Civic Plaza Associates, LLC, Arbor Town II, LLC, & 20300 Civic Center Dr, LLC Petitioner Vs. City Of Southfield Respondent
- Petitioner
- Civic Plaza Associates, LLC, Arbor Town II, LLC, & 20300 Civic Center Dr, LLC
- Respondent
- City Of Southfield
Case overview
- Docket number
- 26-001279-TT
- Status
- Ready Schedule
- CaseType
- ET Property
- Division
- ET
- County
- Oakland
- Judge
- No judge assigned
Docket history
| Line # | Subject | Filer | Line Ref | Enter Date/Post Mark | Fee | Related Item |
|---|---|---|---|---|---|---|
| 5 | Answer was received | RESP | Not recorded | 09/09/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 4 | Proof of service of petition was received. | PET | Not recorded | 08/13/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 3 | Petition has been verified | PET | 1 | 08/06/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 2 | Notice of Docket Number ET | Not recorded | Not recorded | 08/06/2026 | Not recorded | Download |
| 1 | A petition was received. | PET | Not recorded | 05/22/2026 | $675.00 | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
Documents
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Page 1
STATE OF MICHIGAN DEPARTMENTOF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL CIVIC PLAZA ASSOCIATES, LLC, ARBOR TOWN II, LLC and 20300 CIVIC CENTER DR., LLC Petitioner, v CITY OF SOUTHFIELD, Respondent. MTT Docket No. 26-001279 _____________________________________________________________________________/ JEROME P. PESICK (P29039) JASON C. LONG (P59244) WILLIAMS, WILLIAMS, RATTNER & PLUNKETT, P.C. Attorneys for Petitioner 380 N. Old Woodward Avenue, Suite 300 Birmingham, MI 48009 (248) 642-0333 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: The Parties 1. Respondent lacks knowledge or information regarding the truth of the allegations contained in Paragraph 1 and, therefore, leaves Petitioner to its proofs. 2. Respondent admits the allegations in Paragraph 2. The Subject Property
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2 3. Respondent lacks knowledge or information regarding the truth of the allegations contained in Paragraph 3 and, therefore, leaves Petitioner to its proofs. 4. Respondent admits the allegations in Paragraph 4. 5. Respondent admits the allegations in Paragraph 5. The 2026 Assessment 6. Respondent admits the allegations in Paragraph 6. 7. Respondent denies the allegations in Paragraph 7 as to the taxable value only of Parcel No.76-24-22-276-020 as the taxable value on the rolls is $2,876,167 not $2,876,157. As to the remaining allegations in Paragraph 7, Respondent admits the allegations contained therein. 8. Respondent acknowledges Petitioner’s contention of value but denies that it reflects the property’s fair market value as of December 31, 2025. In further answer, the assessed, state equalized and/or taxable values do not exceed permitted amounts, do not exceed the percentage of true cash value permitted by law, were correctly determined and are based upon correct application of proper principles, and the values and Respondent’s mode of assessment are non-discriminatory and constitutional. 9. Respondent acknowledges Petitioner’s belief as to a dispute in the subject property’s valuation but denies Petitioner’s contentions of value have merit and further denies Petitioner is entitled to relief. In further answer, the assessed, state equalized and/or taxable values do not exceed permitted amounts, do not exceed the percentage of true cash value permitted by law, were correctly determined and are based upon correct application of proper principles, and the values and Respondent’s mode of assessment are non-discriminatory and constitutional. 10. Respondent acknowledges the issues raised by Petitioner but denies that those issues have merit and denies Petitioner is entitled to relief. Respondent admits there is no issue relative to an addition or loss but denies Petitioner has a right to raise any additional claims at a later date. 11. Respondent denies the allegations in Paragraph 11, including subparagraphs (a)- (d), for the reason that the same are untrue. In further answer, the assessed, state equalized and/or taxable values do not exceed permitted amounts, do not exceed the percentage of true cash value permitted by law, were correctly determined and are based upon correct application of proper principles, and the values and Respondent’s mode of assessment are non-discriminatory and constitutional. 12. Respondent admits the subject property’s assessment is uniform but denies it overestimated the subject property’s value. Conclusion and Request for Relief
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3 13. Respondent acknowledges the relief requested by Petitioner in the final paragraph of its Petition but denies that Petitioner is entitled to said relief for the reasons set forth above. 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/Laura M. Hallahan______________ 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 9, 2026 (248) 731-3089 AFFIRMATIVE DEFENSES Respondent, City of Southfield, asserts the following affirmative defenses: 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. The Tribunal is charged with finding a property’s true cash value to determine the property’s lawful assessment. Alhi Development Co v Orion Twp, 110 Mich App 764, 767 (1981). 3. Petitioner has the burden of establishing the property’s true cash value. See MCL 205.737(3) and Kern v Pontiac Twp, 93 Mich App 612 (1974). 4. Petitioner has failed to allege specific and sufficient facts to establish fraud, error of law, discrimination, application of wrong principles, or illegality on the part of Respondent or its agents.
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4 5. Petitioner has failed to allege that the mode and method of assessing the subject property fails to conform to the mode and method applied in the case of all other properties in Respondent’s taxing unit for the year in question. 6. Petitioner has failed to show that any factor other than fifty percent (50%) was applied to the true cash value of Petitioner’s property, as well as all others, to arrive at the respective assessments appearing on the roll, and also fails to
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR Entire Tribunal Case Information Sheet - Respondent MTT DOCKET NO. 26-001279 Section 1: Respondent’s Contact Information Filer Type: Local Unit of Government Local Unit of Government City Of Southfield (OAKLAND) First Name M.I. Last Name Home Address (No., Street, P.O. Box or Rural Route) City or Town State ZIP Code Telephone 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 Halahan Firm Name (if any) Hallahan & Associates PC Address (No., Street, P.O. Box or Rural Route) 1750 S. Telegraph Road Suite 202 City or Town Bloomfield Hills State Michigan ZIP Code 48302-2073 Telephone Number 2487313090 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) lhallahan@hallahanlaw.com Electronic Signature *Typing your name below will serve as your signature Respondent or Authorized Attorney/Representative’s Signature: Laura M. Hallahan /s/
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Civic Plaza Associates, LLC, Docket No. 26-001279 Arbor Town II, LLC, and Parcel Nos. 76-24-22-276-020 20300 Civic Center Dr., LLC, 76-CF-22-100-001 76-24-22-276-019 Petitioners, 76-24-22-276-021 v. City of Southfield, Respondent. Jerome P. Pesick (P29039) Jason C. Long (P59244) WILLIAMS, WILLIAMS, RATTNER & PLUNKETT, PC 380 N. Old Woodward Ave., Ste. 300 Birmingham, MI 48009 (248) 642-0333 Attorneys for Petitioners Proof of Service of Petition and Notice of Docket Number
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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, the Notice of Docket Number, and this Proof of Service, on the persons listed below, by the means identified below, by placing those documents in duly stamped, addressed envelopes, and placing the envelopes in the United States mail on August 13, 2026. PERSONS SERVED: Certified Mail First Class Mail Clerk Clerk Secretary of School Board City of Southfield Oakland County Southfield Public Schools 26000 Evergreen Road 1200 N Telegraph 24661 Lahser Rd P.O. Box 2055 Building #12E Southfield MI 48033 Southfield, MI 48037-2055 Pontiac MI 48341 Assessor Director of Equalization State Treasurer City of Southfield Oakland County Michigan Department of Treasury 26000 Evergreen Road 250 Elizabeth Lake Rd Austin Building P.O. Box 2055 Suite 1000W 430 W. Allegan Southfield, MI 48037-2055 Pontiac, MI 48341 Lansing, MI 48922 Inga (Mig) Monica Athanas
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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: 26-001279 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: POS - Petition - Arbor Lofts Fee Information Filing Fee: $ 0.00 Payment Information Payment: $ 0.00
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Petition Page 1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Civic Plaza Associates, LLC, Docket No. 26- Arbor Town II, LLC, and Parcel Nos. 76-24-22-276-020 20300 Civic Center Dr., LLC, 76-CF-22-100-001 76-24-22-276-019 Petitioners, 76-24-22-276-021 v. City of Southfield, Respondent. Jerome P. Pesick (P29039) Jason C. Long (P59244) WILLIAMS, WILLIAMS, RATTNER & PLUNKETT, PC 380 N. Old Woodward Ave., Ste. 300 Birmingham, MI 48009 (248) 642-0333 Attorneys for Petitioners Entire Tribunal Property Tax Petition Petitioners Civic Plaza Associates, LLC, Arbor Town II, LLC and 20300 Civic Center Dr., LLC, by and through their attorneys, Williams Williams Rattner & Plunkett, PC, state as follows for their Entire Tribunal Property Tax Petition. The Parties 1. Petitioners Civic Plaza Associates, LLC, Arbor Town II, LLC and 20300 Civic Center Dr., LLC (collectively, “Petitioners”) are Michigan limited liability companies with their registered office located at 480 Pierce St Ste 200, Birmingham,
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Petition Page 2 MI 48009. Petitioners are related entities that have the same principal ownership. 2. Respondent City of Southfield is a Michigan city with its primary offices located at 26000 Evergreen Road, Southfield, MI 48076. The Subject Properties 3. Petitioners own properties identified as follows: Parcel No. Street Address 76-24-22-276-020 20300 Civic Center Drive 76-CF-22-100-001 20300 Civic Center Drive 76-24-22-276-019 20300 Civic Center Drive 76-24-22-276-021 Civic Center Drive They are referred to collectively in this Petition as the “Subject Properties.” 4. The Subject Properties are located in Oakland County and are within the Southfield Public School District. 5. Respondent possesses jurisdiction to assess and collect property taxes for the Subject Properties. The 2026 Assessments 6. For the 2026 tax year, Respondent classified the Subject Properties as commercial real property. 7. For the 2026 tax year, Respondent established the Subject Properties’ assessments for property taxes in the amounts set forth in paragraph 1 of the attached Multiple Parcel Form. 8. Petitioners contend that lawful assessments of the Subject Properties for the 2026 tax year cannot exceed the amounts set forth in paragraph 2 of the attached Multiple Parcel Form.
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Petition Page 3 9. The amounts in dispute therefore equal the amounts identified in paragraph 3 of the attached Multiple Parcel Form. 10. This Petition presents issues involving the Subject Properties’ valuation for assessment purposes. Petitioners do 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 reserve their right to assert issues involving losses should information supporting such issues become available. 11. The Subject Properties’ 2026 assessments (a) violate the Michigan Constitution, the GPTA, and other Michigan law, (b) are based on erroneous principles and information, (c) are based on the misapplication of valuation principles, and (d) otherwise violate Petitioners’ rights. 12. Petitioners do not assert that the Subject Properties’ 2026 assessments are not uniform aside from the lack of uniformity resulting from Respondent overestimating the Subject Properties’ values. Conclusion and Request for Relief WHEREFORE, Petitioners respectfully request that this honorable Tribunal enter judgment revising the Subject Properties’ 2026 assessments to amounts that do not exceed Petitioners’ contentions of value set forth in paragraph 2 of the attached Multiple Parcel Form and granting Petitioners all other relief to which they are entitled under Michigan law.
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Petition Page 4 Respectfully Submitted, WILLIAMS WILLIAMS RATTNER & PLUNKETT PC By: /s/ Jerome P. Pesick Jerome P. Pesick (P29039) Jason C. Long (P59244) Dated: May 22, 2026 Attorneys for Petitioners
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Multiple Parcel Form Page 1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Civic Plaza Associates, LLC, Docket No. 26- Arbor Town II, LLC, and Parcel Nos. 76-24-22-276-020 20300 Civic Center Dr., LLC, 76-CF-22-100-001 76-24-22-276-019 Petitioners, 76-24-22-276-021 v. City of Southfield, Respondent. Jerome P. Pesick (P29039) Jason C. Long (P59244) WILLIAMS, WILLIAMS, RATTNER & PLUNKETT, PC 380 N. Old Woodward Ave., Ste. 300 Birmingham, MI 48009 (248) 642-0333 Attorneys for Petitioners Entire Tribunal Petition Multiple Parcel Form 1. The values established for the Subject Properties by Respondent’s March 2026 Board of Review are as follows: Parcel No. True Cash Value Assessed Value Taxable Value 76-24-22-276-020 6,703,960 3,351,980 2,876,157 76-CF-22-100-001 473,940 236,970 169,685 76-24-22-276-019 337,600 168,800 164,678 76-24-22-276-021 208,340 104,170 44,540 Totals: 7,723,840 3,861,920 3,255,060
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Multiple Parcel Form Page 2 2. Petitioners contend that lawful 2026 assessments for the Subject Properties cannot exceed the following amounts: Parcel No. True Cash Value Assessed Value Taxable Value 76-24-22-276-020 4,340,000 2,170,000 2,170,000 76-CF-22-100-001 330,000 165,000 165,000 76-24-22-276-019 250,000 125,000 125,000 76-24-22-276-021 80,000 40,000 40,000 Totals: 5,000,000 2,500,000 2,500,000 3. The amounts in dispute for the 2026 tax year are therefore as follows: Parcel No. True Cash Value Assessed Value Taxable Value 76-24-22-276-020
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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 Civic Plaza Associates, LLC, Arbor Town II, LLC, & 20300 Civic Center Dr, LLC Home Address (No., Street, P.O. Box or Rural Route) 480 Pierce St Ste 200 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 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? 4 Property Address (No., Street, City, ST, ZIP) [If multiple, list first property’s address] 20300 Civic Center Drive
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR 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.) Yes 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: 76-24-22-276-020 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: 3351980 Current Taxable Value as established by the Board of Review: 2876157 What do you believe is the fair market value (also known as True Cash Value)? 4340000 Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value). 2170000 If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value. 2170000 Section 6: Valuation Information for Each Parcel under Appeal Parcel Number: 76-CF-22-100-001 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: 236970
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR Current Taxable Value as established by the Board of Review: 169685 What do you believe is the fair market value (also known as True Cash Value)? 330000 Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value). 165000 If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value. 165000 Section 6: Valuation Information for Each Parcel under Appeal Parcel Number: 76-24-22-276-019 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: 168800 Current Taxable Value as established by the Board of Review: 164678 What do you believe is the fair market value (also known as True Cash Value)? 250000 Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value). 125000 If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value. 125000 Section 6: Valuation Information for Each Parcel under Appeal Parcel Number: 76-24-22-276-021 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: 104170 Current Taxable Value as established by the Board of Review: 44540 What do you believe is the fair market value (also known as True Cash Value)? 80000 Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value). 40000 If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value. 40000
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR 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
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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 Civic Plaza Associates, LLC, Arbor Town II, LLC, & 20300 Civic Center Dr, LLC, Petitioner, MICHIGAN TAX TRIBUNAL v MTT Docket No.: 26-001279 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 6, 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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Petition Page 1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Civic Plaza Associates, LLC, Docket No. 26- Arbor Town II, LLC, and Parcel Nos. 76-24-22-276-020 20300 Civic Center Dr., LLC, 76-CF-22-100-001 76-24-22-276-019 Petitioners, 76-24-22-276-021 v. City of Southfield, Respondent. Jerome P. Pesick (P29039) Jason C. Long (P59244) WILLIAMS, WILLIAMS, RATTNER & PLUNKETT, PC 380 N. Old Woodward Ave., Ste. 300 Birmingham, MI 48009 (248) 642-0333 Attorneys for Petitioners Entire Tribunal Property Tax Petition Petitioners Civic Plaza Associates, LLC, Arbor Town II, LLC and 20300 Civic Center Dr., LLC, by and through their attorneys, Williams Williams Rattner & Plunkett, PC, state as follows for their Entire Tribunal Property Tax Petition. The Parties 1. Petitioners Civic Plaza Associates, LLC, Arbor Town II, LLC and 20300 Civic Center Dr., LLC (collectively, “Petitioners”) are Michigan limited liability companies with their registered office located at 480 Pierce St Ste 200, Birmingham,
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Petition Page 2 MI 48009. Petitioners are related entities that have the same principal ownership. 2. Respondent City of Southfield is a Michigan city with its primary offices located at 26000 Evergreen Road, Southfield, MI 48076. The Subject Properties 3. Petitioners own properties identified as follows: Parcel No. Street Address 76-24-22-276-020 20300 Civic Center Drive 76-CF-22-100-001 20300 Civic Center Drive 76-24-22-276-019 20300 Civic Center Drive 76-24-22-276-021 Civic Center Drive They are referred to collectively in this Petition as the “Subject Properties.” 4. The Subject Properties are located in Oakland County and are within the Southfield Public School District. 5. Respondent possesses jurisdiction to assess and collect property taxes for the Subject Properties. The 2026 Assessments 6. For the 2026 tax year, Respondent classified the Subject Properties as commercial real property. 7. For the 2026 tax year, Respondent established the Subject Properties’ assessments for property taxes in the amounts set forth in paragraph 1 of the attached Multiple Parcel Form. 8. Petitioners contend that lawful assessments of the Subject Properties for the 2026 tax year cannot exceed the amounts set forth in paragraph 2 of the attached Multiple Parcel Form.
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Petition Page 3 9. The amounts in dispute therefore equal the amounts identified in paragraph 3 of the attached Multiple Parcel Form. 10. This Petition presents issues involving the Subject Properties’ valuation for assessment purposes. Petitioners do 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 reserve their right to assert issues involving losses should information supporting such issues become available. 11. The Subject Properties’ 2026 assessments (a) violate the Michigan Constitution, the GPTA, and other Michigan law, (b) are based on erroneous principles and information, (c) are based on the misapplication of valuation principles, and (d) otherwise violate Petitioners’ rights. 12. Petitioners do not assert that the Subject Properties’ 2026 assessments are not uniform aside from the lack of uniformity resulting from Respondent overestimating the Subject Properties’ values. Conclusion and Request for Relief WHEREFORE, Petitioners respectfully request that this honorable Tribunal enter judgment revising the Subject Properties’ 2026 assessments to amounts that do not exceed Petitioners’ contentions of value set forth in paragraph 2 of the attached Multiple Parcel Form and granting Petitioners all other relief to which they are entitled under Michigan law.
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Petition Page 4 Respectfully Submitted, WILLIAMS WILLIAMS RATTNER & PLUNKETT PC By: /s/ Jerome P. Pesick Jerome P. Pesick (P29039) Jason C. Long (P59244) Dated: May 22, 2026 Attorneys for Petitioners
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Multiple Parcel Form Page 1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Civic Plaza Associates, LLC, Docket No. 26- Arbor Town II, LLC, and Parcel Nos. 76-24-22-276-020 20300 Civic Center Dr., LLC, 76-CF-22-100-001 76-24-22-276-019 Petitioners, 76-24-22-276-021 v. City of Southfield, Respondent. Jerome P. Pesick (P29039) Jason C. Long (P59244) WILLIAMS, WILLIAMS, RATTNER & PLUNKETT, PC 380 N. Old Woodward Ave., Ste. 300 Birmingham, MI 48009 (248) 642-0333 Attorneys for Petitioners Entire Tribunal Petition Multiple Parcel Form 1. The values established for the Subject Properties by Respondent’s March 2026 Board of Review are as follows: Parcel No. True Cash Value Assessed Value Taxable Value 76-24-22-276-020 6,703,960 3,351,980 2,876,157 76-CF-22-100-001 473,940 236,970 169,685 76-24-22-276-019 337,600 168,800 164,678 76-24-22-276-021 208,340 104,170 44,540 Totals: 7,723,840 3,861,920 3,255,060
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Multiple Parcel Form Page 2 2. Petitioners contend that lawful 2026 assessments for the Subject Properties cannot exceed the following amounts: Parcel No. True Cash Value Assessed Value Taxable Value 76-24-22-276-020 4,340,000 2,170,000 2,170,000 76-CF-22-100-001 330,000 165,000 165,000 76-24-22-276-019 250,000 125,000 125,000 76-24-22-276-021 80,000 40,000 40,000 Totals: 5,000,000 2,500,000 2,500,000 3. The amounts in dispute for the 2026 tax year are therefore as follows: Parcel No. True Cash Value Assessed Value Taxable Value 76-24-22-276-020
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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 Civic Plaza Associates, LLC, Arbor Town II, LLC, & 20300 Civic Center Dr, LLC Home Address (No., Street, P.O. Box or Rural Route) 480 Pierce St Ste 200 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 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? 4 Property Address (No., Street, City, ST, ZIP) [If multiple, list first property’s address] 20300 Civic Center Drive
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR 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.) Yes 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: 76-24-22-276-020 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: 3351980 Current Taxable Value as established by the Board of Review: 2876157 What do you believe is the fair market value (also known as True Cash Value)? 4340000 Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value). 2170000 If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value. 2170000 Section 6: Valuation Information for Each Parcel under Appeal Parcel Number: 76-CF-22-100-001 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: 236970
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR Current Taxable Value as established by the Board of Review: 169685 What do you believe is the fair market value (also known as True Cash Value)? 330000 Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value). 165000 If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value. 165000 Section 6: Valuation Information for Each Parcel under Appeal Parcel Number: 76-24-22-276-019 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: 168800 Current Taxable Value as established by the Board of Review: 164678 What do you believe is the fair market value (also known as True Cash Value)? 250000 Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value). 125000 If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value. 125000 Section 6: Valuation Information for Each Parcel under Appeal Parcel Number: 76-24-22-276-021 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: 104170 Current Taxable Value as established by the Board of Review: 44540 What do you believe is the fair market value (also known as True Cash Value)? 80000 Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value). 40000 If you belive the Taxable Value differs from your contention of Assessed Value, enter your contention of Taxable Value. 40000
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING MARLON I. BROWN, DPA DIRECTOR 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
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