Cvs Lake Norwood Inc, Petitioner Vs. City Of Grand Rapids, Respondent

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

CVS Lake Norwood Inc, 

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-002170

City Of Grand Rapids,

Respondent.

ORDER OF DISMISSAL

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

Petitioner has filed a Motion to Withdraw the Petition and the motion indicates that 

Petitioner informed Respondent of the motion and that Respondent concurs with the 

requested withdrawal. 

Therefore,

IT IS ORDERED that the case is DISMISSED.

This order resolves all pending issues and closes the case.

APPEAL RIGHTS

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

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

Appeals. 

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

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

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

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

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

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

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

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

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

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

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

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

arguments unless otherwise ordered by the Tribunal.

Page 2

MTT Docket No. 25-002170

Page 2 of 6

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

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

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

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

record on appeal. There is no certification fee. 

By:___________________________________

Patricia L. Halm, Tribunal Chair

Entered: February 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

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

CVS Lake Norwood Inc, 

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-002170

City Of Grand Rapids,

Respondent.

ORDER OF DISMISSAL

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

Petitioner has filed a Motion to Withdraw the Petition and the motion indicates that 

Petitioner informed Respondent of the motion and that Respondent concurs with the 

requested withdrawal. 

Therefore,

IT IS ORDERED that the case is DISMISSED.

This order resolves all pending issues and closes the case.

APPEAL RIGHTS

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

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

Appeals. 

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

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

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

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

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

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

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

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

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

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

electronic service, and proof demonstrating that service must be submitted

Page 4

MTT

Page 5

S

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEMS 

MICHIGAN TAX TRIBUNAL 

 

CVS LAKE NORWOOD, INC., 

 

) MOAHR Docket No.: 25-002170 

 

 

 

 

 

 

) 

 

 

 

 

 

 

 

 

Petitioner, 

 

 

) Parcel No.: 41-14-32-229-014 

 

 

) 

 

v. 

 

 

 

 

 

) 

 

 

) 

 

 

 

 

CITY OF GRAND RAPIDS, 

 

) 

 

 

) 

 

 

Respondent. 

 

) 

 

 

 

 

 

 

 

 

 

______________________________________________________________________________ 

 

Paul M. Jones, Jr. (P82235) 

Jones Pyatt Law, LLC 

435 East Main Street, Suite 220 

Greenwood, IN 46143 

(317) 991.1864 

paul@jonespyattlaw.com 

 

Elizabeth J. Fossel (P41430) 

 Dylan M. Gill (P89172) 

Grand Rapids Department of Law 

Attorneys for Respondent 

 300 Monroe Ave NW, Suite 620 

Grand Rapids, MI 49503 

(616) 456-4029 

efossel@grand-rapids.mi.us 

dgill@grand-rapids.mi.us 

 

 

PROOF OF SERVICE 

 

Mandy Jonte states that on February 19, 2026 she served by U.S. first-class mail and email, a 

copy of the Motion to Withdraw Appeal relative to the above-captioned matter to: 

Elizabeth J. Fossel (P41430) 

 Dylan M. Gill (P89172) 

Grand Rapids Department of Law 

Attorneys for Respondent 

 300 Monroe Ave NW, Suite 620 

Grand Rapids, MI 49503 

(616) 456-4029 

efossel@grand-rapids.mi.us 

dgill@grand-rapids.mi.us

Page 2

Mandy Jonte states that on February 19, 2026 she served by U.S. first-class mail, a copy of the 

Motion to Withdraw Appeal relative to the above-captioned matter to: 

 

Kent County 

Bureau of Equalization 

Attn: Equalization Director 

 300 Monroe Avenue NW 

 Grand Rapids, MI 49503-2288 

Kent County 

Attn: County Clerk 

 300 Monroe Avenue NW 

 Grand Rapids, MI 49503-2288 

Grand Rapids Public Schools 

Attn: BOE Secretary 

 1331 Martin Luther King Jr St, SE 

 Grand Rapids, MI 49506 

Michigan Department of Treasury 

State Treasurer 

430 W Allegan 

Lansing, MI 48922 

 

 

 

 

 

Dated: February 19, 2026 

 

 

 

 

/s/Mandy Jonte 

 

 

 

 

 

 

 

 

Mandy Jonte 

 

 

 

 

 

 

 

 

Paralegal 

 

 

 

 

 

 

 

 

Jones Pyatt Law, LLC

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Page 1

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

CVS Lake Nanunad Inc 

: 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

v 

MTT Docket No.25-002170-TT 

City of Grand Rapids 

Respondent(s) 

MOTION TO WITHDRAW APPEAL 

1. 

1 wish to withdraw my appeal in the above-captioned docket. 

2. 

Good cause exists to grant withdrawal because: 

Substantive reasons, including, but not limited to; the cost of litigation outweighs potential tax savings. 

3. 

l ask this Tribunal to grant my request to withdraw the appeal and dismiss the above- 

captioned docket. 

Please select one of the following: 

__ lam filing this Motion to Withdraw before Respondent filed an Answer or a responsive 

motion with the Tribunal. 

x_ 

1 am filing this Motion to Withdraw after Respondent has filed an Answer or Responsive 

Motion with the Tribunal. 

| attached to this Motion Respondent's written consent to withdraw my 

petition, or 

| shall grant Respondent the opportunity to object to this withdrawal. 

Pz 

Paul M. Jones, Jr. (P82235) 

Party/Representative (sign here) 

Print name of person signing 

| certify that on this date 

| served a copy of this Motion, and any additional documentation, on the 

opposing party or their representative. 

2/18/2026 

Pes 

Date 

(sign here) 

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

Page 2

Mandy Jonte 

From: 

Gill, Dylan <dgill@grand-rapids.mi.us> 

Sent: 

Tuesday, February 17, 2026 1:46 PM 

To: 

Paul Jones 

Cc: 

Post, Lindsey; Echeverria, Alma; Mandy Jonte 

Subject: 

RE: CVS LAKE NORWOOD INC. (25-002170) - Answer to Petition 

Good morning Paul, 

Respondent has no objection to the withdrawal. 

Thanks, 

Dylan M. Gill (she, her) » 

Assistant City Attorney 

City of Grand Rapids 

300 Monroe Ave NW 

Grand Rapids, MI 49503 

dgill@grand-rapids.mi.us 

(616)456-4028 

CONFIDENTIAL 

THIS DOCUMENT IS SUBJECT TO ATTORNEY-CLIENT PRIVILEGE 

DO NOT FORWARD WITHOUT PERMISSION 

From: Paul Jones <paul@jonespyattlaw.com> 

Sent: Tuesday, February 17, 2026 11:41 AM 

To: Echeverria, Alma <aecheverria@grand-rapids.mi.us> 

Cc: O'Connor, Kendall <koconnor@grand-rapids.mi.us>; Mandy Jonte <mandy@jonespyattlaw.com> 

Subject: RE: CVS LAKE NORWOOD INC. (25-002170) - Answer to Petition 

[Stop. Think. Read. This is an external email. Please use caution when 

clicking on the links and opening attachments 

in unsolicited email.] 

Counsel, good morning, we have been asked by our client, petitioner, to withdraw the above-referenced 

appeal pending at MTT. Is there any objection to our withdrawal? If not, we will proceed with drafting a 

voluntary dismissal and note no objection. If objection, please let me know. Thank you, Paul 

Paul M. Jones, Jr. 

Partner 

JONES PYATT LAW, LLC 

435 E. Main Street, Suite 220 

Greenwood, IN 46143 

mobile 317.223.5441 

office 317.991.1865

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Page 1

1 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

 

 

 

 

 

CVS LAKE NORWOOD, INC. 

 

 

 

 

 

 

 

 

 

Petitioner, 

 

 

 

 

Docket No. 25-002170 

v. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Parcel No. 41-14-32-229-014 

CITY OF GRAND RAPIDS, 

 

 

 

 

Respondent. 

___________________________________________________________________________ 

 

Paul M. Jones, Jr (P82235) 

Jones Pyatt Law, LLC 

Attorney for Petitioner 

435 E Main St, Ste. 200 

Greenwood, IN 46143 

paul@jonespyatttlaw.com 

 

Elizabeth J. Fossel (P41430) 

Dylan M. Gill (P89172) 

Grand Rapids Department of Law 

Attorneys for Respondent 

300 Monroe Ave NW, Suite 620 

Grand Rapids, MI 49503 

(616) 456-4029 

efossel@grand-rapids.mi.us 

dgill@grand-rapids.mi.us 

______________________________________________________________________________ 

 

APPEARANCE OF COUNSEL 

 

 

NOW COMES, Assistant City Attorney Dylan M. Gill and hereby enters appearance on 

behalf of Respondent City of Grand Rapids 

 

CITY OF GRAND RAPIDS, 

a Michigan municipal corporation 

 

 

Dated: February 17, 2026 

 

 

 

By: /s/ Dylan M. Gill 

 

 

 

 

 

 

 

 

 

 

 Dylan M. Gill (P89172) 

 Assistant City Attorney 

 Attorney for Respondent

Page 2

2 

 

PROOF OF SERVICE 

 

 

Alma Echeverria, being first duly sworn, deposes and says that she is a Paralegal in the 

Office of the City Attorney, attorneys for Respondent herein, and that on February 17, 2026 she 

served true and complete copies of Respondent’s Appearance of Counsel via email, upon: 

 

 

Paul M. Jones Jr. 

Jones Pyatt Law, LLC 

paul@jonespyattlaw.com 

 

 

 

 

 

 

 

 

 

 

/s/ Alma Echeverria 

 

 

 Alma Echeverria

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

NOTICE OF JANUARY 19 - 29, 2027 PREHEARING GENERAL CALL AND ORDER 

OF PROCEDURE

CVS Lake Norwood Inc,

Petitioner,

v

 

 

City Of Grand Rapids,

Respondent.

 MTT Docket No. 25-002170

Please be advised that 25-002170 has been placed on a two-week Prehearing General 

Call commencing January 19, 2027. Unless ordered otherwise, parties will be notified 

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

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

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

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

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

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

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

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

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

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

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

prevent its publication on the Tax Docket Lookup, the user MUST file a Motion for 

Protective Order under MCR 2.302(C)(8). If a Protective Order is issued, documents 

covered by the order will not be published. Documents filed prior to the issuance of a 

Protective Order will be published.

In accordance with MCR 1.109(D)(9) and TTR 209, the responsibility for excluding or 

redacting personal identifying information (PII) from all documents filed with or offered to 

the Tribunal rests solely with the parties and their attorneys. The Tribunal is not 

responsible for or required to review, redact, or screen documents at the time of filing 

for PII whether filed electronically or on paper. A party, representative, or interested 

person (i.e. third party not part of an appeal) may request that the Tribunal redact PII 

contained in a previously filed document by submitting a Request for Redactions. The 

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

of the Tribunal’s website. 

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

website for more information.

Page 2

MTT Docket No. 25-002170

Page 2 of 3

IT IS ORDERED that the parties shall:

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

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

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

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

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

by September 22, 2026. Valuation disclosures will not be admitted into evidence 

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

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

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

Statements by September 22, 2026. Witnesses, with the exception of rebuttal 

witnesses, will not be allowed to testify unless disclosed in the Prehearing Statement 

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

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

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

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

September 22, 2026, which means all discovery has been requested, all Motions to 

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

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

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

permitted during “Pre-Valuation Disclosure” discovery.

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

January 19, 2027, which means all discovery has been requested, all Motions to 

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

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

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

on the opposing party’s Prehearing Statement.

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

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

certain prehearing conference

Page 3

M

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

 

 

 

 

 

CVS LAKE NORWOOD, INC. 

 

 

 

 

 

 

 

 

 

Petitioner, 

 

 

 

 

Docket No. 25-002170 

v. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Parcel No. 41-14-32-229-014 

CITY OF GRAND RAPIDS, 

 

 

 

 

Respondent. 

___________________________________________________________________________ 

 

Paul M. Jones, Jr. 

Jones Pyatt Law, LLC 

Attorney for Petitioner 

435 E Main St, Ste. 220 

Greenwood, IN 46143 

paul@jonespyattlaw.com 

 

Elizabeth J. Fossel (P41430) 

Kendall R. O’Connor (P84036) 

Grand Rapids Department of Law 

Attorneys for Respondent 

300 Monroe Ave NW, Suite 620 

Grand Rapids, MI 49503 

(616) 456-4029 

efossel@grand-rapids.mi.us 

koconnor@grand-rapids.mi.us 

______________________________________________________________________________ 

RESPONDENT’S APPEARANCE AND ANSWER TO PETITION 

WITH PROOF OF SERVICE 

 

 

NOW COMES Elizabeth J. Fossel and Kendall R. O’Connor for the City of Grand Rapids, who 

hereby enters their Appearance of Counsel on behalf of Respondent City of Grand Rapids, and answers 

Petitioner’s Petition as follows: 

1. Property Parcel No: 41-14-32-229-014 

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

addressing all other parcels at issue.) 

 

ANSWER: Admitted. 

 

2. The property identified above is x real personal. 

 

ANSWER: Admitted. 

 

3. If more than one parcel of real property is under appeal, are the properties contiguous?

Page 2

__ Yes __ No. (If no, separate Petitions are required for each non-contiguous parcel.) 

 

ANSWER: There are no allegations in paragraph 3 of Petitioner’s Petition, and 

therefore no response is required. 

 

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.) 

 

ANSWER: There are no allegations in paragraph 4 of Petitioner’s Petition, and 

therefore no response is required. 

 

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

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

 

 

ANSWER: There are no allegations in paragraph 5 of Petitioner’s Petition, and 

therefore no response is required. 

 

6. The property identified above is classified as 201 Commercial- Improved. 

 

ANSWER: Respondent admits the property is classified as Commercial. 

 

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

Respondent’s March ____ July ___ December Board of Review. 

 

ANSWER: There are no allegations in paragraph 7 of Petitioner’s Petition, and therefore no 

response is required. 

 

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): 

 

 

ANSWER: There are no allegations in paragraph 8 of Petitioner’s Petition, and 

therefore no response is required. 

 

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

Page 3

the Tribunal’s authority over the assessment or assessments at issue (attach additional page 

if necessary): 

N/A 

 

ANSWER: There are no allegations in paragraph 9 of Petitioner’s Petition, and 

therefore no response is required. 

 

10. The property or properties at issue are located in Kent County. The property or properties’ 

address is: 

1528 SE Lake Dr, Grand Rapids, MI 49506 

 

ANSWER: Admitted. 

 

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

government unit): City of Grand Rapids 

 

ANSWER: Respondent admits the assessment at issue was established by the City of 

Grand Rapids. 

 

12. Petitioner’s legal residence or principal office address is: 

200 Highland Corp Dr MC 2315 

Cumberland, RI 02864 

 

ANSWER: Respondent lacks knowledge or information sufficient to form a belief as to the 

truth of this allegation, and leaves Petitioner to its proofs. 

 

13. This appeal involved issues relating to the (check all that are applicable); 

x 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 

 

ANSWER: Respondent neither admits nor denies the allegations in paragraph 13 of 

Petitioner’s Petition for the reason that Respondent lacks knowledge or sufficient information to

Page 4

15.

Page 5

Ta

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MOAHR DOCKET NO. 25-002170

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

City Of Grand Rapids (KENT)

Local Unit of Government/First Name

Kendall

M.I.

R.

Last Name

O'Connor

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

300 Monroe Ave NW

City or Town

Grand Rapids

State

Michigan

ZIP Code

49503

Telephone Number

616-456-4029

Fax Number

616-456-4569

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

cityattorney@grcity.us

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Kendall

M.I.

R.

Last Name

O'Connor

Firm Name (if any)

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

300 Monroe Avenue NW

Suite 620

City or Town

Grand Rapids

State

Michigan

ZIP Code

49503

Telephone Number

616-456-4029

Fax Number

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

cityattorney@grand-rapids.mi.us

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

Respondent or Authorized Attorney/Representative’s Signature: 

Kendall R. O'Connor

/s/

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEMS 

MICHIGAN TAX TRIBUNAL 

CVS LAKE NORWOOD INC, 

) MOAHR Docket No.: 25-002170 

) 

Petitioner, 

) Parcel No.: 41-14-32-229-014 

) 

v. 

) 

) 

CITY OF GRAND RAPIDS, 

) 

) 

Respondent. 

) 

Paul M. Jones, Jr. 

Jones Pyatt Law, LLC 

435 East Main Street, Suite 220 

Greenwood, IN 46143 

TEL: (317) 991-1864 

E-mail: paul@jonespyattlaw.com 

Attorney No.: P82235 

PROOF OF SERVICE FOR PROPERTY TAX PETITION 

Mandy Jonte states that on August 21 2025 she served by U.S. certified mail, return receipt 

requested, a copy of the foregoing documents relative to the above-captioned matter: Case 

Information Sheet, Entire Tribunal Property Tax Petition, Notice of Docket Number and Proof of 

Service to: 

City of Grand Rapids 

City of Grand Rapids 

Attn: Assessor 

Attn: City Clerk 

300 Monroe NW, 3 Floor 

300 Monroe Ave NW, 2" Floor 

Grand Rapids, MI 49503 

Grand Rapids, MI 49503

Page 2

Mandy Jonte states that on August 1% 2025 she served by U.S. first-class mail, a copy of the 

Petition relative to the above-captioned matter: Case Information Sheet, Entire Tribunal 

Property Tax Petition, Notice of Docket Number and Proof of Service to: 

Kent County 

Kent County 

Bureau of Equalization 

Attn: County Clerk 

Attn: Equalization Director 

300 Monroe Avenue NW 

300 Monroe Avenue NW 

Grand Rapids, MI 49503-2288 

Grand Rapids, MI 49503-2288 

Grand Rapids Public Schools 

Michigan Department of Treasury 

Attn: BOE Secretary 

State Treasurer 

1331 Martin Luther King Jr St, SE 

430 W Allegan St 

Grand Rapids, MI 49506 

Lansing, MI 48933-1592 

Dated: August id 2025 

/s/Mandy Jonte 

Mandy Jonte 

Paralegal 

Jones Pyatt Law, LLC 

435 E Main St, Suite 220 

Greenwood, IN 46143 

mandy @jonespyattlaw.com

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Page 1

STATE OF MICHIGAN 

 

GRETCHEN WHITMER 

GOVERNOR 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

LANSING 

MARLON I. BROWN, DPA 

DIRECTOR 

 

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

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

 

_____________________________, 

 

 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

 

v 

 

 

 

 

 

 

 

MTT Docket No. 

 

 

 

 

_____________________________, 

Respondent(s) 

 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

1. 

Property Parcel No: _____________________________________________ 

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

Form addressing all other parcels at issue.) 

 

2. 

The property identified above is ___real ___personal. 

 

3. 

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

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

contiguous parcel.) 

 

4. 

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

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

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

appeal.) 

 

5. 

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

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

 

 

 

 

 

6. 

The property identified above is classified as _________________________ 

 

7. 

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

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

 

 

 

 

CVS Lake Norwood, Inc.

CITY OF GRAND RAPIDS

41-14-32-229-014

x

201 Commercial-Improved

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: _______________________________________ 

 

 

 

 

 

 

Kent

1528 SE Lake Dr, Grand Rapids, MI 49506

City of Grand Rapids

200 Highland Corp Dr MC 2315

Cumberland, RI 02864

x

2025

Page 3

MTT Docket No. _________________ 

Page 3 of 4 

 

15. 

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

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

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

 

 

 

 

 

16. 

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

Board of Review are: 

 

Tax Year 

True Cash Value 

Assessed Value 

Taxable Value 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

17. 

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

 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

18. 

The values in dispute for the property identified above are: 

 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

19. 

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

 

 

 

 

 

 

20. 

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

relief requested (attach additional page if necessary): 

 

 

 

 

 

 

 

2025

3,531,200

1,756,600

1,369,097

2025

2,000,000

1,000,000

1,000,000

2025

1,531,200

756,600

369,097

Reduction of TCV, SEV and AV as indicated in paragraph 17.

Petitioner is a party-in-interest, i.e., Petitioner holds an interest in the parcel of property that is 

the subject of this appeal. 

Comparable sales and/or income capitalization analysis. Petitioner may obtain an appraisal 

for the purpose of this appeal.

Page 4

MTT

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

CVS Lake Norwood Inc, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-002170

City Of Grand Rapids, 

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 13, 2025

PROOF OF SERVICE

I certify that a copy of the foregoing was sent on the entry date indicated above to the 

parties or their attorneys or authorized representatives, if any, utilizing either the mailing 

or email addresses on file, as provided by those parties, attorneys, or authorized 

representatives.

By: Tribunal Clerk

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 

Petitioner(s) 

 

v 

 

 

 

 

 

 

 

MTT Docket No. 

 

 

 

 

_____________________________, 

Respondent(s) 

 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

1. 

Property Parcel No: _____________________________________________ 

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

Form addressing all other parcels at issue.) 

 

2. 

The property identified above is ___real ___personal. 

 

3. 

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

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

contiguous parcel.) 

 

4. 

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

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

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

appeal.) 

 

5. 

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

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

 

 

 

 

 

6. 

The property identified above is classified as _________________________ 

 

7. 

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

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

 

 

 

 

CVS Lake Norwood, Inc.

CITY OF GRAND RAPIDS

41-14-32-229-014

x

201 Commercial-Improved

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: _______________________________________ 

 

 

 

 

 

 

Kent

1528 SE Lake Dr, Grand Rapids, MI 49506

City of Grand Rapids

200 Highland Corp Dr MC 2315

Cumberland, RI 02864

x

2025

Page 3

MTT Docket No. _________________ 

Page 3 of 4 

 

15. 

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

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

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

 

 

 

 

 

16. 

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

Board of Review are: 

 

Tax Year 

True Cash Value 

Assessed Value 

Taxable Value 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

17. 

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

 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

18. 

The values in dispute for the property identified above are: 

 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

19. 

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

 

 

 

 

 

 

20. 

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

relief requested (attach additional page if necessary): 

 

 

 

 

 

 

 

2025

3,531,200

1,756,600

1,369,097

2025

2,000,000

1,000,000

1,000,000

2025

1,531,200

756,600

369,097

Reduction of TCV, SEV and AV as indicated in paragraph 17.

Petitioner is a party-in-interest, i.e., Petitioner holds an interest in the parcel of property that is 

the subject of this appeal. 

Comparable sales and/or income capitalization analysis. Petitioner may obtain an appraisal 

for the purpose of this appeal.

Page 4

MTT

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Entire Tribunal Case Information Sheet - Petitioner

MOAHR DOCKET NO. 

Section 1: Petitioner’s Contact Information

Filer type: Organization

First Name/Company Name

M.I.

Last Name

CVS Lake Norwood, Inc.,

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

200 Highland Corp Dr 

Suite 220

City or Town

Cumberland

State

Rhode Island

ZIP Code

02864

Telephone Number

317.991.1865

Fax Number

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

paul@jonespyattlaw.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Paul

M.I.

M

Last Name

Jones

Firm Name (if any)

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

435 East Main St.

Suite 220

City or Town

Greenwood

State

Indiana

ZIP Code

46143

Telephone Number

317-223-5441

Fax Number

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

paul@jonespyattlaw.com

Section 5: Issue

Please designate one: 

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

Section 6: Subject Property Information

How many parcels are you 

appealing?1

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

1528 SE Lake Dr

Grand Rapids

Michigan

49506

Taxing Authority (City or Township)

City Of Grand Rapids (KENT)

County

Kent

If you are appealing more than one parcel, are they contiguous or adjoining? 

(*If no, you must file separate appeals for each non-contiguous or non-adjoining parcel.)

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

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

True Cash and Taxable Values

Section 8: Valuation Information for Each Parcel under Appeal

Parcel Number:

41-14-32-229-014

Classification of Property: Real 

Commercial

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

1756600

Current Taxable Value as established by the Board of Review:

1369097

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

2000000

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

1000000

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

Section 9: Assessment Information

Type of Tax Assessment(s):

Assessment Number(s):

Check all that is being appealed: 

Check what action prompted this appeal:

If “other,” please explain:

Section 10: Special Assessment Information

Type of Special Assessment:

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

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

If No, please explain:

Section 11: Classification Information

Parcel Number:

Current Classification of Property as established by Board of Review: 

What do you believe is the property’s classification?

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

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

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

Fee Information

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

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

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

 

 $100,000.00 and under $250.00

 $100,000.01 to $500,000.00 $400.00

 $Over $500,000.00 $600.00

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

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

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

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

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

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

Petitioner or Attorney/Authorized Representative’s Signature: 

/s/ Paul M Jones, Jr

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