Michigan

Harborside Marina LLC Petitioner Vs. City Of Detroit Respondent

Petitioner: Harborside Marina LLC
Respondent: City Of Detroit

Case overview

Docket number: 26-001130-TT
Status: Ready Sched Prehearing Date Certain
CaseType: ET Property
Division: ET
County: Wayne
Judge: No judge assigned

Docket history

Line #	Subject	Filer	Line Ref	Enter Date/Post Mark	Fee	Related Item
8	Prehearing General Call	Not recorded	Not recorded	09/01/2026	Not recorded	Download
7	Answer was received	RESP	Not recorded	08/04/2026	Not recorded	Download
Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Download
6	Documentation	PET	Not recorded	05/27/2026	Not recorded	Download
5	Petition has been verified	PET	1	07/22/2026	Not recorded	Download
Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Download
4	Notice of Docket Number ET	Not recorded	Not recorded	07/22/2026	Not recorded	Download
3	Proof of Service of Misc Documents was received.	Not recorded	Not recorded	05/20/2026	Not recorded	Download
Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Download
2	Amended Petition	Not recorded	Not recorded	05/20/2026	Not recorded	Download
Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Download
1	A petition was received.	PET	Not recorded	05/19/2026	$600.00	Download
Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Not recorded	Download

Documents

Prehearing_General_Call.2026-09-01_11-45-36.pdfRead complete document text →

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

NOTICE OF AUGUST 2- 13, 2027 PREHEARING GENERAL CALL AND ORDER OF

PROCEDURE

Harborside Marina LLC,

Petitioner,

City of Detroit,

Respondent.

MTT Docket No. 26-001130

Please be advised that 26-001130 has been placed on a two-week Prehearing General

Call commencing August 02, 2027. Unless ordered otherwise, parties will be notified at

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Protective Order will be published.

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

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

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

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

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

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

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

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

of the Tribunal’s website.

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

website for more information.

Page 2

MTT Docket No. 26-001130

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 April 5, 2027. 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 April 5, 2027. 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

April 5, 2027, which means all discovery has been requested, all Motions to Compel

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

date. 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

August 2, 2027, which means all discovery has been requested, all Motions to Compel

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

date. “Post-Valuation Disclosure” discovery is

Page 3

MTT

Page 4

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Harbortown Marina LLC MTT# 26-001130 answer.pdfRead complete document text →

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Page 1

1 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

HARBORTOWN MARINA, LLC, 

 

Petitioner, 

v. 

 

 

 

 

 

 

 

Docket No. 26-001130 

 

CITY OF DETROIT, 

 

 

 

 

 

 

 

Respondent. 

________________________________/ 

 

ANSWER 

 

 

RESPONDENT, CITY OF DETROIT, for its Answer to the Petition filed in this matter 

states as follows: 

1. Respondent admits. 

2. Respondent admits. 

3. Respondent admits. 

4. Respondent admits. 

5. Respondent admits only that Petitioner’s instant Tax Tribunal appeal alleges issues 

involving valuation, assessment, due process equal protection, and uniformity, however, 

Respondent denies that any such allegations have merit. 

6. Respondent admits. 

7. Respondent denies as untrue. 

AFFIRMATIVE DEFENSES 

Respondent further asserts that Petitioner’s claims are barred, in whole or in part, by: 

1. Petitioner’s claims are barred by the applicable statute of limitations.

Page 2

2 

 

2. Petitioner has failed to state a claim for which relief may be granted. 

3. This Tribunal lacks subject matter jurisdiction. 

WHEREFORE, Respondent City of Detroit respectfully requests that this Honorable 

Tribunal dismiss the petition in this matter and award costs and attorney fees. 

 

 

 

 

Respectfully Submitted, 

 

 

 

 

 

/s/ Kevin C. Richard 

 

 

 

 

 

Kevin C. Richard (P43417) 

 

 

 

 

 

Mary Beth Cobbs (P40080) 

 

 

 

 

 

City of Detroit Law Department 

 

 

 

 

 

Coleman A. Young Municipal Center 

 

 

 

 

 

2 Woodward Avenue, Suite 500 

 

 

 

 

 

Detroit, Michigan 48226 

 

 

 

 

 

(313) 237-3061 

Dated: August 4, 2026 

 

PROOF OF SERVICE 

 

On August 4, 2026, I served by first class mail and email a copy of 

Respondent’s Answer w/Affirmative Defenses in the instant matter to: 

 

Stewart L. Mandell 

Honigman LLP 

2290 First National Building 

660 Woodward Avenue 

Detroit, Michigan 48226 

slmandell@honigman.com 

 

I declare that the statement above is true to the best of my information, 

knowledge and belief. 

 

 

 

 

 

/s/ Kevin C. Richard 

 

 

 

 

Kevin C. Richard (P43417) 

 

 

 

 

Senior Assistant Corporation Counsel 

 

 

 

 

City of Detroit Law Department 

 

 

 

 

Coleman A. Young Municipal Center 

 

 

 

 

2 Woodward Avenue, Suite 500 

Dated: August 4, 2026 

 

Detroit, Michigan 48226

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EntireTribunalCaseISAnswer.pdfRead complete document text →

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MTT DOCKET NO. 26-001130

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government

City of Detroit (Wayne)

First Name

M.I.

Last Name

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

City or Town

State

ZIP Code

Telephone Number

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

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Kevin

M.I.

C

Last Name

Richard

Firm Name (if any)

City of Detroit Law Department

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

2 Woodward Avenue, Suite 500

City or Town

Detroit

State

 Michigan

ZIP Code

48226

Telephone Number

3132373061

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

richkc@detroitmi.gov

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

Respondent or Authorized Attorney/Representative’s Signature: 

Kevin C. Richard

/s/

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26-001130.pdfRead complete document text →

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Page 1

RECEIVED 

A 

STATE OF MICHIGAN 

MAY 27 2026 60) 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

MICHIGAN TAX TRIBUNAL 

Harbortown Marina LLC, 

Petitioner, 

MTT Docket No. 26-001130 

Vv. 

Parcel No. 13000114.001 

City of Detroit, 

Respondent. 

Stewart L. Mandell (P33781) 

Honigman LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7420 

slmandell@honigman.com 

Proof of Service 

Lisa Joseph states that on 

Slat ob 

, she did serve 

a copy of Petitioner's 

Amended Petition, with docket number, upon the parties named on the attached list. 

/3/ Aanlpaoh 

Lis¥ J oseph 

/

Page 2

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

DETROIT 

804 CAYMC, 2 WOODWARD AVENUE 

DETROIT, MI 48226 

ASSESSOR 

DETROIT 

804 CAYMC, 2 WOODWARD AVENUE 

DETROIT, MI 48226 

AND BY FIRST-CLASS UNITED STATES MAIL: 

CLERK 

WAYNE COUNTY 

CAYMC, 2 WOODWARD AVENUE #211 

DETROIT, MI 48226 

DIRECTOR OF EQUALIZATION 

WAYNE COUNTY 

500 GRISWOLD ST. 21ST FLOOR 

DETROIT, MI 48226 

SECRETARY OF SCHOOL BOARD 

DETROIT PUBLIC SCHOOLS 

7321 2ND AVENUE, 14TH FLOOR 

DETROIT, MI 48202-4050 

STATE TREASURER 

MICHIGAN DEPARTMENT OF TREASURY 

TREASURY BUILDING 

430 W. ALLEGAN ST. 

LANSING, MI 48922 

26-0026

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Petition 2026 (AV Only) - Harbortown Marina Detroit.pdfRead complete document text →

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Page 1

26-0009 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Harborside Marina LLC, 

Petitioner, 

v. 

City of Detroit, 

Respondent. 

MTT Docket No. ________ 

Parcel No. 13000114.001 

Stewart L. Mandell (P33781) 

Honigman LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7420 

slmandell@honigman.com

Petition 

Harbortown Marina LLC (“Petitioner”), through its attorneys, HONIGMAN LLP, says: 

1.

Petitioner's principal office address is 6021 S. Syracuse Way, Suite 100, 

Greenwood Village, CO 80111. Petitioner is a party in interest with respect to property taxes on 

tax parcel number 13000114.001 ("Petitioner's Property"), with an address of 3450 E. Jefferson, 

Detroit, MI, located in Wayne County. 

2.

Respondent, City of Detroit, assesses and collects property taxes on Petitioner's 

Property.

Page 2

75616921.1

In 2026, Respondent determined the taxable value of Petitioner's Property to be

$144,581 and assessed Petitioner's Property at $1,534,500, which will result in a state equalized

value in the same amount based upon the tentative equalization factor.

Petitioner's Property is classified as commercial real. Petitioner's Property is

presently used or available for use for commercial purposes. Petitioner believes that Petitioner's

Property was originally designed to be used for commercial purposes.

This case involves issues relating to: (a) valuation, (b) assessment, and (c)

constitutionally required equal protection, due process, and uniformity.

No March Board of Review protest was required for Petitioner’s Property.

The 2026 assessment imposed on Petitioner's Property is invalid and unlawful for

the reasons that:

(a)

The 2026 assessment, including state equalized value, exceeds the amount

permitted by the Michigan Constitution and applicable statutes;

(b)

The 2026 assessment, including state equalized value, is at a higher

percentage of true cash value than permissible under the Michigan Constitution and applicable

statutes;

(c)

The 2026 assessment, including state equalized value, is based upon an

erroneous determination of the true cash value of that portion of Petitioner's Property that is taxable

under Michigan law, and is based upon the application of wrong principles; and

(d)

The 2026 assessment, including state equalized value, and the mode of

assessment adopted by Respondent, discriminate against Petitioner and deny Petitioner its

constitutional rights to uniformity, equal protection, and due process of law.

Page 3

3 

75616921.1 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order: (i) reducing the 

2026 assessed values and state equalized values from $1,534,500, to $300,000, and (ii) awarding 

Petitioner any other relief to which it is entitled. 

Dated: May 19, 2026

Respectfully submitted, 

HONIGMAN LLP 

Attorneys for Petitioner 

By: _______________________________________ 

Stewart L. Mandell (P33781) 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7420 

slmandell@honigman.com

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EntireTribunalCaseISPetition.pdfRead complete document text →

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Petitioner

MTT DOCKET NO. 

 

Section 1: Petitioner’s Contact Information

Filer type: 

Organization 

Local Unit of Government

First Name

M.I.

Last Name/Company Name

Harborside Marina LLC

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

6021 S. Syracuse Way

Suite 100

City or Town

Greenwood Village

State

Colorado

ZIP Code

80111

Telephone Number

3134657420

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

slmandell@honigman.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Stewart

M.I.

Last Name

Mandell

Firm Name (if any)

Honigman LLP

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

2290 First National Building

660 Woodward Avenue

City or Town

Detriot

State

Michigan

ZIP Code

48226

Telephone Number

3134657420

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

slmandell@honigman.com

 

Section 3: Issue 

Please designate one: 

Valuation 

 

Section 4: Subject Property Information 

How many parcels are you 

appealing?

1

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

3500 E Jefferson

Detroit

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48226

Taxing Authority (City or Township)

City of Detroit (Wayne) 

County

Wayne

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.)

N/A

 

 

Section 5: Check which of the following you are appealing (check all that apply) 

True Cash and Taxable Values

If “Other”, please explain:

 

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

13000114.001

Classification of Property: Real (check one)

Commercial (check one)

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

1534500

Current Taxable Value as established by the Board of Review:

144581

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

600000

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

300000

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

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.

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

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/ Stewart L. Mandell

Payment Information

Amount: 600

Success: True

Message: ""

Waiver Code:

Transaction Number: 26051986164771

Supporting Waiver Documents:

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ET_Notice_of_Docket_Number.2026-07-22_07-26-26.pdfRead complete document text →

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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

Harborside Marina LLC,

Petitioner,

MICHIGAN TAX TRIBUNAL

MTT Docket No.: 26-001130

City of Detroit,

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 22, 2026

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

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Harborside Marina - POS 26-001130.pdfRead complete document text →

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Harborside Marina LLC, 

Petitioner, 

MTT Docket No. A Oo / 

) 3 @} 

Ve 

Parcel No. 13000114.001 

City of Detroit, 

Respondent. 

Stewart L. Mandell (P33781) 

Honigman LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7420 

slmandell@honigman.com 

Proof of Service 

Lisa Joseph states that on _ 5 ( 9 

/ 2b 

she did serve a copy of Petitioner's Petition, 

with docket number, upon the parties named on the attached list. 

Js) 

Fon 

Vrocoh 

"Lisa Joseph 

26-0009 

75616921.1

Page 2

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

DETROIT 

804 CAYMC, 2 WOODWARD AVENUE 

DETROIT, MI 48226 

ASSESSOR 

DETROIT 

804 CAYMC, 2 WOODWARD AVENUE 

DETROIT, MI 48226 

AND BY FIRST-CLASS UNITED STATES MAIL: 

CLERK 

WAYNE COUNTY 

CAYMC, 2 WOODWARD AVENUE #211 

DETROIT, MI 48226 

DIRECTOR OF EQUALIZATION 

WAYNE COUNTY 

500 GRISWOLD ST. 21ST FLOOR 

DETROIT, MI 48226 

SECRETARY OF SCHOOL BOARD 

DETROIT PUBLIC SCHOOLS 

7321 2ND AVENUE, 14TH FLOOR 

DETROIT, MI 48202-4050 

STATE TREASURER 

MICHIGAN DEPARTMENT OF TREASURY 

TREASURY BUILDING 

430 W. ALLEGAN ST. 

LANSING, MI 48922 

26-0026 

75616921.1

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MITAT_SubsequentFiling.pdfRead complete document text →

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Page 1

1 of 1

Docket #: 26-001130

Party Filing Document

Party Filing Document: 

 Petitioner

 Petitioner

 

 

If 'other', Identify: 

File

Document Type: 

 

 

fuFile:

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Amended Petition 2026 (AV Only) - Harbortown Marina Detroit.pdfRead complete document text →

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Page 1

26-0009 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Harbortown Marina LLC, 

Petitioner, 

v. 

City of Detroit, 

Respondent. 

MTT Docket No. ________ 

Parcel No. 13000114.001 

Stewart L. Mandell (P33781) 

Honigman LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7420 

slmandell@honigman.com

Amended Petition 

Harbortown Marina LLC (“Petitioner”), through its attorneys, HONIGMAN LLP, says: 

1.

Petitioner's principal office address is 6021 S. Syracuse Way, Suite 100, 

Greenwood Village, CO 80111. Petitioner is a party in interest with respect to property taxes on 

tax parcel number 13000114.001 ("Petitioner's Property"), with an address of 3450 E. Jefferson, 

Detroit, MI, located in Wayne County. 

2.

Respondent, City of Detroit, assesses and collects property taxes on Petitioner's 

Property. 

26-001130

Page 2

75616921.2