Haggerty Corridor Office Centre IV LLC, 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 

Haggerty Corridor Office Centre IV LLC, 

MICHIGAN TAX TRIBUNAL 

 

Petitioner, 

 

 

v 

 

MTT Docket No. 25-001859 

 

City of Novi, 

 

Presiding Judge 

Respondent. 

 

Patricia L. Halm 

 

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, 2020, through June 30, 2022, at the rate of 4.25%, 

(ii) after June 30, 2022, through December 31, 2022, at the rate of 4.27%, (iii) after 

December 31, 2022, through June 30, 2023, at the rate of 5.65%, (iv) after June 30, 

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

 

1 See MCL 211.27a. 

2 See MCL 205.755.

Page 2

MTT Docket No. 25-001859 

Page 2 of 2 

 

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

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

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

of 8.66%. 

 

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: October 31, 2025 

sb 

 

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

Page 1 of 2 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

 

 

HAGGERTY CORRIDOR 

OFFICE CENTRE IV, LLC, 

 

 

Petitioner, 

v. 

 

 

 

 

 

 

 

 

 Docket No. 25-001859 

 

CITY OF NOVI, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Jason C. Long (P59244) 

Jerome P. Pesick (P29039) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

Attorneys for Petitioner 

Stephanie Simon Morita (P53864) 

ROSATI, SCHULTZ, JOPPICH 

& AMTSBUECHLER, P.C. 

27555 Executive Dr., Ste. 250 

Farmington Hills, MI 48331-3550 

(248) 489-4100 

Attorneys for Respondent 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Stipulation for Entry of Consent Judgment 

 

1. 

This appeal is pending in the Entire Tribunal Division. 

 

2. 

The subject property in this appeal is identified as Parcel No. 50-22-12-

400-060 and commonly known as 28175 Cabot Drive, Novi, Michigan 48377 (the 

“Subject Property”). 

 

3. 

The values for the Subject Property for the 2025 tax year established 

by Respondent’s Board of Review are as follows: 

 

 

True Cash Value 

 

Assessed Value 

 

Taxable Value 

 

 $4,144,720 

 

 $2,072,360 

 

 $2,058,430 

 

4. 

The values for the Subject Property for the 2023 tax year stipulated by 

the parties for settlement purposes are as follows: 

 

True Cash Value 

 

Assess Value 

 

Taxable Value 

 $3,200,000 

 

 $1,600,000 

 

 $1,600,000 

SSM

Page 2

Page 2 of 2 

Docket No. 25-001859 

5.

Special terms and conditions:

(a) The parties agree that any refunds shall be without interest provided that

the refunds are paid within 60 days of the date of entry of any Consent Judgment. 

Taxing entities shall have 60 days from the date of the consent judgment to pay any 

refunds due. 

(b) Any refunds shall be issued payable jointly to Petitioner and Williams,

Williams, Rattner & Plunkett, P.C., and shall be delivered to Petitioner’s attorneys 

as follows: Williams, Williams, Rattner & Plunkett, P.C., Attn: Jason C. Long, 380 

N. Old Woodward, Suite 300, Birmingham, MI 48009.

Wherefore, the parties respectfully request that this honorable Tribunal 

enter a Consent Judgment revising the Subject Property’s 2025 property tax 

assessment consistent with the values set forth in this Stipulation. 

Jason C. Long (P59244) 

Attorney for Petitioner 

 

 

 

Stephanie Simon Morita (P53864) 

Attorney for Respondent 

Dated: October ___, 2025 

/s/ Stephanie S. Morita

29

/s/ Jason C. Long

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Page 1

Page 1 of 2 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

 

 

HAGGERTY CORRIDOR 

OFFICE CENTRE IV, LLC, 

 

 

Petitioner, 

v. 

 

 

 

 

 

 

 

 

 Docket No. 25-001859 

 

CITY OF NOVI, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Jason C. Long (P59244) 

Jerome P. Pesick (P29039) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

Attorneys for Petitioner 

Stephanie Simon Morita (P53864) 

ROSATI, SCHULTZ, JOPPICH 

& AMTSBUECHLER, P.C. 

27555 Executive Dr., Ste. 250 

Farmington Hills, MI 48331-3550 

(248) 489-4100 

Attorneys for Respondent 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Stipulation for Entry of Consent Judgment 

 

1. 

This appeal is pending in the Entire Tribunal Division. 

 

2. 

The subject property in this appeal is identified as Parcel No. 50-22-12-

400-060 and commonly known as 28175 Cabot Drive, Novi, Michigan 48377 (the 

“Subject Property”). 

 

3. 

The values for the Subject Property for the 2025 tax year established 

by Respondent’s Board of Review are as follows: 

 

 

True Cash Value 

 

Assessed Value 

 

Taxable Value 

 

 $4,144,720 

 

 $2,072,360 

 

 $2,058,430 

 

4. 

The values for the Subject Property for the 2023 tax year stipulated by 

the parties for settlement purposes are as follows: 

 

True Cash Value 

 

Assess Value 

 

Taxable Value 

 $3,200,000 

 

 $1,600,000 

 

 $1,600,000 

SSM

Page 2

Page 2 of 2 

Docket No. 25-001859 

5.

Special terms and conditions:

(a) The parties agree that any refunds shall be without interest provided that

the refunds are paid within 60 days of the date of entry of any Consent Judgment. 

Taxing entities shall have 60 days from the date of the consent judgment to pay any 

refunds due. 

(b) Any refunds shall be issued payable jointly to Petitioner and Williams,

Williams, Rattner & Plunkett, P.C., and shall be delivered to Petitioner’s attorneys 

as follows: Williams, Williams, Rattner & Plunkett, P.C., Attn: Jason C. Long, 380 

N. Old Woodward, Suite 300, Birmingham, MI 48009.

Wherefore, the parties respectfully request that this honorable Tribunal 

enter a Consent Judgment revising the Subject Property’s 2025 property tax 

assessment consistent with the values set forth in this Stipulation. 

Jason C. Long (P59244) 

Attorney for Petitioner 

 

 

 

Stephanie Simon Morita (P53864) 

Attorney for Respondent 

Dated: October ___, 2025 

/s/ Stephanie S. Morita

29

/s/ Jason C. Long

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

Haggerty Corridor Office Centre IV LLC, 

 

 

Petitioner, 

 

 

MTT Docket No. 25-001859 

v. 

 

City of Novi, 

 

 

Respondent. 

 

 WILLIAMS, WILLIAMS, RATTNER & 

 PLUNKET, P.C. 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

Attorneys for Petitioner 

380 N. Old Woodward Ave., Suite 300 

Birmingham, MI 48009 

(248) 642-0333 

jpesick@wwrplaw.com 

jlong@wwrplaw.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 

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 

proof. 

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 

admits the same except that the property is Petitioner’s and as to that allegation, 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. 

4. 

As to the allegations contained in Paragraph 4 of the Petition, Respondent 

admits the same. 

5. 

As to the allegations contained in Paragraph 5 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. 

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, Respondent 

admits the same. 

8. 

As to the allegations contained in Paragraph 8 of the Petition, Respondent 

admits the same. 

9. 

As to the allegations contained in Paragraph 9 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. 

10. 

As to the allegations contained in Paragraph 10 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.

Page 3

3 

 

11. 

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

denies as untrue that Petitioner may amend the Petition to assert additional claims 

subsequent to the statutory filing deadline; as to the remainder of the allegations, 

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. 

12. 

As to the allegations contained in Paragraph 12 and its subparts of the 

Petition, Respondent denies the same as untrue. 

13. 

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

admits the same. 

14. 

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 

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: August 25, 2025

Page 4

4 

 

Affirmative Defenses 

 

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

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

 

1. 

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

action against Respondent and to support its claim for relief. 

 

2. 

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

law, discrimination, application of wrong principles or illegality on the part of the 

Respondent. 

 

3. 

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

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

Respondent's taxing unit for the year in question. 

 

4. 

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

value, assessed value and taxable value of its property. 

 

5. 

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

that the assessed value of its property, as equalized, is at a factor other than 50% and also 

fails to allege specific and sufficient facts to support its allegations that the property's taxable 

value is improper. 

 

6. 

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

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

at the respective equalized

Page 5

5 

 

 

9.

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. 25-001859

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

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

HAGGERTY CORRIDOR OFFICE 

CENTRE IV, LLC, 

Petitioner, 

v. 

CITY OF NOVI, 

Respondent. 

Docket No. 25-001859 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

Attorneys for Petitioner 

Proof of Service of Petition and Notice of Docket Number

Page 2

Proof of Service of Petition and Notice of Docket Number 

Monica Athanas states that she personally served copies of the Entire Tribunal 

Property Tax Petition, the Notice of Docket Number, and this Proof of Service, on the 

persons listed below, by the means identified below, by placing those documents in 

duly stamped, addressed envelopes, and placing the envelopes in the United States 

. 2025. 

mail on hd yi 24 

J 

7 

PERSONS SERVED: 

Certified Mail 

Clerk 

City of Novi 

45175 W 10 Mile Rd, 

Novi, Michigan 48375 

Assessor 

City of Novi 

45175 W 10 Mile Rd, 

Novi, Michigan 48375 

This Proof of Service was signed and sworn before me on 

Toly 

24 

First Class Mail 

Clerk 

Oakland County 

1200 N Telegraph Building 

#12E 

Pontiac MI 48341 

Director of Equalization 

Oakland County 

250 Elizabeth Lake Rd 

#1000W 

Pontiac MI 48341 

Secretary of School Board 

Novi Community School District 

25345 Taft Road 

Novi, MI 48374 

State Treasurer 

Michigan Department of Treasury 

Austin Building 

430 W. Allegan 

Lansing, MI 

48922 

“I Nowiz YD, 

Monica Athanas 

, 2025. 

1, 

7, 

G2, 

wg 

l A 

So © Loy 

Soot Oaks, 

‘ 

§ 

v

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Page 1

1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

HAGGERTY CORRIDOR OFFICE 

CENTRE IV, LLC, 

 

 

 

 

 

 

 

 

Docket No. 25- 

 

Petitioner, 

 

 

 

 

 

Parcel No. 50-22-12-400-060 

v. 

 

CITY OF NOVI, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

Attorneys for Petitioner 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Entire Tribunal Property Tax Petition 

 

Petitioner Haggerty Corridor Office Centre IV, LLC, by and through its 

attorneys, Williams, Williams, Rattner & Plunkett, PC, states as follows for its Entire 

Tribunal Property Tax Petition. 

The Parties 

1. 

Petitioner Haggerty Corridor Office Centre IV, LLC, is a Michigan 

limited liability company with its principal place of business in Michigan located at 

39000 Country Club Drive, Farmington Hills, Michigan 48331. 

2. 

Respondent the City of Novi is a Michigan city with its principal offices 

located at 45175 W. 10 Mile Rd, Novi, Michigan 48375.

Page 2

2 

The Subject Property 

3. 

Petitioner owns property identified as Parcel No. 50-22-12-400-060 and 

commonly known as 28175 Cabot Drive, Novi, Michigan 48377 (the “Subject 

Property”). 

4. 

The Subject Property is located in Oakland County and is within the 

Novi Community School District, the Oakland County Community College District, 

and the Oakland Intermediate School District. 

5. 

The Subject Property was designed for, and is presently used for, office 

purposes, though it suffers from significant office vacancy. 

The 2025 Assessment 

6. 

Respondent possesses jurisdiction to assess and collect property taxes 

for the Subject Property. 

7. 

For the 2025 tax year, Respondent classified the Subject Property as 

commercial real property. 

8. 

For the 2025 tax year, Respondent established the Subject Property’s 

assessment for property taxes as follows: 

 

True Cash Value 

 

Assessed Value 

 

Taxable Value 

 

 $4,144,720 

 

 $2,072,360 

 

 $2,058,430 

 

A copy of the Subject Property’s Notice of Assessment is attached to this Petition as 

Exhibit A. 

9. 

Petitioner contends that a lawful assessment of the Subject Property for 

the 2025 tax year cannot exceed the following amounts: 

 

True Cash Value 

 

Assessed Value 

 

Taxable Value 

 

 $3,200,000 

 

 $1,600,000 

 

 $1,600,000

Page 3

3 

10. 

The amounts in dispute therefore are as follows: 

 

True Cash Value 

 

Assessed Value 

 

Taxable Value 

 

 $944,720 

 

 $472,360 

 

 $458,430 

 

11. 

This Petition presents issues involving the Subject Property’s valuation 

for property tax assessment purposes. Petitioner does not believe that this Petition 

presents any issues arising out of “additions” or “losses” as the General Property Tax 

Act, MCL 211.1 et seq. (the “GPTA”), defines those terms, but reserves its right to 

assert issues involving losses should information supporting such issues become 

available. 

12. 

The Subject Property’s 2025 assessment (a) violates the Michigan 

Constitution, the GPTA, and other Michigan law, (b) is based on erroneous principles 

and information, (c) is based on the misapplication of valuation principles, and (d) 

otherwise violates Petitioner’s rights. 

13. 

Petitioner does not assert that the Subject Property’s 2025 assessment 

is not uniform aside from the lack of uniformity resulting from Respondent 

overestimating the Subject Property’s values. 

Conclusion and Request for Relief 

WHEREFORE, Petitioner respectfully requests that this honorable Tribunal 

enter judgment revising the Subject Property’s 2025 assessment to be consistent with 

the values set forth in Paragraph 9 of this Petition and granting Petitioner all other

Page 4

4 

relief to which it is entitled under Michigan law. 

 

 

 

 

 

Respectfully Submitted, 

 

 

 

 

 

 

WILLIAMS, WILLIAMS, RATTNER 

 

 

 

 

 

& PLUNKETT, PC 

 

 

 

 

 

 

 

By: /s/ Jason C. Long 

 

 

 

 

 

 

 

 

 

 Jerome P. Pesick (P29039) 

 

 

 

 

 

 

 Jason C. Long (P59244) 

Dated: May 30, 2025 

 

 

Attorneys for Petitioner

Page 5

Exhibit A

Page 6

L-4400 

Michigan Department of Treasury 

1019 Rov. 1024) 

THIS IS NOT ATAX BILL 

Notice of Assessment, Taxable Valuation, and Property Classification 

Thie for 

ssed 

dor the aur 

of Pubic Act 208 of 1853, Sec. 211.24c and Sec21134c, 

3 amended. This 

I 

8 model assesment nofice 

0 bo used by 1 

ca 3569532" 

FROM: 

PARCEL IDENTIFICATION 

City of Nov) Assessing Dept 

PARCEL CODE NUMBER: 50-22-12-400-060 

Novi, MI 48375 

PROPERTY ADDRESS: 

28175 CABOT DR 

TO: 

0015377 

me 

FET HRI 

036*001*15377****SCH 5-DIGIT 

PRINCIPAL RESIDENCE EXEMPTION 

HAGGERTY CORRIDOR OFFICE CENTRE IV 

9% Exempt 

As “Homeowners Principal Residence": 

0.00% 

39000 COUNTRY CLUB DR 

w 

. 

200% 

FARMINGTON HILLS Mi 48331-3453 

% Exempt 

As “Qualified Agricultural Property” 

- 

% Exempt 

As “MBT industrial Personal”: 

0.00% 

% Exempt 

As “MBT Commercial Personal” 

0.00% 

Exempt As “Qualified Forest property”:|_| Yes x No 

Exempt 

As “Development Property”: 

O Yes x] No 

Legal Description: TIN, REE, SEC 12 OAKLAND COUNTY CONDOMINIUM PLAN NO 1679 HAGGERTY CORRIDOR CORPORATE PARK CONDOMINIUM-PHASE 1 UNIT 41 

34421 P 115 11-24-04 FR O50 

ACCORDING TO MCL 211.34c THIS PROPERTY IS CLASSIFIED AS: 

201 COMMERCIAL-IMPROVED 

CURRENT 

CHANGE FROM 

PRIOR AMOUNT 

| TENTATIVE AMOUNT 

PRIOR YEAR TO 

YEAR: 2024 

YEAR: 2025 

CURRENT YEAR 

1,996,540 

2,058,430 

61,890 

2. ASSESSED VALUE: 

1,996,540 

2,072,360 

75,820 

3. TENTATIVE EQUALIZATION FACTOR: 1.000 

4. STATE EQUALIZED VALUE (SEV): 

1,096,540 | 

2,072,360 

| 

75,820 

5. THERE WAS or WAS NOT A TRANSFER OF OWNERSHIP ON THIS PROPERTY IN 2024: Was Not 

5. ASSESSOR CHANGE REASON:Market Adjustment 

The 2025 Inflation Rate Multiplier is: 1.031 

Questions regarding the Notice of Assessment, Taxable Valuation, and Property Classification may be directed to the following: 

Name 

Telephone Number 

Email Address 

Janeene Ziozios 

(248) 347-0485

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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

Haggerty Corridor Office Centre IV LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-001859

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 28, 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

1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

HAGGERTY CORRIDOR OFFICE 

CENTRE IV, LLC, 

 

 

 

 

 

 

 

 

Docket No. 25- 

 

Petitioner, 

 

 

 

 

 

Parcel No. 50-22-12-400-060 

v. 

 

CITY OF NOVI, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

Attorneys for Petitioner 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Entire Tribunal Property Tax Petition 

 

Petitioner Haggerty Corridor Office Centre IV, LLC, by and through its 

attorneys, Williams, Williams, Rattner & Plunkett, PC, states as follows for its Entire 

Tribunal Property Tax Petition. 

The Parties 

1. 

Petitioner Haggerty Corridor Office Centre IV, LLC, is a Michigan 

limited liability company with its principal place of business in Michigan located at 

39000 Country Club Drive, Farmington Hills, Michigan 48331. 

2. 

Respondent the City of Novi is a Michigan city with its principal offices 

located at 45175 W. 10 Mile Rd, Novi, Michigan 48375.

Page 2

2 

The Subject Property 

3. 

Petitioner owns property identified as Parcel No. 50-22-12-400-060 and 

commonly known as 28175 Cabot Drive, Novi, Michigan 48377 (the “Subject 

Property”). 

4. 

The Subject Property is located in Oakland County and is within the 

Novi Community School District, the Oakland County Community College District, 

and the Oakland Intermediate School District. 

5. 

The Subject Property was designed for, and is presently used for, office 

purposes, though it suffers from significant office vacancy. 

The 2025 Assessment 

6. 

Respondent possesses jurisdiction to assess and collect property taxes 

for the Subject Property. 

7. 

For the 2025 tax year, Respondent classified the Subject Property as 

commercial real property. 

8. 

For the 2025 tax year, Respondent established the Subject Property’s 

assessment for property taxes as follows: 

 

True Cash Value 

 

Assessed Value 

 

Taxable Value 

 

 $4,144,720 

 

 $2,072,360 

 

 $2,058,430 

 

A copy of the Subject Property’s Notice of Assessment is attached to this Petition as 

Exhibit A. 

9. 

Petitioner contends that a lawful assessment of the Subject Property for 

the 2025 tax year cannot exceed the following amounts: 

 

True Cash Value 

 

Assessed Value 

 

Taxable Value 

 

 $3,200,000 

 

 $1,600,000 

 

 $1,600,000

Page 3

3 

10. 

The amounts in dispute therefore are as follows: 

 

True Cash Value 

 

Assessed Value 

 

Taxable Value 

 

 $944,720 

 

 $472,360 

 

 $458,430 

 

11. 

This Petition presents issues involving the Subject Property’s valuation 

for property tax assessment purposes. Petitioner does not believe that this Petition 

presents any issues arising out of “additions” or “losses” as the General Property Tax 

Act, MCL 211.1 et seq. (the “GPTA”), defines those terms, but reserves its right to 

assert issues involving losses should information supporting such issues become 

available. 

12. 

The Subject Property’s 2025 assessment (a) violates the Michigan 

Constitution, the GPTA, and other Michigan law, (b) is based on erroneous principles 

and information, (c) is based on the misapplication of valuation principles, and (d) 

otherwise violates Petitioner’s rights. 

13. 

Petitioner does not assert that the Subject Property’s 2025 assessment 

is not uniform aside from the lack of uniformity resulting from Respondent 

overestimating the Subject Property’s values. 

Conclusion and Request for Relief 

WHEREFORE, Petitioner respectfully requests that this honorable Tribunal 

enter judgment revising the Subject Property’s 2025 assessment to be consistent with 

the values set forth in Paragraph 9 of this Petition and granting Petitioner all other

Page 4

4 

relief to which it is entitled under Michigan law. 

 

 

 

 

 

Respectfully Submitted, 

 

 

 

 

 

 

WILLIAMS, WILLIAMS, RATTNER 

 

 

 

 

 

& PLUNKETT, PC 

 

 

 

 

 

 

 

By: /s/ Jason C. Long 

 

 

 

 

 

 

 

 

 

 Jerome P. Pesick (P29039) 

 

 

 

 

 

 

 Jason C. Long (P59244) 

Dated: May 30, 2025 

 

 

Attorneys for Petitioner

Page 5

Exhibit A

Page 6

L-4400 

Michigan Department of Treasury 

1019 Rov. 1024) 

THIS IS NOT ATAX BILL 

Notice of Assessment, Taxable Valuation, and Property Classification 

Thie for 

ssed 

dor the aur 

of Pubic Act 208 of 1853, Sec. 211.24c and Sec21134c, 

3 amended. This 

I 

8 model assesment nofice 

0 bo used by 1 

ca 3569532" 

FROM: 

PARCEL IDENTIFICATION 

City of Nov) Assessing Dept 

PARCEL CODE NUMBER: 50-22-12-400-060 

Novi, MI 48375 

PROPERTY ADDRESS: 

28175 CABOT DR 

TO: 

0015377 

me 

FET HRI 

036*001*15377****SCH 5-DIGIT 

PRINCIPAL RESIDENCE EXEMPTION 

HAGGERTY CORRIDOR OFFICE CENTRE IV 

9% Exempt 

As “Homeowners Principal Residence": 

0.00% 

39000 COUNTRY CLUB DR 

w 

. 

200% 

FARMINGTON HILLS Mi 48331-3453 

% Exempt 

As “Qualified Agricultural Property” 

- 

% Exempt 

As “MBT industrial Personal”: 

0.00% 

% Exempt 

As “MBT Commercial Personal” 

0.00% 

Exempt As “Qualified Forest property”:|_| Yes x No 

Exempt 

As “Development Property”: 

O Yes x] No 

Legal Description: TIN, REE, SEC 12 OAKLAND COUNTY CONDOMINIUM PLAN NO 1679 HAGGERTY CORRIDOR CORPORATE PARK CONDOMINIUM-PHASE 1 UNIT 41 

34421 P 115 11-24-04 FR O50 

ACCORDING TO MCL 211.34c THIS PROPERTY IS CLASSIFIED AS: 

201 COMMERCIAL-IMPROVED 

CURRENT 

CHANGE FROM 

PRIOR AMOUNT 

| TENTATIVE AMOUNT 

PRIOR YEAR TO 

YEAR: 2024 

YEAR: 2025 

CURRENT YEAR 

1,996,540 

2,058,430 

61,890 

2. ASSESSED VALUE: 

1,996,540 

2,072,360 

75,820 

3. TENTATIVE EQUALIZATION FACTOR: 1.000 

4. STATE EQUALIZED VALUE (SEV): 

1,096,540 | 

2,072,360 

| 

75,820 

5. THERE WAS or WAS NOT A TRANSFER OF OWNERSHIP ON THIS PROPERTY IN 2024: Was Not 

5. ASSESSOR CHANGE REASON:Market Adjustment 

The 2025 Inflation Rate Multiplier is: 1.031 

Questions regarding the Notice of Assessment, Taxable Valuation, and Property Classification may be directed to the following: 

Name 

Telephone Number 

Email Address 

Janeene Ziozios 

(248) 347-0485

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

Haggerty Corridor Office Centre IV, LLC

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

c/o 380 N. Old Woodward Ave.

Ste. 300

City or Town

Birmingham

State

Michigan

ZIP Code

48009

Telephone Number

2486420333

Fax Number

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

jlong@wwrplaw.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Jason

M.I.

C

Last Name

Long

Firm Name (if any)

Williams Williams Rattner & Plunkett, PC

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

380 N Old Woodward Ave

Suite 300

City or Town

Birmingham

State

Michigan

ZIP Code

48009

Telephone Number

248-642-0333

Fax Number

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

jlong@wwrplaw.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]

28175 Cabot Drive

Novi

Michigan

48377

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:

50-22-12-400-060

Classification of Property: Real 

Commercial

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

2072360

Current Taxable Value as established by the Board of Review:

2058430

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

3200000

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

1600000

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/ Jason C. Long

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.