Generate Fremont Digester LLC, Petitioner Vs. City Of Fremont, 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

Generate Fremont Digester LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-001622

City Of Fremont,

Respondent.

ORDER GRANTING JOINT MOTION TO WITHDRAW

ORDER OF DISMISSAL

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

have filed a Joint Motion to Withdraw the appeal. Therefore,

IT IS ORDERED that the parties’ Joint Motion to Withdraw is GRANTED. 

IT IS FURTHER ORDERED that this case is DISMISSED. 

This order resolves all pending issues and closes the case.

By:_____________________________________

Patricia L. Halm, Tribunal Chair

Entered: December 2, 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

Page 2

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

Generate Fremont Digester LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-001622

City Of Fremont,

Respondent.

ORDER GRANTING JOINT MOTION TO WITHDRAW

ORDER OF DISMISSAL

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

have filed a Joint Motion to Withdraw the appeal. Therefore,

IT IS ORDERED that the parties’ Joint Motion to Withdraw is GRANTED. 

IT IS FURTHER ORDERED that this case is DISMISSED. 

This order resolves all pending issues and closes the case.

By:_____________________________________

Patricia L. Halm, Tribunal Chair

Entered: December 2, 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

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

Generate Fremont Digester LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-001622

City Of Fremont,

Respondent.

ORDER GRANTING JOINT MOTION TO WITHDRAW

ORDER OF DISMISSAL

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

have filed a Joint Motion to Withdraw the appeal. Therefore,

IT IS ORDERED that the parties’ Joint Motion to Withdraw is GRANTED. 

IT IS FURTHER ORDERED that this case is DISMISSED. 

This order resolves all pending issues and closes the case.

By:_____________________________________

Patricia L. Halm, Tribunal Chair

Entered: December 2, 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 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

Generate Fremont Digester, LLC, 

 Petitioner, 

 

v. 

 

City of Fremont, 

 Respondent. 

___________________________________/ 

 

 

MTT Docket No. 25-001622-TT 

 

 

 

STIPULATED DISMISSAL 

 

 

Petitioner, Generate Fremont Digester, LLC, and Respondent, the City of 

Fremont, by and through their respective undersigned counsel, hereby stipulate to 

the dismissal of the above-captioned matter, with prejudice, and without costs to 

either party. 

 

So Agreed: 

 

/s/ Ryan M. Shannon 

Ryan M. Shannon (P74535) 

Dickinson Wright PLLC 

Counsel for Petitioner 

123 W. Allegan St., Suite 900 

Lansing, MI 48933 

(517) 371-1730 

rshannon@dickinsonwright.com 

 

Dated: December 1, 2025 

 

/s/ Laura M. Hallahan 

Laura M. Hallahan (P42101) 

Hallahan & Associates, P.C. 

Counsel for Respondent 

1750 S. Telegraph Rd., Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

lhallahan@hallahanlaw.com 

 

Dated: December 1, 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

NOTICE OF OCTOBER 16 - 30, 2026 PREHEARING GENERAL CALL AND ORDER 

OF PROCEDURE

Generate Fremont Digester LLC,

Petitioner,

v

 

 

City Of Fremont,

Respondent.

 MTT Docket No. 25-001622

Please be advised that 25-001622 has been placed on a two-week Prehearing General 

Call commencing October 16, 2026. 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. 25-001622

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 June 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 June 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 

June 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 

October 16, 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. “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 at any time subsequent to the completion date for this 

Prehearing General Call. Parties will, however, be notified in writing approximately one 

week before they are scheduled to appear. 

By:_____________________________________

Patricia L. Halm, Tribunal Chair

Entered: November 17, 2025

Page 3

MTT Docket No. 25-001622

Page 3 of 3

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 provide by those parties, attorneys, or authorized 

representatives.

By: Tribunal Clerk

Page 4

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 OCTOBER 16 - 30, 2026 PREHEARING GENERAL CALL AND ORDER

Page 5

MT

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Page 1

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

GENERATE FREMONT DIGESTER LLC, 

 

 

 

Petitioner, 

 

v 

 

CITY OF FREMONT, 

 

 

 

Respondent. 

 

 

 

Docket No. 25-001622 

Parcel No. 62-17-03-151-038 

 

 

_____________________________________________________________________________/ 

 

RYAN M. SHANNON (P74535) 

DICKINSON WRIGHT PLLC 

Attorney for Petitioner 

123 W. Allegan Street, Suite 900 

Lansing, MI 48933 

(517) 371-1730 

 

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 Fremont, by and through its attorneys, Hallahan & Associates, P.C., 

responds to the allegations made in Petitioner’s Petition as follows: 

1. 

Respondent admits the allegations in Paragraph 1. 

 

2. 

Respondent admits the allegations in Paragraph 2. 

 

3. 

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

truth of the allegations contained therein and, therefore, leaves Petitioner to its proofs. 

 

4. 

Respondent neither admits nor denies the allegations in Paragraph 4 as the 

General Property Tax Act speaks for itself. 

 

5. 

Respondent admits the allegations in Paragraph 5.

Page 2

Entire Tribunal Property Tax Answer 

Page 2 of 5 

 

6. 

Respondent admits the allegations in Paragraph 6. 

 

7. 

Respondent lacks the information and knowledge necessary to respond to the 

truth of the allegations set forth in Paragraph 7 and, therefore, leaves Petitioner to its proofs. 

 

8. 

Respondent acknowledges Petitioner’s beliefs as to the issues in this appeal but 

denies that those issues have merit and further denies Petitioner is entitled to any relief. 

 

9. 

Respondent acknowledges Petitioner’s belief as to an issue with the 2025 tax year 

but denies any issue with said tax year. 

 

10. 

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 

$1,874,200 

$937,100 

$917,136 

 

11. 

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

 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2025 

$1,874,200 

$937,100 

$917,136 

 

12. 

The values in dispute for the property identified above are: 

 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2025 

$0 

$0 

$0 

 

13. 

Respondent denies the allegations in Paragraph 13 for the reason that the same are 

untrue. Furthermore, the assessed, state equalized and/or taxable values do not exceed permitted 

amounts, do not exceed the percentage for 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. 

 

14. 

Respondent acknowledges the relief requested by Petitioner in the final paragraph 

of its Petition but denies that Petitioner is entitled to the relief requested for the reasons stated in 

the preceding paragraphs. 

 

WHEREFORE, Respondent, City of Fremont, 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.

Page 3

Entire Tribunal Property Tax Answer 

Page 3 of 5 

 

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 3, 2025 

(248) 731-3089 

 

 

 

AFFIRMATIVE DEFENSES 

 

Respondent, City of Fremont, 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. 

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.

Page 4

Entire Tribunal Property Tax Answer 

Page 4 of 5 

 

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 allege specific and sufficient facts 

to support its allegations that the property’s taxable value is improper. 

7. 

Petitioner asks the Tribunal to grant it preference by application of a self-chosen 

method of assessment contrary to the intent, purpose and law of this State. 

8. 

Petitioner, in essence, asks the Tribunal to grant it an illegal preference by 

application of a method of assessment different from that employed in the assessment of other 

properties in Respondent’s taxing unit. 

9. 

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

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

10. 

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

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

equitable tax

Page 5

Entir

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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. 25-001622

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

City Of Fremont (NEWAYGO)

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

Laura

M.I.

M

Last Name

Hallahan

Firm Name (if any)

Hallahan & Associates, P.C.

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

Telephone Number

248-731-3087

Fax Number

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

MTT@hallahanlaw.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Kelsea M. Melcher

/s/

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Page 1

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

) 

MICHIGAN TAX TRIBUNAL 

Generate Fremont Digester LLC 

Petitioner(s) 

v 

MTT Docket No. 25-001622 

City of Fremont 

Respondent(s) 

PROOF OF SERVICE FOR PROPERTY TAX PETITION 

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

Deirdriu J. Coffman 

states that on 

August 6, 2025 

he/she 

[Name of person serving/mailing petition] 

[date of service] 

served a copy of the Petition and Notice of Docket Number relative to the above-captioned 

matter upon: 

1. 

Assessor (via certified mail): 

Assessor, City of Fremont, 101 E. Main Street, Fremont, MI 49412 

2. 

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

City Clerk, City of Fremont, 

101 E, Main Street, Fremont, MI 49412 

3. 

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

Di 

{ 

Equalization. 

c 

PO Box 885. 

White 

C. 

0349-0885 

4. 

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

County Clerk, 

Newaygo County, PO Box 885. White Cloud, 

MI 49349-0885 

5. 

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

Secretary of School Board, Fremont Public Schools, 

450 E. Pine, Fremont, MI 49412 

6. 

State Treasurer (via first class mail): 

Michigan Department of Treasury, State Treasurer 

430 W. Allegan 

Lansing, MI 48922 

/ 

: 

’ 

Deirdriu J. Coffman 

[Signature of perispn who is serving/mailing copy] 

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

MICHIGAN TAX TRIBUNAL 

- 611 W. OTTAWA ST., LANSING, MI 48933 

- 517-335-9760 

PO BOX 30232, LANSING, MI 48909 

- Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906

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

Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

ENTIRE TRIBUNAL 

 

Generate Fremont Digester LLC, 

 Petitioner, 

 

v. 

 

City of Fremont, 

 Respondent. 

___________________________________/ 

 

 

MTT Docket No. __________________ 

 

 

Ryan M. Shannon (P74535) 

Dickinson Wright PLLC 

Counsel for Petitioner 

123 W. Allegan St., Suite 900 

Lansing, MI 48933 

(517) 371-1730 office 

(517) 410-5443 mobile 

rshannon@dickinsonwright.com 

__________________________________/ 

 

 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

 

Petitioner, Generate Fremont Digester LLC (“Petitioner”), by and through its 

counsel, Dickinson Wright PLLC, hereby states as follows for its Petition: 

1. 

This appeal concerns the following parcel number, hereinafter referred to 

as the “Subject Property”: 

• 62-17-03-151-038 

2. 

The Subject Property is real property and classified as 301-industrial. 

3. 

Petitioner owns the Subject Property and is a party in interest. 

4. 

No appeal to the local board of review was necessary to invoke the 

jurisdiction of the Tribunal as the parcel is classified as industrial.

Page 2

Generate Fremont Digester, LLC Petition 

2 

 

5. 

The Subject Property is located in Newaygo County; its physical address is 

1634 Locust St., Fremont, MI. 

6. 

The assessment at issue was established by the City of Fremont 

(“Respondent”). 

7. 

Petitioner’s principal office address is 560 Davis St., Ste. 250, San 

Francisco, CA 94111. 

8. 

This appeal involves issues relating the Subject Property’s true cash and 

taxable values, as well as uniformity of assessment. 

9. 

The tax year at issue is 2025. 

10. 

The 2025 values for the Subject Property as established by Respondent’s 

Board of Review are: 

Parcel No. 

True Cash Value 

Assessed Value 

Taxable Value 

62-17-03-151-038 

$1,874,200 

$937,100 

$917,136 

 

11. 

Petitioner contends that the 2025 values for the Subject Property are: 

Parcel No. 

True Cash Value 

State Equalized 

Value 

Taxable Value 

62-17-03-151-038 

$300,000 

$150,000 

$150,000 

 

12. 

The 2025 values in dispute for the Subject Property are: 

Parcel No. 

True Cash Value 

State Equalized 

Value 

Taxable Value 

62-17-03-151-038 

$1,574,200 

$787,100 

$767,136

Page 3

Generate Fremont Digester, LLC Petition 

3 

 

13. 

The 2025 assessments are improper because the assessed and taxable 

values exceed 50% of the true cash value. The mode of assessment adopted 

is improper and/or overstates the value of the Subject Property. 

 

WHEREFORE, Petitioner requests that the Tribunal enter an order: (i) finding the 

current assessments to be invalid, (ii) adopting the values set forth as Petitioner’s 

contentions above, (iii) ordering a refund with interest of any overpayment of taxes, 

and (iv) granting such other further relief as the Tribunal deems to be within its 

power to grant. 

 

Submitted Respectfully, 

 

DICKINSON WRIGHT PLLC 

/s/ Ryan M. Shannon 

Ryan M. Shannon (P74535 

Counsel for Petitioner 

 

Dated: May 28, 2025 

 

 

 

Filing fee: $600

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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

Generate Fremont Digester LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-001622

City Of Fremont, 

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 8, 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

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

ENTIRE TRIBUNAL 

 

Generate Fremont Digester LLC, 

 Petitioner, 

 

v. 

 

City of Fremont, 

 Respondent. 

___________________________________/ 

 

 

MTT Docket No. __________________ 

 

 

Ryan M. Shannon (P74535) 

Dickinson Wright PLLC 

Counsel for Petitioner 

123 W. Allegan St., Suite 900 

Lansing, MI 48933 

(517) 371-1730 office 

(517) 410-5443 mobile 

rshannon@dickinsonwright.com 

__________________________________/ 

 

 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

 

Petitioner, Generate Fremont Digester LLC (“Petitioner”), by and through its 

counsel, Dickinson Wright PLLC, hereby states as follows for its Petition: 

1. 

This appeal concerns the following parcel number, hereinafter referred to 

as the “Subject Property”: 

• 62-17-03-151-038 

2. 

The Subject Property is real property and classified as 301-industrial. 

3. 

Petitioner owns the Subject Property and is a party in interest. 

4. 

No appeal to the local board of review was necessary to invoke the 

jurisdiction of the Tribunal as the parcel is classified as industrial.

Page 2

Generate Fremont Digester, LLC Petition 

2 

 

5. 

The Subject Property is located in Newaygo County; its physical address is 

1634 Locust St., Fremont, MI. 

6. 

The assessment at issue was established by the City of Fremont 

(“Respondent”). 

7. 

Petitioner’s principal office address is 560 Davis St., Ste. 250, San 

Francisco, CA 94111. 

8. 

This appeal involves issues relating the Subject Property’s true cash and 

taxable values, as well as uniformity of assessment. 

9. 

The tax year at issue is 2025. 

10. 

The 2025 values for the Subject Property as established by Respondent’s 

Board of Review are: 

Parcel No. 

True Cash Value 

Assessed Value 

Taxable Value 

62-17-03-151-038 

$1,874,200 

$937,100 

$917,136 

 

11. 

Petitioner contends that the 2025 values for the Subject Property are: 

Parcel No. 

True Cash Value 

State Equalized 

Value 

Taxable Value 

62-17-03-151-038 

$300,000 

$150,000 

$150,000 

 

12. 

The 2025 values in dispute for the Subject Property are: 

Parcel No. 

True Cash Value 

State Equalized 

Value 

Taxable Value 

62-17-03-151-038 

$1,574,200 

$787,100 

$767,136

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Generate Fremont Digester, LLC Petition 

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13. 

The 2025 assessments are improper because the assessed and taxable 

values exceed 50% of the true cash value. The mode of assessment adopted 

is improper and/or overstates the value of the Subject Property. 

 

WHEREFORE, Petitioner requests that the Tribunal enter an order: (i) finding the 

current assessments to be invalid, (ii) adopting the values set forth as Petitioner’s 

contentions above, (iii) ordering a refund with interest of any overpayment of taxes, 

and (iv) granting such other further relief as the Tribunal deems to be within its 

power to grant. 

 

Submitted Respectfully, 

 

DICKINSON WRIGHT PLLC 

/s/ Ryan M. Shannon 

Ryan M. Shannon (P74535 

Counsel for Petitioner 

 

Dated: May 28, 2025 

 

 

 

Filing fee: $600

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

Generate Fremont Digester LLC

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

560 Davis St.

Ste. 250

San Francisco,

City or Town

California

State

Michigan

ZIP Code

94111

Telephone Number

(517) 410-5443

Fax Number

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

rshannon@dickinsonwright.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Ryan

M.I.

Michael

Last Name

Shannon

Firm Name (if any)

Dickinson Wright PLLC

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

123 W. Allegan St.

Suite 900

City or Town

Lansing

State

Michigan

ZIP Code

48933

Telephone Number

517-487-4719

Fax Number

517-487-4700

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

rshannon@dickinsonwright.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]

1634 Locust St.

Fremont

Michigan

49412

Taxing Authority (City or Township)

City Of Fremont (NEWAYGO)

County

Newaygo

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:

62-17-03-151-038

Classification of Property: Real 

Industrial

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

937100

Current Taxable Value as established by the Board of Review:

917136

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

300000

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

150000

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/ Ryan M. Shannon

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.