Canterbury Realty Holdings LLC Petitioner Vs. Township Of Waterford Respondent

Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

Canterbury Realty Holdings LLC, 

 

 

 

Petitioner, 

 

Charter Township of Waterford, 

 

 

 

Respondent. 

 

 

 

MTT Docket No. 26-001597 

 

_____________________________________________________________________________/ 

 

DOUGLAS J. FRYER (P51765) 

DYKEMA GOSSETT PLLLC 

Attorney for Petitioner 

39577 Woodward Ave, Suite 300 

Bloomfield Hills, MI 48304 

 

 

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 

_____________________________________________________________________________/ 

 

RESPONDENT’S SUBSTITUTION OF AUTHORIZED REPRESENTATIVE 

 

Hallahan & Associates, P.C. will substitute in place of Paula Moore of Charter Township 

of Waterford as Representative for Respondent Charter Township of Waterford. 

_/s/ Paula Moore________________ 

Paula Moore 

Assessor 

Charter Township of Waterford 

 

 

Dated: September 29, 2026 

__/s/ Laura M. Hallahan____________ 

Laura M. Hallahan (P42101) 

Seth O’Loughlin (P80257) 

Kelsea M. Melcher (P85821) 

 

 

Dated: September 29, 2026

Page 2

MTT Docket No. 26-001597 

 

 

2

PROOF OF MAILING 

 

On the date below I sent by electronic mail a copy of the foregoing Respondent’s Substitution of 

Authorized Representative to: 

 

Douglas J. Fryer. 

dfryer@dykema.com 

 

 

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

 

 

/s/ Laura M. Hallahan_______ 

Dated: September 29, 2026 

Laura M. Hallahan

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: 26-001597

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

Party Filing Document 

Respondent

Files

Document Type: Substitution of Counsel

Attachment File Name: Substitution- Waterford

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 

MICHIGAN TAX TRIBUNAL 

CANTERBURY REALTY HOLDINGS LLC 

Petitioner 

vs. 

Docket No: 26-001597 

Parcel(s): W-13-16-126-001 

TOWNSHIP OF WATERFORD 

Respondent 

ANSWER TO PETITION 

Now comes the Township of Waterford, a Michigan Municipal 

Corporation, through its’ Assessor, Paula Moore, and answers the Petition heretofore 

filed in this cause. 

1) 

Answering paragraph one of the Petition, Respondent admits the 

allegations therein contained. 

2) 

Answering paragraph two of the Petition, Respondent admits the 

allegations therein contained. 

3) N/A 

4) N/A 

5) N/A 

6) 

Answering paragraph five of the Petition, Respondent admits the 

allegations therein contained. 

7) N/A 

8) N/A

Page 2

10) 

Answering paragraph ten of the Petition, Respondent admits the 

allegations therein contained. 

11) 

Answering paragraph eleven of the Petition, Respondent admits the 

allegations therein contained. 

12) 

Answering paragraph twelve of the Petition, Respondent admits the 

allegations therein contained. 

13) 

Answering paragraph thirteen of the Petition, Respondent denies the 

allegations therein contained. 

14) 

Answering paragraph fourteen of the Petition, Respondent denies the 

allegations therein contained. 

15) N/A 

16) Answering paragraph sixteen of the Petition, Respondent admits the 

allegations therein contained. 

17) Answering paragraph seventeen of the Petition, Respondent denies the 

allegations therein contained. 

18) Answering paragraph eighteen of the Petition, Respondent denies the 

allegations therein contained. 

19) Answering paragraph nineteen of the Petition, Respondent denies the 

allegations therein contained. 

20) Answering paragraph twenty of the Petition, Respondent denies the 

allegations therein contained. 

Wherefore, Respondent respectfully requests that the Petitioners’ claim be 

denied and that the Tribunal sustains the assessed value of $17,424,030 and the taxable 

value of $17,424,030 as confirmed by the local Board of Review.

Page 3

AFFIRMATIVE DEFENSES 

For its further Answer to Petitioner’s Petition and by way of its Affirmative Defenses, 

Respondent states as follows and demands an answer from Petitioner as to each: 

1. 

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

against Respondent and to support its claim for relief. 

2. 

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

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

3. 

Petitioner fails to allege that the mode and method of appraising its property failed 

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

Respondent’s taxing unit for the year in question. 

4. 

Petitioner fails to allege specific and sufficient facts to establish the true cash value, 

assessed value and taxable value of its property. 

5. 

Petitioner fails to allege specific and sufficient facts to support its allegation that the 

assessed value of its property, as equalized, is at a factor other than 50% and also fails to allege 

specific and sufficient facts to support its allegations that the property’s taxable value is 

improper. 

6. 

Petitioner fails to show that any rate other than 50% after equalization was applied 

to the true cash value of its property, as well as to the properties of all others to arrive at the 

respective equalized assessments.

Page 4

8. 

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

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

9. 

If Petitioner appeared at the Board of Review, Petitioner failed in its appearance 

before the Board of Review to specifically allege: 

A. The equalized assessment of the property is more than 50% of its true cash 

value and that the taxable value is in violation of applicable statutory and 

constitutional limitations. 

The property is assessed in a discriminatory manner and that the assessment 

is a higher level of true cash value than the average level of assessment of all 

other property within the Township of Waterford, excepting this property 

which is also under appeal. 

C. 

The assessment and taxable value are unlawful and based upon the 

application of wrong principles and thereby operate as a constructive 

fraud upon the taxpayer. 

D. 

Sufficient evidence to enable the Board of Review to make a decision. 

The failure to raise such objections to the Respondent’s Board of Review, if a Board of Review 

appearance was required, constitutes a failure to exhaust the administrative remedies provided 

for by the General Property Tax Act, constitutes a waiver of any such allegations contained in 

the Petition, and further amounts to a failure by the Petitioner to appear in protest to 

Respondent’s Board of Review as required by the Tax Tribunal Act. 

10. 

Any decrease in the value of Petitioner's property was a result of its own 

intentional acts and/or negligence and cannot be allowed to reduce Petitioner's otherwise

Page 5

WHEREFORE, Respondent, CITY OF KEEGO HARBOR, demands that Petitioner respond to 

these Affirmative Defenses and denies that Petitioner is entitled to the relief it seeks and 

respectfully requests that the Respondent's assessment and taxable value of the subject 

property be affirmed or increased and that the Petitioner's Petition be dismissed with prejudice 

and that Respondent be granted costs and

Page 6

ST

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: 26-001597

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

Party Filing Document 

Respondent

Files

Document Type: Response to Order - Answer

Attachment File Name: Docket No 26-001597

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

= 

Tn 

Lh 

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON 

I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

CANTERBURY REALTY HOLDINGS, LLC 

| 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

Vv 

MTT Docket No.26-001597 

TOWNSHIP OF WATERFORD 

Respondent(s) 

PROOF OF SERVICE FOR PROPERTY TAX PETITION 

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

DOUGLAS J. FRYER 

states that on AUGUST 28, 2026 

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): 

Paula Moore, Assessing Department, 5200 Civil Center Drive, Waterford, 

MI 48329 

2. 

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

Anthony M.Bartolotta, Supervisor, Waterford Township Supervisor's Office, 5200 Civil 

Center Drive, Waterford, MI 48329 

3. 

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

Michael R. Lohmeier, County Equalization Director, 250 Elizabeth Lake Road, Suite 

1000, Pontiac, MI 48341 

4. 

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

Lisa Brown, Oakland County Clerk, 1200 North Telegraph Road, 

Building 12E 

Pontiac, MI 48341 

5. 

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

Michael Ristich, 

Ph.D., Secretary, Board of Education, Waterford School District, 

501 

N. Cass Lake Road, Waterford, MI 48328 

6. 

State Treasurer (via first class mail): 

Michigan Department of Treasury, State Treasurer 

430 W. Allegan 

Lansing, MI 48922 

/s/ DOUGLAS J. FRYER 

DOUGLAS J. FRYER 

[Signature of person who is serving/mailing copy] 

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

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

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: 26-001597

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: Canterbury - ET Proof of Service of 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

v

STATE OF MICHIGAN

GRETCHEN WHITMER

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

MARLON I. BROWN, DPA

GOVERNOR

DIRECTOR

LANSING

_____________________________,

MICHIGAN TAX TRIBUNAL

Petitioner(s)

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.

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

CANTERBURY REALTY HOLDINGS LLC

CHARTER TOWNSHIP OF WATERFORD

W-13-16-126-001

 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

5601 HATCHERY RD.

WATERFORD, MI 48329

WATERFORD TWP. ASSESSOR

175 ROUTE 70

TOMS RIVER, NJ 08755

 X

 X

2026

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

2026

$34,848,060

$17,424,030

$17,424,030

2026

$20,000,000

$10,000,000

$10,000,000

2026

$14,848,060

$7,424,030

$7,424,030

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

taxable value of the subject real property to be an amount less than $10,000,000 and requiring

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

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

See Attached.

Page 4

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

MTT Docket No. _________________

Page 4 of 4

Signature of Petitioner’s Authorized Representative or, if none, Petitioner:

Printed Name of Petitioner’s Authorized Representative or, if none, Petitioner:

Email Address:

Page 5

Canterbury Realty Holdings LLC v Charter

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

Canterbury Realty Holdings LLC

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

175 Route 70

Suite 300

City or Town

Toms River

State

New Jersey

ZIP Code

08755

Telephone Number

248-203-0767

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 Avenue

Suite 300

City or Town

Bloomfield Hills

State

Michigan

ZIP Code

48304

Telephone Number

2482030767

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

dfryer@dykema.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]

5601 Hatchery Road

Waterford

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48329

Taxing Authority (City or Township)

Township Of Waterford (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:

W-13-16-126-001

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:

17424030

Current Taxable Value as established by the Board of Review:

17424030

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

20000000

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

10000000

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

7424030

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/ /s/ Douglas J. Fryer

Payment Information

Amount: 600

Success: True

Message: ""

Waiver Code:

Transaction Number: 26052787097229

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.

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

Canterbury Realty Holdings LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-001597

Township Of Waterford, 

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 19, 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

v

STATE OF MICHIGAN

GRETCHEN WHITMER

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

MARLON I. BROWN, DPA

GOVERNOR

DIRECTOR

LANSING

_____________________________,

MICHIGAN TAX TRIBUNAL

Petitioner(s)

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.

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

CANTERBURY REALTY HOLDINGS LLC

CHARTER TOWNSHIP OF WATERFORD

W-13-16-126-001

 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

5601 HATCHERY RD.

WATERFORD, MI 48329

WATERFORD TWP. ASSESSOR

175 ROUTE 70

TOMS RIVER, NJ 08755

 X

 X

2026

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

2026

$34,848,060

$17,424,030

$17,424,030

2026

$20,000,000

$10,000,000

$10,000,000

2026

$14,848,060

$7,424,030

$7,424,030

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

taxable value of the subject real property to be an amount less than $10,000,000 and requiring

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

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

See Attached.

Page 4

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

MTT Docket No. _________________

Page 4 of 4

Signature of Petitioner’s Authorized Representative or, if none, Petitioner:

Printed Name of Petitioner’s Authorized Representative or, if none, Petitioner:

Email Address:

Page 5

Canterbury Realty Holdings LLC v Charter

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

Canterbury Realty Holdings LLC

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

175 Route 70

Suite 300

City or Town

Toms River

State

New Jersey

ZIP Code

08755

Telephone Number

248-203-0767

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 Avenue

Suite 300

City or Town

Bloomfield Hills

State

Michigan

ZIP Code

48304

Telephone Number

2482030767

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

dfryer@dykema.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]

5601 Hatchery Road

Waterford

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48329

Taxing Authority (City or Township)

Township Of Waterford (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:

W-13-16-126-001

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:

17424030

Current Taxable Value as established by the Board of Review:

17424030

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

20000000

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

10000000

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

7424030

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/ /s/ Douglas J. Fryer

Payment Information

Amount: 600

Success: True

Message: ""

Waiver Code:

Transaction Number: 26052787097229

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.