Associated Bank Na, Petitioner Vs. City Of Southfield, Respondent

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

Associated Bank NA, 

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-001973

City Of Southfield,

Respondent.

ORDER OF DISMISSAL

The Tribunal has reviewed the file in the above-captioned case and finds that:

Petitioner has filed a Motion to Withdraw the Petition and Respondent has not filed an 

objection to the requested withdrawal. 

Therefore,

IT IS ORDERED that the case is DISMISSED.

This order resolves all pending issues and closes the case.

APPEAL RIGHTS

If you disagree with the final decision in this case, you may file a motion for 

reconsideration with the Tribunal or a claim of appeal with the Michigan Court of 

Appeals. 

A motion for reconsideration must be filed with the Tribunal with the required filing fee 

within 21 days from the date of entry of the final decision. Because the final decision 

closes the case, the motion cannot be filed through the Tribunal’s web-based e-filing 

system; it must be filed by mail or personal service. The fee for the filing of such 

motions is $50.00 in the Entire Tribunal and $25.00 in the Small Claims Division, unless 

the Small Claims decision relates to the valuation of property and the property had a 

principal residence exemption of at least 50% at the time the petition was filed or the 

decision relates to the grant or denial of a poverty or disabled veterans exemption and, 

if so, there is no filing fee. You are required to serve a copy of the motion on the 

opposing party by mail or personal service or by email if the opposing party agrees to 

electronic service, and proof demonstrating that service must be submitted with the 

motion. Responses to motions for reconsideration are prohibited and there are no oral 

arguments unless otherwise ordered by the Tribunal.

Alternatively, you may file a claim of appeal with the Michigan Court of Appeals. If the 

claim is filed within 21 days of the entry of the final decision, it is an “appeal of right.” If

Page 2

MTT Docket No. 25-001973

Page 2 of 6

the claim is filed more than 21 days after the entry of the final decision, it is an “appeal 

by leave.” A copy of the claim of appeal must be filed with the Tribunal to certify the 

record on appeal. There is no certification fee. 

By:___________________________________

Patricia L. Halm, Tribunal Chair

Entered: February 12, 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

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

Associated Bank NA, 

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-001973

City Of Southfield,

Respondent.

ORDER OF DISMISSAL

The Tribunal has reviewed the file in the above-captioned case and finds that:

Petitioner has filed a Motion to Withdraw the Petition and Respondent has not filed an 

objection to the requested withdrawal. 

Therefore,

IT IS ORDERED that the case is DISMISSED.

This order resolves all pending issues and closes the case.

APPEAL RIGHTS

If you disagree with the final decision in this case, you may file a motion for 

reconsideration with the Tribunal or a claim of appeal with the Michigan Court of 

Appeals. 

A motion for reconsideration must be filed with the Tribunal with the required filing fee 

within 21 days from the date of entry of the final decision. Because the final decision 

closes the case, the motion cannot be filed through the Tribunal’s web-based e-filing 

system; it must be filed by mail or personal service. The fee for the filing of such 

motions is $50.00 in the Entire Tribunal and $25.00 in the Small Claims Division, unless 

the Small Claims decision relates to the valuation of property and the property had a 

principal residence exemption of at least 50% at the time the petition was filed or the 

decision relates to the grant or denial of a poverty or disabled veterans exemption and, 

if so, there is no filing fee. You are required to serve a copy of the motion on the 

opposing party by mail or personal service or by email if the opposing party agrees to 

electronic service, and proof demonstrating that service must be submitted with the 

motion. Responses to motions for reconsideration are prohibited and there are no oral 

arguments unless otherwise ordered by the

Page 4

MT

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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

Associated Bank NA,

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v 

MTT Docket No. 25-001973

City Of Southfield,

Respondent.

NOTICE OF FILING OF MOTION TO WITHDRAW APPEAL

TAKE NOTICE that Petitioner has filed a Motion to Withdraw (Motion) in the above-

captioned appeal. Because the motion was not filed jointly (i.e. signed by both parties or 

representatives), Respondent has seven days from the service of the motion to file a 

response. Respondent may respond by agreeing to (i.e. concurrence) the withdrawal of 

the case or by objecting to the motion. If Respondent does not timely submit a 

concurrence or objection to the request, it will be deemed to be a concurrence and the 

request will be granted, unless otherwise ordered by the Tribunal. If the request is 

granted, the case will be dismissed. If a request is not granted or the Tribunal has not 

notified you that it has been granted, you are required to attend the hearing. 

For your convenience, you may use the Tribunal’s form “Response to Motion to 

Withdraw Appeal” located on the Tribunal’s website. To access the form, please go to 

our website at www.michigan.gov/taxtrib and go to either the “Entire Tribunal” or “Small 

Claims” page, depending on the division in which the case is pending. To submit the 

response, please fill out the form and file it with the Tribunal by e-mail or e-filing.1

By: Tribunal Clerk__________

Entered: January 30, 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

1 Though you may file the response by hard copy (i.e. mail), filing by e-mail or e-filing will facilitate the 

efficient administration of justice.

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

Associated Bank NA,

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v 

MTT Docket No. 25-001973

City Of Southfield,

Respondent.

NOTICE OF FILING OF MOTION TO WITHDRAW APPEAL

TAKE NOTICE that Petitioner has filed a Motion to Withdraw (Motion) in the above-

captioned appeal. Because the motion was not filed jointly (i.e. signed by both parties or 

representatives), Respondent has seven days from the service of the motion to file a 

response. Respondent may respond by agreeing to (i.e. concurrence) the withdrawal of 

the case or by objecting to the motion. If Respondent does not timely submit a 

concurrence or objection to the request, it will be deemed to be a concurrence and the 

request will be granted, unless otherwise ordered by the Tribunal. If the request is 

granted, the case will be dismissed. If a request is not granted or the Tribunal has not 

notified you that it has been granted, you are required to attend the hearing. 

For your convenience, you may use the Tribunal’s form “Response to Motion to 

Withdraw Appeal” located on the Tribunal’s website. To access the form, please go to 

our website at www.michigan.gov/taxtrib and go to either the “Entire Tribunal” or “Small 

Claims” page, depending on the division in which the case is pending. To submit the 

response, please fill out the form and file it with the Tribunal by e-mail or e-filing.2

By: Tribunal Clerk__________

Entered: January 30, 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

2 Though you may file the response by hard copy (i.e. mail), filing by e-mail or e-filing will facilitate the 

efficient administration of justice.

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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 

Petitioner(s) 

 

v 

 

 

 

 

 

 

 

MTT Docket No. 

 

 

 

 

_____________________________, 

Respondent(s) 

 

PROOF OF SERVICE 

 

 

___________________________________ states that on ___________________ he/she 

[Name of person serving/mailing petition] 

 

 

[date of service] 

 

served a copy of the ___________________ relative to the above-captioned matter upon: 

 

[Provide name and address of the party/people being served] 

 

________________________________________________ 

 

________________________________________________ 

 

________________________________________________ 

 

________________________________________________ 

 

 

 

 

 

 

 

 

 

 

_________________________________________ 

[Signature of person who is serving/mailing copy] 

 

_________________________________________ 

[Print/type name of person serving/mailing copy] 

 

 

 

 

ASSOCIATED BANK N.A.

25-001973

CITY OF SOUTHFIELD

DOUGLAS J. FRYER

JANUARY 29, 2026

Petitioner's Motion to

and by email at lhallahan@hallahanlaw.com

Laura M. Hallahan (P42101)

1750 S. Telegraph Road, Suite 202

Bloomfield Hills, MI 48302

/s/ DOUGLAS J. FRYER

DOUGLAS J. FRYER

Withdraw Petition

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Page 1

127479.000001 4916-9518-2219.1

DYKEMA GOSSETT PLLC • 39577 Woodward Avenue, Suite 300, Bloomfield Hills, Michigan 48304

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

ASSOCIATED BANK N.A., 

Petitioner, 

v. 

CITY OF SOUTHFIELD, 

Respondent. 

MTT Docket No. 25-001973 

Parcel ID No. 76-24-22-201-019 

Douglas J. Fryer (P51765) 

DYKEMA GOSSETT PLLC 

Attorneys for Petitioner 

39577 Woodward Avenue, Suite 300 

Bloomfield Hills, MI 48304 

(248) 203-0700 

dfryer@dykema.com 

Laura M. Hallahan (P42101) 

Seth A. O’Loughlin (P80257) 

Kelsea M. Melcher (P85821) 

HALLAHAN & ASSOCIATES, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

lhallahan@hallahanlaw.com 

soloughlin@hallahanlaw.com 

PETITIONER’S MOTION TO WITHDRAW PETITION 

Petitioner Associated Bank, N.A. (“Petitioner”), for its motion to withdraw Petition 

pursuant to TTR 237(4), states as follows: 

1. 

On May 30, 2023, Petitioner filed its Entire Tribunal Property Tax Petition (the 

“Petition”), seeking a reduction in the true cash and taxable values for the subject property. 

2. 

On September 18, 2025, Respondent City of Southfield (“Respondent”) filed its 

Answer to Petition, denying the requested relief. 

3. 

TTR 237(4) provides: 

A petition may be withdrawn upon a motion filed by the petitioner 

before the answer or first responsive motion has been filed with the 

tribunal. Once the answer or first responsive motion has been filed, a 

petition may be withdrawn upon motion filed by petitioner only if the

Page 2

DYKEMA GOSSETT PLLC • 39577 Woodward Avenue, Suite 300, Bloomfield Hills, Michigan 48304

other parties do not object to the withdrawal for substantive reasons. 

For purposes of this subrule, a request for costs is not a substantive 

reason. 

4. 

By its motion, Petitioner requests that this Tribunal enter an order providing that the 

Petition is withdrawn, and that the case is therefore closed. 

5. 

On January 23, 2026, Petitioner’s counsel contacted Respondent’s counsel and 

advised of its intent to file a motion to withdraw its Petition. Respondent’s counsel advised that 

Respondent does not object to the withdrawal. As such, withdrawal of the Petition at this time fully 

comports with TTR 237(4). 

WHEREFORE, Petitioner requests that the Tribunal grant its motion to withdraw the 

Petition and close the case. 

January 29, 2026 

Respectfully Submitted, 

By: /s/ Douglas J. Fryer

Douglas J. Fryer (P51765) 

DYKEMA GOSSETT PLLC 

39577 Woodward Avenue, Suite 300 

Bloomfield Hills, MI 48304 

(248) 203-0700 

dfryer@dykema.com

Page 3

DYKEMA GOSSETT PLLC • 39577 Woodward Avenue, Suite 300, Bloomfield Hills, Michigan 48304

CERTIFICATE OF SERVICE 

I hereby certify that on January 29, 2026, I served the foregoing Motion, upon counsel for 

Respondent, via email and first class mail, as follows: 

Laura M. Hallahan (P42101) 

HALLAHAN & ASSOCIATES, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

lhallahan@hallahanlaw.com 

I declare that the statement above is true to the best of my information, knowledge and belief. 

By: /s/ Denise Shiemke

Denise Shiemke 

Assistant to Douglas J. Fryer 

Dykema Gossett PLLC

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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

NOTICE OF DECEMBER 1 - 14, 2026 PREHEARING GENERAL CALL AND ORDER 

OF PROCEDURE

Associated Bank NA,

Petitioner,

v

 

 

City Of Southfield,

Respondent.

 MTT Docket No. 25-001973

Please be advised that 25-001973 has been placed on a two-week Prehearing General 

Call commencing December 01, 2026. 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. 25-001973

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 August 4, 2026. 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 August 4, 2026. 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 

August 4, 2026, 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 

December 1, 2026, 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

Page 3

MTT

Page 4

S

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Page 1

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

Associated Bank N.A., 

 

 

 

Petitioner, 

 

v 

 

City of Southfield, 

 

 

 

Respondent. 

 

 

 

MTT Docket No. 25-001973 

Parcel No. 76-24-22-201-019 

 

 

_____________________________________________________________________________/ 

 

DOUGLAS J. FRYER 

DYKEMA GOSSETT PLLC 

Representatives for Petitioner 

39577 Woodward Avenue, Suite 300 

Bloomfield Hills, MI 48304 

(248) 203-0767 

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 Southfield, by and through its attorneys, Hallahan & Associates, 

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

1. 

Respondent admits the allegations in Paragraph 1. 

 

2. 

Respondent admits the allegations in Paragraph 2. 

 

3. 

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

only one parcel was identified as under appeal and, thus, contiguity is not at issue. 

 

4. 

Respondent neither admits nor denies the allegations in Paragraph 4 for the reason that no 

statement is made. 

 

5. 

Respondent neither admits nor denies the allegations in Paragraph 5 for the reason that no 

statement is made.

Page 2

Entire Tribunal Property Tax Answer 

Page 2 of 5 

 

 

6. 

Respondent admits the allegations in Paragraph 6. 

 

7. 

Respondent neither admits nor denies the allegations in Paragraph 7 for the reason that no 

statement is made. 

 

8. 

Respondent neither admits nor denies the allegations in Paragraph 8 for the reason that no 

statement is made. 

 

9. 

Respondent neither admits nor denies the allegations in Paragraph 9 for the reason that no 

statement is made. 

 

10. 

Respondent admits the allegations in Paragraph 10. 

 

11. 

Respondent admits the assessment identified at issue was established by the City of 

Southfield. 

 

12. 

Respondent lacks the information and knowledge necessary to respond to the truth of the 

allegations set forth in Paragraph 12 and, therefore, leaves Petitioner to its proofs. 

 

13. 

Respondent acknowledges Petitioner’s beliefs as to the issues in this appeal as set forth in 

Paragraph 13 but denies that those issues have merit and denies that Petitioner is entitled 

to any relief. 

 

14. 

Respondent acknowledges Petitioner’s belief as to an issue with the 2025 tax year but 

denies any issue with said tax year. 

 

15. 

Respondent neither admits nor denies the allegations in Paragraph 15 for the reason that 

no statement is made. 

 

16. 

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

Review are: 

 

Tax Year 

True Cash Value 

Assessed Value 

Taxable Value 

2025 

$6,079,460 

$3,039,730 

$3,039,730 

 

17. 

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

 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2025 

$6,079,460 

$3,039,730 

$3,039,730 

 

18. 

The values in dispute for the property identified above are: 

 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2025 

$0 

$0 

$0

Page 3

Entire Tribunal Property Tax Answer 

Page 3 of 5 

 

 

19. 

Petitioner is not entitled to the relief requested in Paragraph 19 for the reason that 

Petitioner’s amounts do not reflect accurate valuations for the subject property. 

Furthermore, 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. 

 

20. 

Respondent denies the allegations set forth in Paragraph 20 support the relief requested 

by Petitioner. In further answer, 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. 

 

 

WHEREFORE, Respondent City of Southfield 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/ Seth A. O’Loughlin______________ 

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: September 18, 2025 

(248) 731-3089 

 

 

 

AFFIRMATIVE DEFENSES 

 

Respondent, City of Southfield, asserts the following affirmative defenses: 

1. 

Petitioner

Page 4

Entire

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MOAHR DOCKET NO. 25-001973

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

City Of Southfield (OAKLAND)

Local Unit of Government/First Name

M.I.

Last Name

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

City or Town

State

Michigan

ZIP Code

Telephone Number

Fax 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.

M

Last Name

Hallahan

Firm Name (if any)

Hallahan & Associates, P.C.

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

248-731-3087

Fax Number

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: 

Kelsea M. Melcher

/s/

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER 

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

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 

Petitioner(s) 

v 

MTT Docket No. 

 

_____________________________, 

Respondent(s) 

PROOF OF SERVICE FOR PROPERTY TAX PETITION 

*To be filed after the Tribunal issues the Notice of Docket Number* 

___________________________________ states that on ___________________ he/she 

[Name of person serving/mailing petition] 

[date of service] 

served a copy of the Petition relative to the above-captioned matter upon: 

[Provide name and address of the following entities] 

1. Assessor (via certified mail): 

______________________________________________________________________ 

______________________________________________________________________ 

2. City Clerk or Township Supervisor/Clerk (via certified mail): 

______________________________________________________________________ 

______________________________________________________________________ 

3. County Equalization Director (via first class mail or personal service): 

______________________________________________________________________ 

______________________________________________________________________ 

4. County Clerk (via first class mail or personal service): 

______________________________________________________________________ 

______________________________________________________________________ 

5. Secretary of the local school board (via first class mail or personal service): 

______________________________________________________________________ 

______________________________________________________________________ 

6. State Treasurer (via first class mail): 

Michigan Department of Treasury, State Treasurer 

430 W. Allegan 

Lansing, MI 48922 

 _______________________________ 

 _______________________________ 

[Signature of person who is serving/mailing copy]

[Print/type name of person serving/mailing copy]

ASSOCIATED BANK N.A.

25-001973

CITY OF SOUTHFIELD

DOUGLAS J. FRYER

AUGUST 13, 2025

Justin Prybylski, City Assessor, City of Southfield Assessing Dept., 26000 Evergreen

Road, Southfield, MI 48037

Janet Jackson, City Clerk, City of Southfield Clerk's Office, 26000 Evergreen Road,

Southfield, MI 48037

Michael Lohmeier, Oakland County Equalization Director, 250 Elizabeth Lake Road,

Suite 1000W, Pontiac, MI 48341

Lisa Brown, Clerk, Oakland County Clerk's Office, 1200 N. Telegraph Road, Bldg. 12E,

Pontiac, MI 48341

Carolyn Foster, Secretary, Southfield Board of Education, John W. English

Administrative Building, 24661 Lahser Road, Southfield, MI 48033

/s/ Douglas J. Fryer

Douglas J. Fryer

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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 

Petitioner(s) 

v 

MTT Docket No. 

 

_____________________________, 

Respondent(s) 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

1. 

Property Parcel No: _____________________________________________ 

(If more than one parcel is at issue, attach a completed Multiple Parcel Petition 

Form addressing all other parcels at issue.) 

2. 

The property identified above is ___real ___personal. 

3. 

If more than one parcel of real property is under appeal, are the properties 

contiguous? ___Yes ___No. (If no, separate Petitions are required for each non-

contiguous parcel.) 

4. 

Are all of the parcels of personal property located on a parcel of real property 

under appeal? ___Yes ___No. (If no, separate Petitions are required for each 

parcel of personal property not located on a parcel of real property under 

appeal.) 

5. 

If parcels of personal property are under appeal, when were the personal 

property statements filed by parcel number (attach additional page if necessary): 

6. 

The property identified above is classified as _________________________ 

7. 

If the assessment or assessments at issue were protested, the protest was made 

to Respondent’s ___ March ___ July ___December Board of Review. 

ASSOCIATED BANK, N.A.

CITY OF SOUTHFIELD

76-24-22-201-019

X

N/A

N/A

N/A

201 COMMERCIAL-IMPROVED

N/A

Page 2

MTT Docket No. _________________ 

Page 2 of 4 

8. 

If a protest was required and no protest was made, list the separate and specific 

facts upon which Petitioner relies to invoke the Tribunal’s authority over the 

assessment or assessments at issue (attach additional page if necessary): 

9. 

If the appeal was not submitted by the deadline for the filing of an appeal for the 

classification or classifications of the properties at issue (i.e., May 31 or July 31 

of the tax year involved), list the separate and specific facts upon which 

Petitioner relies to invoke the Tribunal’s authority over the assessment or 

assessments at issue (attach additional page if necessary): 

10. 

The property or properties at issue are located in _______________County. The 

property or properties’ address is: 

11. 

The assessment or assessments at issue were established by the (applicable 

local governmental unit): ________________________________________ 

12. 

Petitioner’s legal residence or principal office address is: 

13. 

This appeal involves issues relating to the (check all that are applicable): 

________the property or properties’ true cash and taxable values 

________the property or properties’ taxable value only 

If the property or properties’ taxable value is at issue, is there a 

dispute as to the value of an addition or loss? ___ Yes ___No 

________uniformity of the property or properties’ assessment 

________the property or the properties’ exemption from ad valorem taxation 

 under MCL ______ 

14. 

The tax year(s) at issue are: _______________________________________ 

N/A

N/A

OAKLAND

20500 CIVIC CENTER DR., SOUTHFIELD, MI 48076

CITY OF SOUTHFIELD ASSESSOR

111 E. KILBOURN AVE.

MILWAUKEE, WI 53202

X

X

2025

Page 3

MTT Docket No. _________________ 

Page 3 of 4 

15. 

If more than the current tax year is being appealed, list the separate and specific 

facts upon which Petitioner relies to invoke the Tribunal’s authority over the prior 

tax year or years (attach additional page if necessary): 

16. 

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

Board of Review are: 

Tax Year 

True Cash Value 

Assessed Value 

Taxable Value 

17. 

Petitioner contends that the values for the property identified above are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

18. 

The values in dispute for the property identified above are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

19. 

Petitioner requests the following relief (attach additional page if necessary): 

20. 

List the separate and specific facts upon which Petitioner relies to support the 

relief requested (attach additional page if necessary): 

N/A

2025

$6,079,460

$3,039,730

$3,039,730

2025

$2,700,000

$1,350,000

$1,350,000

2025

$3,379,460

$1,689,730

$1,689,730

Petitioner requests that the Michigan Tax Tribunal enter its order determining the assessed

and taxable values to be in the amounts set forth in Sec. 17, or less, and requiring Respondent

to correct its assessment roll in accordance with such determination and to refund to Petitioner

any taxes paid in excess of such determination with interest, costs and fees.

The subject property is a commercial office building. It was built in 1977 and has a total

floor area of 180,288 square feet. The subject property is a single-tenant building and

Page 4

MTT

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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

Associated Bank NA, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-001973

City Of Southfield, 

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: August 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

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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 

Petitioner(s) 

v 

MTT Docket No. 

 

_____________________________, 

Respondent(s) 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

1. 

Property Parcel No: _____________________________________________ 

(If more than one parcel is at issue, attach a completed Multiple Parcel Petition 

Form addressing all other parcels at issue.) 

2. 

The property identified above is ___real ___personal. 

3. 

If more than one parcel of real property is under appeal, are the properties 

contiguous? ___Yes ___No. (If no, separate Petitions are required for each non-

contiguous parcel.) 

4. 

Are all of the parcels of personal property located on a parcel of real property 

under appeal? ___Yes ___No. (If no, separate Petitions are required for each 

parcel of personal property not located on a parcel of real property under 

appeal.) 

5. 

If parcels of personal property are under appeal, when were the personal 

property statements filed by parcel number (attach additional page if necessary): 

6. 

The property identified above is classified as _________________________ 

7. 

If the assessment or assessments at issue were protested, the protest was made 

to Respondent’s ___ March ___ July ___December Board of Review. 

ASSOCIATED BANK, N.A.

CITY OF SOUTHFIELD

76-24-22-201-019

X

N/A

N/A

N/A

201 COMMERCIAL-IMPROVED

N/A

Page 2

MTT Docket No. _________________ 

Page 2 of 4 

8. 

If a protest was required and no protest was made, list the separate and specific 

facts upon which Petitioner relies to invoke the Tribunal’s authority over the 

assessment or assessments at issue (attach additional page if necessary): 

9. 

If the appeal was not submitted by the deadline for the filing of an appeal for the 

classification or classifications of the properties at issue (i.e., May 31 or July 31 

of the tax year involved), list the separate and specific facts upon which 

Petitioner relies to invoke the Tribunal’s authority over the assessment or 

assessments at issue (attach additional page if necessary): 

10. 

The property or properties at issue are located in _______________County. The 

property or properties’ address is: 

11. 

The assessment or assessments at issue were established by the (applicable 

local governmental unit): ________________________________________ 

12. 

Petitioner’s legal residence or principal office address is: 

13. 

This appeal involves issues relating to the (check all that are applicable): 

________the property or properties’ true cash and taxable values 

________the property or properties’ taxable value only 

If the property or properties’ taxable value is at issue, is there a 

dispute as to the value of an addition or loss? ___ Yes ___No 

________uniformity of the property or properties’ assessment 

________the property or the properties’ exemption from ad valorem taxation 

 under MCL ______ 

14. 

The tax year(s) at issue are: _______________________________________ 

N/A

N/A

OAKLAND

20500 CIVIC CENTER DR., SOUTHFIELD, MI 48076

CITY OF SOUTHFIELD ASSESSOR

111 E. KILBOURN AVE.

MILWAUKEE, WI 53202

X

X

2025

Page 3

MTT Docket No. _________________ 

Page 3 of 4 

15. 

If more than the current tax year is being appealed, list the separate and specific 

facts upon which Petitioner relies to invoke the Tribunal’s authority over the prior 

tax year or years (attach additional page if necessary): 

16. 

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

Board of Review are: 

Tax Year 

True Cash Value 

Assessed Value 

Taxable Value 

17. 

Petitioner contends that the values for the property identified above are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

18. 

The values in dispute for the property identified above are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

19. 

Petitioner requests the following relief (attach additional page if necessary): 

20. 

List the separate and specific facts upon which Petitioner relies to support the 

relief requested (attach additional page if necessary): 

N/A

2025

$6,079,460

$3,039,730

$3,039,730

2025

$2,700,000

$1,350,000

$1,350,000

2025

$3,379,460

$1,689,730

$1,689,730

Petitioner requests that the Michigan Tax Tribunal enter its order determining the assessed

and taxable values to be in the amounts set forth in Sec. 17, or less, and requiring Respondent

to correct its assessment roll in accordance with such determination and to refund to Petitioner

any taxes paid in excess of such determination with interest, costs and fees.

The subject property is a commercial office building. It was built in 1977 and has a total

floor area of 180,288 square feet. The subject property is a single-tenant building and

Page 4

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

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

Associated Bank, N.A.

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

111 E. Kilbourn Avenue

Suite 300

City or Town

Milwaukee

State

Wisconsin

ZIP Code

53202

Telephone Number

248-203-0700

Fax Number

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

dfryer@dykema.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Douglas

M.I.

J

Last Name

Fryer

Firm Name (if any)

Dykema Gossett PLLC

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

39577 Woodward Ave Ste 300

City or Town

Bloomfield Hills

State

Michigan

ZIP Code

48304

Telephone Number

248-203-0767

Fax Number

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

dfryer@dykema.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]

20500 Civic Center Drive

Southfield

Michigan

48076

Taxing Authority (City or Township)

City Of Southfield (OAKLAND)

County

Oakland

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:

76-24-22-201-019

Classification of Property: Real 

Commercial

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

3039730

Current Taxable Value as established by the Board of Review:

3039730

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

2700000

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

1350000

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/ /s/ Douglas J. Fryer

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.