Blossom Creek LLC Petitioner Vs. Township Of Oakland Respondent

Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

BLOSSOM CREEK LLC, 

 

 

Petitioner, 

 

 

 

 

 

MTT Docket No.: 26-001622-TT 

 

 

 

 

 

Parcel No.:10-31-200-011 

 

v. 

 

 

 

 

 

 

 

 

 

CHARTER TOWNSHIP OF OAKLAND, 

Respondent. 

_____________________________________________________________________________ 

Jerome P. Pesick (P29039) 

 

 

 

Zachary Learman (P71005) 

Richard E. Rassel III (P57540) 

 

 

Daniel J. Kelly (P41315) 

Jason C. Long (P59244) 

 

 

 

THE KELLY FIRM, PLC 

WILLIAMS, WILLIAMS, RATTNER, 

 

Attorneys for Respondent 

& PLUNKETT, PC 

 

 

 

512 E. 11 Mile Rd 

Attorneys for Petitioner 

 

 

 

Royal Oak, MI 48067 

380 N. Old Woodward Ave., Ste 300 

 

(248) 655-7025 

(248) 642-0333 

 

 

 

 

zack@kellyfirmpc.com 

Attorneys for Respondent 

 

 

jpesick@wwrplaw.com 

 

 

 

 

APPEARANCE 

 

The undersigned hereby enters her appearance as attorney for the Township of Oakland in 

the above-entitled cause. 

Respectfully submitted, 

 

/s/ Zachary Learman 

 

 

Zachary Learman (P71005) 

The Kelly Firm, PLC 

Attorneys for the Township of Oakland 

512 E. 11 Mile Rd. 

Royal Oak, MI 48067 

(248) 655-7025 

Dated: September 25, 2026

Page 2

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

BLOSSOM CREEK LLC, 

 

 

Petitioner, 

 

 

 

 

 

MTT Docket No.: 26-001622-TT 

 

 

 

 

 

Parcel No.:10-31-200-011 

 

v. 

 

 

 

 

 

 

 

 

 

CHARTER TOWNSHIP OF OAKLAND, 

Respondent. 

_____________________________________________________________________________ 

Jerome P. Pesick (P29039) 

 

 

 

Zachary Learman (P71005) 

Richard E. Rassel III (P57540) 

 

 

Daniel J. Kelly (P41315) 

Jason C. Long (P59244) 

 

 

 

THE KELLY FIRM, PLC 

WILLIAMS, WILLIAMS, RATTNER, 

 

Attorneys for Respondent 

& PLUNKETT, PC 

 

 

 

512 E. 11 Mile Rd 

Attorneys for Petitioner 

 

 

 

Royal Oak, MI 48067 

380 N. Old Woodward Ave., Ste 300 

 

(248) 655-7025 

(248) 642-0333 

 

 

 

 

zack@kellyfirmpc.com 

Attorneys for Respondent 

 

 

jpesick@wwrplaw.com 

 

 

 

 

PROOF OF SERVICE 

 

 

Julian Slavsky hereby affirms that on September 25, 2026, via electronic mail, she served 

a copy of the Appearance upon: 

 

 

 

 

Jerome P. Pesick (P29039) 

 

 

 

 

WILLIAMS, WILLIAMS, RATTNER & PLUNKETT, PC 

 

 

 

 

jpesick@wwrplaw.com 

 

 

 

 

 

 

 

 

Attorney for Petitioner 

 

 

 

 

 

 

 

 

 

 

/s/ Julian Slavsky 

Dated: September 25, 2026 

 

 

 

 

Julian Slavsky

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

MICHIGAN TAX TRIBUNAL

Docket Number: 26-001622

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

Party Filing Document 

Respondent

Files

Document Type: Appearance

Attachment File Name: Appearance & POS Learman 2026.09.25

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 TAX TRIBUNAL 

 

BLOSSOM CREEK LLC, 

 

 

Petitioner, 

 

 

 

 

 

MTT Docket No.: 26-001622-TT 

 

 

 

 

 

Parcel No.:10-31-200-011 

 

v. 

 

 

 

 

 

 

 

 

 

CHARTER TOWNSHIP OF OAKLAND, 

Respondent. 

_____________________________________________________________________________ 

Jerome P. Pesick (P29039) 

 

 

 

Zachary Learman (P71005) 

Richard E. Rassel III (P57540) 

 

 

Daniel J. Kelly (P41315) 

Jason C. Long (P59244) 

 

 

 

THE KELLY FIRM, PLC 

WILLIAMS, WILLIAMS, RATTNER, 

 

Attorneys for Respondent 

& PLUNKETT, PC 

 

 

 

512 E. 11 Mile Rd 

Attorneys for Petitioner 

 

 

 

Royal Oak, MI 48067 

380 N. Old Woodward Ave., Ste 300 

 

(248) 655-7025 

(248) 642-0333 

 

 

 

 

zack@kellyfirmpc.com 

Attorneys for Respondent 

 

 

jpesick@wwrplaw.com 

 

 

 

 

RESPONDENT’S ANSWER TO PETITION, 

AFFIRMATIVE DEFENSES, AND PROOF OF SERVICE 

 

 

NOW COMES the Respondent, TOWNSHIP OF OAKLAND, by its attorneys, THE 

KELLY FIRM, PLC, and for its answer to the Entire Tribunal Property Tax Petition, states as 

follows: 

1. In response to paragraph 1, Respondent neither admits nor denies same for lack of 

sufficient information and leave Petitioner to its proofs. 

2. In response to paragraph 2, Respondent neither admits nor denies same for lack of 

sufficient information and leave Petitioner to its proofs. 

3. In response to paragraph 3, Respondent admits the allegations contained therein.

Page 2

4. In response to paragraph 4, Respondent admits the allegations contained therein. 

5. In response to paragraph 5, Respondent neither admits nor denies same for lack of 

sufficient information and leave Petitioner to its proofs. 

6. In response to paragraph 6, Respondent neither admits nor denies same for lack of 

sufficient information and leave Petitioner to its proofs. 

7. In response to paragraph 7, Respondent admits the allegations contained therein. 

8. In response to paragraph 8, Respondent neither admits nor denies same for lack of 

sufficient information and leave Petitioner to its proofs. 

9. In response to paragraph 9, Respondent admits the allegations contained therein. 

10. In response to paragraph 10, Respondent neither admits nor denies same for lack of 

sufficient information and leave Petitioner to its proofs. 

11. In response to paragraph 11, Respondent neither admits nor denies same for lack of 

sufficient information and leave Petitioner to its proofs. 

12. In response to paragraph 12, Respondent neither admits nor denies same for lack of 

sufficient information and leave Petitioner to its proofs. 

AFFIRMATIVE DEFENSES 

NOW COMES the Respondent, TOWNSHIP OF OAKLAND, by its attorneys, THE 

KELLY FIRM, PLC, and files the following Affirmative Defenses in support of its 

Answer to the Petition: 

1. The facts as alleged by the Petitioner do not establish mutual mistake of fact. 

2. Petitioner has failed to allege specific and sufficient facts upon which the mode 

and method of appraising property fails to conform with mode and method applied to 

all other properties in the community.

Page 3

3. Petitioner has failed to show that any fact other than fifty percent (50%) was 

applied to the true cash value of the property. 

4. Petitioner’s claim, if prevailed upon, would create a windfall for Petitioner and 

create a burden upon the Township, schools, County taxes, and other property owners 

in the community. 

5. Petitioner is asking this Honorable Tribunal to make an underassessment based 

upon an arbitrary basis. 

6. A levy of all taxes is required to be made based upon the assessment of fifty 

percent (50%) of true cash value as ultimately determined by the process of County 

and State equalization. 

7. Respondent reserves the right to file additional Affirmative Defenses as may 

become apparent in this case. 

 

 

 

 

 

 

 

THE KELLY FIRM, PLC 

 

 

 

 

 

 

 

 

Respectfully submitted, 

 

 

Dated: September 25, 2026 

 

 

 

/s/ Zachary Learman 

 

 

 

 

 

 

 

 

Zachary Learman (P71005) 

 

 

 

 

 

 

 

Attorney for Plaintiff 

 

 

 

 

 

 

 

512 E. Eleven Mile Rd 

Royal Oak, Michigan 48067 

(248) 655-7025 

 

 

 

 

 

 

 

zack@kellyfirmpc.com 

 

 

PROOF OF SERVICE 

 

 

The undersigned states that on September 25, 2026, she electronically filed Appearance, 

Respondent's Answer to Petition, Affirmative Defenses, and this Proof of Service with the 

Michigan Tax Tribunal via the Tribunal's E-filing System and served a copy upon Representative 

for Petitioner via electronic mail to Petitioners address at jpesick@wwrplaw.com. 

 

 

/s/ Julian Slavsky 

 Julian Slavsky

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

MICHIGAN TAX TRIBUNAL

Docket Number: 26-001622

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

Party Filing Document 

Respondent

Files

Document Type: Documentation

Attachment File Name: Resp Answer & Affirm Defense Bloom Creek LLC 2026.09.25

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 

Blossom Creek LLC, 

Docket No. 26-001622 

Petitioner, 

Parcel No. 10-31-200-011 

v. 

Charter Township of Oakland, 

Respondent. 

Jerome P. Pesick (P29039) 

Richard E Rassel, III (P57540) 

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, by placing those documents in a duly 

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

on September 4, 2026. 

PERSONS SERVED: 

Certified Mail 

First Class Mail 

Clerk 

Clerk 

Secretary of School Board 

Township of Oakland 

Oakland County 

Rochester 

Community 

School 

4393 Collins Road 

1200 North Telegraph Rd 

District 

Rochester, MI 48306 

Building 12E 

52585 Dequindre Road 

Pontiac, MI 48341 

Rochester, MI 48307 

Assessor 

Director of Equalization 

State Treasurer 

Township of Oakland 

Oakland County 

Michigan Dep't of Treasury 

4393 Collins Road 

250 Elizabeth Lake Rd. 

Austin Building 

Rochester, MI 48306 

Suite 1000W 

430 W. Allegan 

Pontiac, MI 48341 

Lansing, MI 

48922 

Monica Athanas

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

MICHIGAN TAX TRIBUNAL

Docket Number: 26-001622

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: Blossom Creek - 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 

 

 

Blossom Creek LLC, 

 

 

 

 

 

 

 

 

Docket No. 26- 

 

Petitioner, 

 

 

 

 

 

Parcel No. 10-31-200-011 

 

v. 

 

Charter Township of Oakland, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Jerome P. Pesick (P29039) 

Richard E Rassel, III (P57540) 

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 Blossom Creek, 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 Blossom Creek, LLC is a Michigan limited liability company 

with its principal place of business located in Michigan at 3005 University Drive, 

Suite 100, Auburn Hills, MI 48326. 

2. 

Respondent Charter Township of Oakland is a Michigan township with

Page 2

its principal offices located at 4393 Collins Road, Rochester, MI 48306. 

The Subject Property 

3. 

Petitioner owns property identified as Parcel No. 10-31-200-011 and 

commonly known as 3096 Tribute Creek Blvd, Oakland Township, MI 48306 (the 

“Subject Property”). 

4. 

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

Rochester Community School District. 

5. 

Respondent possesses jurisdiction to assess and collect property taxes 

for the Subject Property. 

The 2026 Assessment 

6. 

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

commercial 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 

 20,095,880 

 10,047,940 

 9,027,460 

 

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 

 14,000,000 

 7,000,000 

 7,000,000 

 

9. 

The amounts in dispute therefore are as follows: 

True Cash Value 

Assessed Value 

Taxable Value 

 6,095,880 

 3,047,940 

 2,027,460

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: May 27, 2026 

 

 

Attorneys for Petitioner

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Petitioner

MTT DOCKET NO. 

 

Section 1: Petitioner’s Contact Information

Filer type: 

Organization 

Local Unit of Government

First Name

M.I.

Last Name/Company Name

Blossom Creek LLC

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

3005 University Drive, Suite 100

City or Town

Auburn Hills

State

Michigan

ZIP Code

48326

Telephone Number

2486420333

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)

Williams, Williams, Rattner & Plunkett, PC

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

380 N. Old Woodward, Ste 300

City or Town

Birmingham

State

Michigan

ZIP Code

48009

Telephone Number

2486420333

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

jpesick@wwrplaw.com

 

Section 3: Issue 

Please designate one: 

Valuation 

 

Section 4: Subject Property Information 

How many parcels are you 

appealing?

1

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

3096 Tribute Creek Blvd

Oakland Township

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48306

Taxing Authority (City or Township)

Township Of Oakland (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.)

N/A

 

 

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

True Cash and Taxable Values

If “Other”, please explain:

 

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

10-31-200-011

Classification of Property: Real (check one)

Commercial (check one)

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

10047940

Current Taxable Value as established by the Board of Review:

9027460

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

14000000

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

7000000

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

7000000

Fee Information

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

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

appealed.

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

 

 $100,000.00 and under $250.00

 $100,000.01 to $500,000.00 $400.00

 $Over $500,000.00 $600.00

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

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

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

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

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

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

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

Petitioner or Attorney/Authorized Representative’s Signature: 

/s/ Jerome P. Pesick

Payment Information

Amount: 600

Success: True

Message: ""

Waiver Code:

Transaction Number: 26052787106347

Supporting Waiver Documents:

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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

Blossom Creek LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-001622

Township Of Oakland, 

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 20, 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

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

 

Blossom Creek LLC, 

 

 

 

 

 

 

 

 

Docket No. 26- 

 

Petitioner, 

 

 

 

 

 

Parcel No. 10-31-200-011 

 

v. 

 

Charter Township of Oakland, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Jerome P. Pesick (P29039) 

Richard E Rassel, III (P57540) 

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 Blossom Creek, 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 Blossom Creek, LLC is a Michigan limited liability company 

with its principal place of business located in Michigan at 3005 University Drive, 

Suite 100, Auburn Hills, MI 48326. 

2. 

Respondent Charter Township of Oakland is a Michigan township with

Page 2

its principal offices located at 4393 Collins Road, Rochester, MI 48306. 

The Subject Property 

3. 

Petitioner owns property identified as Parcel No. 10-31-200-011 and 

commonly known as 3096 Tribute Creek Blvd, Oakland Township, MI 48306 (the 

“Subject Property”). 

4. 

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

Rochester Community School District. 

5. 

Respondent possesses jurisdiction to assess and collect property taxes 

for the Subject Property. 

The 2026 Assessment 

6. 

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

commercial 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 

 20,095,880 

 10,047,940 

 9,027,460 

 

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 

 14,000,000 

 7,000,000 

 7,000,000 

 

9. 

The amounts in dispute therefore are as follows: 

True Cash Value 

Assessed Value 

Taxable Value 

 6,095,880 

 3,047,940 

 2,027,460

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: May 27, 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

Entire Tribunal Case Information Sheet - Petitioner

MTT DOCKET NO. 

 

Section 1: Petitioner’s Contact Information

Filer type: 

Organization 

Local Unit of Government

First Name

M.I.

Last Name/Company Name

Blossom Creek LLC

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

3005 University Drive, Suite 100

City or Town

Auburn Hills

State

Michigan

ZIP Code

48326

Telephone Number

2486420333

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)

Williams, Williams, Rattner & Plunkett, PC

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

380 N. Old Woodward, Ste 300

City or Town

Birmingham

State

Michigan

ZIP Code

48009

Telephone Number

2486420333

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

jpesick@wwrplaw.com

 

Section 3: Issue 

Please designate one: 

Valuation 

 

Section 4: Subject Property Information 

How many parcels are you 

appealing?

1

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

3096 Tribute Creek Blvd

Oakland Township

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48306

Taxing Authority (City or Township)

Township Of Oakland (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.)

N/A

 

 

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

True Cash and Taxable Values

If “Other”, please explain:

 

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

10-31-200-011

Classification of Property: Real (check one)

Commercial (check one)

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

10047940

Current Taxable Value as established by the Board of Review:

9027460

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

14000000

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

7000000

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

7000000

Fee Information

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

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

appealed.

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

 

 $100,000.00 and under $250.00

 $100,000.01 to $500,000.00 $400.00

 $Over $500,000.00 $600.00

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

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

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

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

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

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

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

Petitioner or Attorney/Authorized Representative’s Signature: 

/s/ Jerome P. Pesick

Payment Information

Amount: 600

Success: True

Message: ""

Waiver Code:

Transaction Number: 26052787106347

Supporting Waiver Documents:

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.