Eberspaecher North America, Petitioner Vs. City Of Novi, 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 

Eberspaecher North America, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 25-001907 

 

City of Novi, 

 

Presiding Judge 

Respondent. 

 

Marcus L. Abood 

 

 

ORDER GRANTING JOINT STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

 

CONSENT JUDGMENT 

 

The Tribunal has reviewed the Stipulation and finds that it comports with the mandates 

of State law.1 As a result, the Tribunal shall enter the parties’ Stipulation. Therefore, 

 

IT IS ORDERED that the Joint Stipulation for Entry of Consent Judgment including all 

attachments, terms and conditions is GRANTED and ADOPTED, unless otherwise 

indicated. 

 

IT IS FURTHER ORDERED that the officer charged with maintaining the assessment 

rolls for the tax years at issue shall correct or cause the assessment rolls to be 

corrected to reflect the property’s true cash and taxable values as provided in this 

Consent Judgment within 20 days of the entry of the Consent Judgment.2 

 

IT IS FURTHER ORDERED that the officer charged with collecting or refunding the 

affected taxes shall collect taxes and any applicable interest or issue a refund as 

required by the Consent Judgment within 28 days of the entry of the Consent 

Judgment. If a refund is warranted, it shall, unless otherwise indicated, include a 

proportionate share of any property tax administration fees paid and of penalty and 

interest paid on delinquent taxes. The refund shall also, unless otherwise indicated, 

separately indicate the amount of the taxes, fees, penalties, and interest being 

refunded. A sum determined by the Tribunal to have been unlawfully paid shall, unless 

otherwise indicated, bear interest from the date of payment to the date of judgment and 

the judgment shall bear interest to the date of its payment. A sum determined by the 

Tribunal to have been underpaid shall not bear interest for any time period prior to 28 

days after the issuance of this Consent Judgment. Pursuant to MCL 205.737, interest 

shall accrue (i) after December 31, 2013, through June 30, 2016, at the rate of 4.25%, 

(ii) after June 30, 2016, through December 31, 2016, at the rate of 4.40%, (iii) after 

December 31, 2016, through June 30, 2017, at the rate of 4.50%, (iv) after June 30, 

 

1 See MCL 211.27a. 

2 See MCL 205.755.

Page 2

MTT Docket No. 25-001907 

Page 2 of 2 

 

2017, through December 31, 2017, at the rate of 4.70%, (v) after December 31, 2017, 

through June 30, 2018, at the rate of 5.15%, (vi) after June 30, 2018, through December 

31, 2018, at the rate of 5.41%, (vii) after December 31, 2018, through June 30, 2019, at 

the rate of 5.9%, (viii) after June 30, 2019, through December 31, 2019, at the rate of 

6.39%, (ix) after December 31, 2019, through June 30, 2020, at the rate of 6.40%, (x) 

after June 30 2020, through December 31, 2020, at the rate of 5.63%, (xi) after 

December 31, 2020, through June 30, 2022, at the rate of 4.25%, (xii) after June 30, 

2022, through December 31, 2022, at the rate of 4.27%, (xiii) after December 31, 2022, 

through June 30, 2023, at the rate of 5.65%, (xiv) after June 30, 2023, through 

December 31, 2023, at the rate of 8.25%, (xv) after December 31, 2023, through June 

30, 2024, at the rate of 9.30%, (xvi) after June 30, 2024, through December 31, 2024, at 

the rate of 9.50%, (xvii) after December 31, 2024, through June 30, 2025, at the rate of 

9.47%, (xviii) after June 30, 2025, through December 31, 2025, at the rate of 8.66%, 

and (xix) after December 31, 2025, through June 30, 2026, at a rate of 8.48%. 

 

This Consent Judgment resolves all pending claims in this matter and closes this case. 

 

See docket look up for a copy of stipulation and for any possible refund paragraph. 

 

 

 

 

 

 

 

 

By

 

 

Entered: December 2, 2025 

am 

 

PROOF OF SERVICE 

 

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

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

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

representatives. 

 

By: Tribunal Clerk

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER 

GOVERNOR 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

LANSING

MARLON I. BROWN, DPA 

DIRECTOR 

 

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

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

_____________________________, 

 

 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

 

v 

 

MTT Docket No. 

 

 

 

 

_____________________________, 

Respondent(s) 

 

STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

(VALUATION) 

 

1. The subject property is in _________________________________ County. 

 

2. Parcel Number: ____________________________________________. 

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

Form addressing all other parcels at issue.) 

 

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

of Review are: 

 

Tax year 

Assessed Value (AV) 

Taxable Value (TV) 

 

 

 

 

 

 

 

4. The values for the property identified above as stipulated by the parties for 

settlement purposes are: 

 

Tax year 

True Cash Value 

AV 

TV 

 

 

 

 

 

 

 

 

 

5. If the stipulated TV does not equal the prior year TV multiplied by the applicable 

inflation rate multiplier, explain why (e.g., transfer of ownership, additions, losses, 

omitted property etc.) 

___________________________________________________________________

___________________________________________________________________

___________________________________________________________________

___________________________________________________________________ 

 

6. List any special terms or conditions being proposed by the parties that would affect 

the execution of a Consent Judgment including, but not limited to, the joint payment 

of the refund, the waiver of interest, etc. (attach additional page if necessary): 

___________________________________________________________________

EBERSPAECHER NORTH AMERICA

25-001907

CITY OF NOVI

OAKLAND

50-22-12-200-018

2025

3,870,760

2,608,470

2025

4,950,400 

2,475,200

2,475,200

N/A

Petitioner agrees to waive the interest if refunds are paid within 60 days of the Consent Judgment.

SSM

Page 2

MTT Docket No. ___________ 

Page 2 of 2 

 

___________________________________________________________________

___________________________________________________________________

___________________________________________________________________ 

 

NOTE: The Stipulation MUST include ALL parcels and ALL tax years included in the 

appeal (including subsequent tax years on or after April 1 of each year for appeals 

pending in the Small Claims Division). The parties may agree, however, to withdraw the 

appeal of specific parcels and/or tax year(s). 

 

IF APPLICABLE, complete the following section(s). Otherwise, LEAVE BLANK. 

 

7. The parties agree to the withdrawal of parcel number: 

__________________________________________. 

(If more than one parcel is being withdrawn, attach a separate page addressing 

all other parcels being withdrawn.) 

 

8. The parties agree to the withdrawal of tax year(s) ____________________. 

 

 

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

 

__________________________________________________________________ 

 

Printed Name:_______________________________________________________ 

 

Date: ______________________________________________________________ 

 

Signature of Respondent’s authorized representative: 

 

__________________________________________________________________ 

 

Printed Name:_______________________________________________________ 

 

Date: ______________________________________________________________ 

 

25-001907

Respondent has 60 days from the entry of the Consent Judgment to pay any refunds due. 

Please mail all refunds to Eberspaecher North America (c/o Ryan, LLC - Attn: Mark McMerrell) 

600 Superior Avenue E., Suite 1810, Cleveland, OH 44114

/s/ Mark T. McMerrell

Mark T. McMerrell (Ryan, LLC - Petitioner's Authorized Agent)

November 11, 2025

/s/ Stephanie S. Morita

Stephanie S. Morita

December 1, 2025

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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) 

 

STIPULATION FOR ENTRY OF CONSENT JUDGMENT 

(VALUATION) 

 

1. The subject property is in _________________________________ County. 

 

2. Parcel Number: ____________________________________________. 

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

Form addressing all other parcels at issue.) 

 

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

of Review are: 

 

Tax year 

Assessed Value (AV) 

Taxable Value (TV) 

 

 

 

 

 

 

 

4. The values for the property identified above as stipulated by the parties for 

settlement purposes are: 

 

Tax year 

True Cash Value 

AV 

TV 

 

 

 

 

 

 

 

 

 

5. If the stipulated TV does not equal the prior year TV multiplied by the applicable 

inflation rate multiplier, explain why (e.g., transfer of ownership, additions, losses, 

omitted property etc.) 

___________________________________________________________________

___________________________________________________________________

___________________________________________________________________

___________________________________________________________________ 

 

6. List any special terms or conditions being proposed by the parties that would affect 

the execution of a Consent Judgment including, but not limited to, the joint payment 

of the refund, the waiver of interest, etc. (attach additional page if necessary): 

___________________________________________________________________

EBERSPAECHER NORTH AMERICA

25-001907

CITY OF NOVI

OAKLAND

50-22-12-200-018

2025

3,870,760

2,608,470

2025

4,950,400 

2,475,200

2,475,200

N/A

Petitioner agrees to waive the interest if refunds are paid within 60 days of the Consent Judgment.

SSM

Page 2

MTT Docket No. ___________ 

Page 2 of 2 

 

___________________________________________________________________

___________________________________________________________________

___________________________________________________________________ 

 

NOTE: The Stipulation MUST include ALL parcels and ALL tax years included in the 

appeal (including subsequent tax years on or after April 1 of each year for appeals 

pending in the Small Claims Division). The parties may agree, however, to withdraw the 

appeal of specific parcels and/or tax year(s). 

 

IF APPLICABLE, complete the following section(s). Otherwise, LEAVE BLANK. 

 

7. The parties agree to the withdrawal of parcel number: 

__________________________________________. 

(If more than one parcel is being withdrawn, attach a separate page addressing 

all other parcels being withdrawn.) 

 

8. The parties agree to the withdrawal of tax year(s) ____________________. 

 

 

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

 

__________________________________________________________________ 

 

Printed Name:_______________________________________________________ 

 

Date: ______________________________________________________________ 

 

Signature of Respondent’s authorized representative: 

 

__________________________________________________________________ 

 

Printed Name:_______________________________________________________ 

 

Date: ______________________________________________________________ 

 

25-001907

Respondent has 60 days from the entry of the Consent Judgment to pay any refunds due. 

Please mail all refunds to Eberspaecher North America (c/o Ryan, LLC - Attn: Mark McMerrell) 

600 Superior Avenue E., Suite 1810, Cleveland, OH 44114

/s/ Mark T. McMerrell

Mark T. McMerrell (Ryan, LLC - Petitioner's Authorized Agent)

November 11, 2025

/s/ Stephanie S. Morita

Stephanie S. Morita

December 1, 2025

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

EBERSPAECHER NORTH AMERICA, 

 

 

Petitioner, 

 

 

MTT Docket No. 25-001907 

v. 

 

CITY OF NOVI, 

 

 

Respondent. 

 

RYAN, LLC 

Mark McMerrell 

Representative for Petitioner 

600 Superior Avenue E 

Suite 1810 

Cleveland, OH 44114 

(216) 685-9448 

mark.mcmerrell@ryan.com 

ROSATI, SCHULTZ, JOPPICH 

 & AMTSBUECHLER, P.C. 

Stephanie Simon Morita (P53864) 

Matthew C. Wayne (P80542) 

Attorneys for Respondent 

27555 Executive Drive 

Suite 250 

Farmington Hills, MI 48331-3550 

(248) 489-4100 

smorita@rsjalaw.com 

mwayne@rsjalaw.com 

 

 

Respondent's Answer to Petition 

 

 

 

NOW COMES Respondent, City of Novi, by and through its Attorneys, ROSATI, 

SCHULTZ, JOPPICH & AMTSBUECHLER, P.C. and for its Answer to Petitioner's Petition, 

states as follows: 

 

1. 

As to the allegations contained in Paragraph 1 of the Petition, Respondent 

admits the same. 

2. 

As to the allegations contained in Paragraph 2 of the Petition, Respondent 

admits the same.

Page 2

2 

 

3. 

As to the allegations contained in Paragraph 3 of the Petition, Respondent 

denies the same as untrue and because only one parcel is under appeal. 

4. 

As to the allegations contained in Paragraph 4 of the Petition, no allegation is 

made so no response is necessary. 

5. 

As to the allegations contained in Paragraph 5 of the Petition, Respondent 

admits the same. 

6. 

As to the allegations contained in Paragraph 6 of the Petition, Respondent 

admits the same. 

7. 

As to the allegations contained in Paragraph 7 of the Petition, no allegation is 

made so no response is necessary. 

8. 

As to the allegations contained in Paragraph 8 of the Petition, no allegation is 

made so no response is necessary. 

9. 

As to the allegations contained in Paragraph 9 of the Petition, no allegation is 

made so no response is necessary. 

10. 

As to the allegations contained in Paragraph 10 of the Petition, Respondent 

denies the same as untrue and because the property’s address does not contain the name of 

the Petitioner. 

11. 

As to the allegations contained in Paragraph 11 of the Petition, Respondent 

admits the same. 

12. 

As to the allegations contained in Paragraph 12 of the Petition, Respondent 

neither admits nor denies the same for the reason Respondent is without sufficient 

knowledge to form a belief as to the truth thereof and therefore leaves Petitioner to its strict 

proofs. 

13. 

As to the allegations contained in Paragraph 13 of the Petition, Respondent 

neither admits nor denies the same for the reason Respondent is without sufficient

Page 3

3 

 

knowledge to form a belief as to the truth thereof and therefore leaves Petitioner to its strict 

proofs. 

14. 

As to the allegations contained in Paragraph 14 of the Petition, Respondent 

admits the same. 

15. 

As to the allegations contained in Paragraph 15 of the Petition, no allegation 

is made, so no response is necessary. 

16. 

As to the allegations contained in Paragraph 16 of the Petition, Respondent 

admits the same. 

17. 

As to the allegations contained in Paragraph 17 of the Petition, Respondent 

neither admits nor denies the same for the reason Respondent is without sufficient 

knowledge to form a belief as to the truth thereof and therefore leaves Petitioner to its strict 

proofs. 

18. 

As to the allegations contained in Paragraph 18 of the Petition, Respondent 

neither admits nor denies the same for the reason Respondent is without sufficient 

knowledge to form a belief as to the truth thereof and therefore leaves Petitioner to its strict 

proofs. 

19. 

As to the allegations contained in Paragraph 19 of the Petition, Respondent 

denies as untrue that the Petitioner is entitled to the relief requested. 

20. 

As to the allegations contained in Paragraph 20 of the Petition, Respondent 

denies the same as untrue. 

21. 

Respondent further states the ratio of the average level of assessment in 

relation to true cash value in the assessment district is 50%, and the equalization factor was 

uniformly applied in the assessment district for the year in question. 

WHEREFORE, Respondent, City of Novi, denies that Petitioner is entitled to the 

relief it seeks and respectfully requests that the Respondent's assessment and taxable value

Page 4

4 

 

of the subject property be affirmed or increased, that Petitioner's Petition be dismissed with 

prejudice and that Respondent be granted costs and attorney fees so wrongfully sustained. 

 

 

 

 

 

 

Respectfully submitted, 

 

 

 

 

 

 

ROSATI, SCHULTZ, JOPPICH 

& AMTSBUECHLER, P.C. 

 

 

 

 

 

 

 

/s/ Stephanie Simon Morita 

 

 

 

 

 

 

 

 

 

STEPHANIE SIMON MORITA (P53864) 

 

 

 

 

 

 

Attorney for Respondent 

 

 

 

 

 

 

27555 Executive Drive, Suite 250 

 

 

 

 

 

 

Farmington Hills, MI 48331 

 

 

 

 

 

 

(248) 489-4100 

 

Dated: September 9, 2025 

 

 

 

 

 

 

 

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.

Page 5

5 

 

 

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

Page 6

6

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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. 25-001907

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

City Of Novi (OAKLAND)

Local Unit of Government/First Name

M.I.

Last Name

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

City or Town

State

Michigan

ZIP Code

Telephone Number

Fax Number

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

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Stephanie

M.I.

Simon

Last Name

Morita

Firm Name (if any)

Rosati, Schultz, Joppich & Amtsbuechler, P.C. 

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

27555 Executive Drive

Suite 250

City or Town

Farmington Hills

State

Michigan

ZIP Code

48331

Telephone Number

248-489-4100

Fax Number

248-489-1726

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

smorita@rsjalaw.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Stephanie S. Morita

/s/

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Page 1

August 27, 2025 

Chief Clerk 

Michigan Tax Tribunal 

P.O. Box 30232 

Lansing, MI 48909 

MTT Docket No. 25-001907-TT 

Eberspaecher North America, Petitioner, 

\ 

City of Novi, Respondent. 

Dear Honorable Tribunal 

Enclosed for filing, with regards to the above referenced docket number, please find: 

1. 

A Proof of Service indicating that a copy of the Petition was served on the appropriate 

parties. 

If you should have any questions or concerns, please contact me at 216.685.9448. 

Respectfully Submitted 

Ryan, LLC 

/s/ Mark T. McMerrell 

Mark T. McMerrell 

Petitioner's Representative 

600 Superior Avenue E, Suite 1810 

Cleveland, OH 44114 

216.685.9448

Page 2

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

Eberspaecher North America, 

Petitioner, 

MTT Docket No. 25-001907-TT 

v 

City of Novi, 

Respondent. 

PROOF OF SERVICE 

1, Janet Muchewicz, being duly sworn, deposes and says that on August 27, 2025, a copy of 

the Petition relative to the above-captioned matter, was served by U.S Postal Service upon: 

Certified Mail 

— 

City of Novi Assessor, 45175 W 10 Mile Road, Novi, Michigan 48375 

2. 

City of Novi Clerk, 45175 W 10 Mile Road, Novi, Michigan 48375 

First Class Mail 

Oakland County Clerk, 1200 North Telegraph Road, Bldg 12E, Pontiac, Michigan 48341 

Novi Community School District, 25345 Taft Road, Novi, Michigan 48374 

Oakland County Equalization, 1200 North Telegraph Road, Ste 1000, Pontiac, Michigan 48341 

State Treasurer, Michigan Department of Treasury, 430 W. Allegan, Lansing, Michigan 48922 

Ona 

gs

Page 3

Sam 

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

EBERSPAECHER NORTH AMERICA 

, 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

Vv 

MTT Docket No. 25-001907 

CITY OF NOVI 

, 

Respondent(s) 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

1. 

Property Parcel No: 50-22-12-200-018 

(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 X__real __ personal. 

3. 

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

contiguous? Yes 

X 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): 

N/A - No personal property is included in this appeal 

6. 

The property identified above is classified as 301 - INDUSTRIAL IMPROVED

Page 4

MTT Docket No. 25-001807 

Page 2 of 4 

10. 

11. 

12. 

13. 

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): 

N/A 

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 Tribunals authority over the assessment or 

assessments at issue (attach additional page if necessary): 

N/A 

The property or properties at issue are located in OAKLAND 

County. The 

property or properties’ address is: 

EBERSPAECHER NORTH AMERICA 

29101 HAGGERTY RD 

NOVI, MI 48377-2913 

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

local governmental unit): CITY OF NOVI 

Petitioner's legal residence or principal office address is: 

EBERSPAECHER NORTH AMERICA 

29101 HAGGERTY RD 

NOVI, Mi 48377-2913 

This appeal involves 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

Page 5

MTT Docket No. 25-001907 

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): 

N/A 

16. 

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

Board of Review are: 

Tax Year 

True Cash Value 

Assessed Value 

Taxable Value 

2025 

7,741,520 

3,870,760 

2,608,470 

17. 

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

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2025 

4,000,000 

2,000,000 

2,000,000 

18. 

The values in dispute for the property identified above are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2025 

3,741,520 

1,870,760 

608,470 

19. 

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

Petitioner requests that the Tax Tribunal reduce the 2025 True Cash, State Equalized, 

and taxable values of the appeal parcel and order a tax refund with interest and costs, 

as provided by the Tax Tribunal Act.

Page 6

MTT Docket No. 25-001907 

Page 4 of 4 

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

Is! Mark T. McMerrell 

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

Mark T. McMerrell 

Email Address: mark.mcmerrell@ryan.com 

Mailing Address: 

Ryan, LLC Attn: Mark McMerrell 

600 Superior Avenue E, Suite 1810 

Cleveland, OH 44114 

Telephone Number: 216.685.9448 

Date: May 30, 2025

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.

EBERSPAECHER NORTH AMERICA

TBD

CITY OF NOVI

50-22-12-200-018

x

X

N/A - No personal property is included in this appeal

301 - INDUSTRIAL 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: _______________________________________ 

 

 

 

 

 

 

TBD

N/A

N/A

OAKLAND

EBERSPAECHER NORTH AMERICA

29101 HAGGERTY RD

NOVI, MI 48377-2913

CITY OF NOVI

EBERSPAECHER NORTH AMERICA

29101 HAGGERTY RD

NOVI, MI 48377-2913

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): 

 

 

 

 

 

 

 

TBD

N/A

2025

7,741,520

3,870,760

2,608,470

2025

4,000,000

2,000,000

2,000,000

2025

3,741,520

1,870,760

608,470

Petitioner requests that the Tax Tribunal reduce the 2025 True Cash, State Equalized,

 and taxable values of the appeal parcel and order a tax refund with interest and costs,

 as provided by the Tax Tribunal Act.

The 2025 assessment imposed on the subject property is excessive and exceeds the 

market value. The State equalized value imposed on the subject property is more 

than 50% of its true cash value. Thus, the tax levied and collected should be deemed 

to be excessive and invalid.

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: _________________________________________________________ 

 

Mailing Address: 

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________ 

 

Telephone Number: _____________________________________________________ 

 

Date: _________________________________________________________________ 

 

TBD

/s/ Mark T.

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

Eberspaecher North America, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-001907

City Of Novi, 

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: July 30, 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.

EBERSPAECHER NORTH AMERICA

TBD

CITY OF NOVI

50-22-12-200-018

x

X

N/A - No personal property is included in this appeal

301 - INDUSTRIAL 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: _______________________________________ 

 

 

 

 

 

 

TBD

N/A

N/A

OAKLAND

EBERSPAECHER NORTH AMERICA

29101 HAGGERTY RD

NOVI, MI 48377-2913

CITY OF NOVI

EBERSPAECHER NORTH AMERICA

29101 HAGGERTY RD

NOVI, MI 48377-2913

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): 

 

 

 

 

 

 

 

TBD

N/A

2025

7,741,520

3,870,760

2,608,470

2025

4,000,000

2,000,000

2,000,000

2025

3,741,520

1,870,760

608,470

Petitioner requests that the Tax Tribunal reduce the 2025 True Cash, State Equalized,

 and taxable values of the appeal parcel and order a tax refund with interest and costs,

 as provided by the Tax Tribunal Act.

The 2025 assessment imposed on the subject property is excessive and exceeds the 

market value. The State equalized value imposed on the subject property is more 

than 50% of its true cash value. Thus, the tax levied and collected should be deemed 

to be excessive and invalid.

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: _________________________________________________________ 

 

Mailing Address: 

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________

______________________________________________________________________ 

 

Telephone Number: _____________________________________________________ 

 

Date: _________________________________________________________________ 

 

TBD

/s/ Mark T.

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Entire Tribunal Case Information Sheet - Petitioner

MOAHR DOCKET NO. 

Section 1: Petitioner’s Contact Information

Filer type: Organization

First Name/Company Name

M.I.

Last Name

Eberspaecher North America

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

29101 Haggerty Rd

City or Town

Novi

State

Michigan

ZIP Code

48377-2913

Telephone Number

3307014156

Fax Number

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

mark.mcmerrell@ryan.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Mark

M.I.

T

Last Name

McMerrell

Firm Name (if any)

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

127 Public Square Suite 2800

City or Town

Cleveland

State

Ohio

ZIP Code

44114

Telephone Number

216-685-9448

Fax Number

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

mark.mcmerrell@ryan.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]

29101 Haggerty Rd

Novi

Michigan

48377-2913

Taxing Authority (City or Township)

City Of Novi (OAKLAND)

County

Oakland

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

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

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

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

True Cash and Taxable Values

Section 8: Valuation Information for Each Parcel under Appeal

Parcel Number:

50-22-12-200-018

Classification of Property: Real 

Industrial

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

3870760

Current Taxable Value as established by the Board of Review:

2608470

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

4000000

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

2000000

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/ Mark T McMerrell

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.