of the subject property, as equalized, is at a level other than 50% and it also 

fails to allege specific and sufficient facts to support its allegations that the subject property’s

Page 5

MTT Docket # 26-000693 

G. 

Petitioner asks this Tribunal to grant it illegal preference by application of a method 

of assessment different from that utilized in the assessment of other properties in the Respondent’s 

taxing unit, thereby shifting an otherwise equitable tax burden to the City’s remaining taxpayers. 

H. 

Petitionet, 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. 

LL 

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 Petitioner’s otherwise equitable tax burden. 

J. 

Respondent 

has 

properly 

and 

lawfully 

assessed

Page 6

ray,

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 ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

Apex Ultra Worldwide, LLC, 

Docket No. 26-000693 

Petitioner, 

Parcel No. 33-01-01-08-301-032 

v. 

City of Lansing, 

Respondent. 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

Attorneys for Petitioner 

Proof of Service of Petition and Notice of Docket Number

Page 2

Proof of Service of Petition and Notice of Docket Number 

Monica Athanas states that she personally served copies of the Entire Tribunal 

Property Tax Petition, Notice of Docket Number, and this Proof of Service, on the 

persons listed below, by the means identified below, by placing those documents in 

duly stamped, addressed envelopes, and placing the envelopes in the United States 

mail on June 11, 2026. 

PERSONS SERVED: 

Certified Mail: 

First Class Mail: 

Clerk 

Clerk 

Secretary of School Board 

City of Lansing 

Ingham County 

Lansing School District 

124 W. Michigan Avenue 

P.O. Box 179 

519 W. Kalamazoo Street 

9 Floor 

Mason, MI 

48854 

Lansing, Ml 

48933 

Lansing, MI 

48933 

Assessor 

Director of Equalization 

State Treasurer 

City of Lansing 

Ingham County 

Michigan Department of Treasury 

124 W. Michigan Avenue 

P.O. Box 319, Courthouse 

Austin Building 

3 Floor 

Mason, MI 

48854 

430 W. Allegan 

Lansing, MI 

48933 

Lansing, MI 48922 

Werses Whore 

Monica Athanas 

~~

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: 26-000693

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: APEX POS - Petition

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 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

 

Apex Ultra Worldwide, LLC, 

 

 

 

 

 

 

 

 

Docket No. 26- 

 

Petitioner, 

 

 

 

 

 

Parcel No. 33-01-01-08-301-032 

 

v. 

 

City of Lansing, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

Attorneys for Petitioner 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Entire Tribunal Property Tax Petition 

 

 

Petitioner Apex Ultra Worldwide, 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 Apex Ultra Worldwide, LLC is a Michigan limited liability 

company with its principal place of business in Michigan located at 2101 W. Willow 

Street, Lansing, Michigan 48917. 

2. 

Respondent City of Lansing is a Michigan city with its principal offices

Page 2

located at 124 W Michigan Avenue, Lansing, MI 48933. 

The Subject Property 

3. 

Petitioner owns property identified as Parcel No. 33-01-01-08-301-032 

and commonly known as 2101 W. Willow Street, Lansing, Michigan 48917 (the 

“Subject Property”). 

4. 

The Subject Property is located in Ingham County and is within the 

Lansing Public 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 real 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 

 3,695,600 

 1,847,800 

 1,682,096 

 

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 

 2,500,000 

 1,250,000 

 1,250,000 

 

9. 

The amounts in dispute therefore are as follows: 

True Cash Value 

Assessed Value 

Taxable Value 

 1,195,600 

 597,800 

 432,096

Page 3

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”), 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/ Jerome P. Pesick 

 

 

 

 

 

 

 

 Jerome P. Pesick (P29039) 

Dated: April 22, 2026 

 

 

Attorneys for Petitioner

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

Apex Ultra Worldwide, LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-000693

City Of Lansing, 

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: June 2, 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.

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 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

 

Apex Ultra Worldwide, LLC, 

 

 

 

 

 

 

 

 

Docket No. 26- 

 

Petitioner, 

 

 

 

 

 

Parcel No. 33-01-01-08-301-032 

 

v. 

 

City of Lansing, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

Attorneys for Petitioner 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Entire Tribunal Property Tax Petition 

 

 

Petitioner Apex Ultra Worldwide, 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 Apex Ultra Worldwide, LLC is a Michigan limited liability 

company with its principal place of business in Michigan located at 2101 W. Willow 

Street, Lansing, Michigan 48917. 

2. 

Respondent City of Lansing is a Michigan city with its principal offices

Page 2

located at 124 W Michigan Avenue, Lansing, MI 48933. 

The Subject Property 

3. 

Petitioner owns property identified as Parcel No. 33-01-01-08-301-032 

and commonly known as 2101 W. Willow Street, Lansing, Michigan 48917 (the 

“Subject Property”). 

4. 

The Subject Property is located in Ingham County and is within the 

Lansing Public 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 real 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 

 3,695,600 

 1,847,800 

 1,682,096 

 

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 

 2,500,000 

 1,250,000 

 1,250,000 

 

9. 

The amounts in dispute therefore are as follows: 

True Cash Value 

Assessed Value 

Taxable Value 

 1,195,600 

 597,800 

 432,096

Page 3

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”), 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/ Jerome P. Pesick 

 

 

 

 

 

 

 

 Jerome P. Pesick (P29039) 

Dated: April 22, 2026 

 

 

Attorneys for Petitioner

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

Entire Tribunal Case Information Sheet - Petitioner

MOAHR DOCKET NO. 

Section 1: Petitioner’s Contact Information

Filer type: Organization

First Name/Company Name

M.I.

Last Name

Apex Ultra Worldwide, LLC

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

2101 W. Willow Street

City or Town

Lansing

State

Michigan

ZIP Code

48917

Telephone Number

248-642-0333

Fax Number

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

jpesick@wwrplaw.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Jerome

M.I.

P

Last Name

Pesick

Firm Name (if any)

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

380 N Old Woodward Ave

Suite 300

City or Town

Birmingham

State

Michigan

ZIP Code

48009

Telephone Number

248-642-0333

Fax Number

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

jpesick@wwrplaw.com

Section 5: Issue

Please designate one: 

Valuation – Fill out Sections 4, 5, & 6 below

Section 6: Subject Property Information

How many parcels are you 

appealing?1

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

2101 W. Willow Street

Lansing

Michigan

48917

Taxing Authority (City or Township)

City Of Lansing (INGHAM)

County

Ingham

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.)

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Section 7: Check which of the following you are appealing (check all that apply)

True Cash and Taxable Values

Section 8: Valuation Information for Each Parcel under Appeal

Parcel Number:

33-01-01-08-301-032

Classification of Property: Real 

Commercial

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

1847800

Current Taxable Value as established by the Board of Review:

1682096

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

2500000

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

1250000

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

Section 9: Assessment Information

Type of Tax Assessment(s):

Assessment Number(s):

Check all that is being appealed: 

Check what action prompted this appeal:

If “other,” please explain:

Section 10: Special Assessment Information

Type of Special Assessment:

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

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

If No, please explain:

Section 11: Classification Information

Parcel Number:

Current Classification of Property as established by Board of Review: 

What do you believe is the property’s classification?

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

If improved property, how is the property currently being used?

If improved property, for what use was the property designed?

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.

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/ Jerome P. Pesick

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.