Harborside Residences LLC Petitioner Vs. City Of Detroit 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

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

PROCEDURE

Harborside Residences LLC,

Petitioner,

v

 

 

City of Detroit,

Respondent.

 MTT Docket No. 26-001127

Please be advised that 26-001127 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covered by the order will not be published.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.

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MTT Docket No. 26-001127

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 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

Page 3

MTT

Page 4

STATE

Page 5

MT

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

Harborside Residences LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 26-001127

City of Detroit,

Respondent.

ORDER SETTING ASIDE DEFAULT

The Tribunal has considered the file in this case and finds that Respondent was held in 

default on July 27, 2026, and the default has been timely cured. The documents curing 

the default can be reviewed through the docket search function on the Tribunal’s 

website at www.michigan.gov/taxtrib by inputting the docket number and clicking on the 

document link next to the line item entry for the documents. Therefore,

IT IS ORDERED that the Default is SET ASIDE.

By: /s/ Patricia L. Halm

Entered: August 19, 2026

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

Page 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

Harborside Residences LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 26-001127

City of Detroit,

Respondent.

ORDER SETTING ASIDE DEFAULT

The Tribunal has considered the file in this case and finds that Respondent was held in 

default on July 27, 2026, and the default has been timely cured. The documents curing 

the default can be reviewed through the docket search function on the Tribunal’s 

website at www.michigan.gov/taxtrib by inputting the docket number and clicking on the 

document link next to the line item entry for the documents. Therefore,

IT IS ORDERED that the Default is SET ASIDE.

By: /s/ Patricia L. Halm

Entered: August 19, 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

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 AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

HARBORSIDE RESIDENCES, LLC, 

 

Petitioner, 

v. 

 

 

 

 

 

 

 

Docket No. 26-001127 

 

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: July 30, 2026 

 

PROOF OF SERVICE 

 

On July 30, 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: July 30, 2026 

 

Detroit, Michigan 48226

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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. 26-001127

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/

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

Harborside Residences LLC,

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 26-001127

City of Detroit,

Respondent.

ORDER OF DEFAULT

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

Respondent has failed to file an answer. As such, Respondent must file and serve an 

answer to the petition and file proof demonstrating service of the answer within 14 days 

of the entry of this order. See TTR 235 and 227. Tribunal rules and information on 

Entire Tribunal answers can be found on our website at www.michigan.gov/taxtrib. 

Therefore,

IT IS ORDERED that Respondent is HELD IN DEFAULT.

IT IS FURTHER ORDERED that the defaulted party shall cure the default, as indicated 

above, within 14 days of the entry of this order.1 

Failure to comply with this order will result in the defaulted party being required to file a 

motion to set aside the default (with appropriate filing fee).

By: /s/ Patricia L. Halm

Entered: July 27, 2026

1 “A submission by mail is considered filed on the date indicated by the United States Postal Service 

postmark on the envelope containing the submission. A submission without a postmark or with an illegible 

postmark is considered filed on the date the submission is received by the tribunal. A submission by 

commercial delivery service is considered filed on the date the submission is given to the commercial 

service for delivery to the tribunal as indicated by the receipt date on the package containing the 

submission. A submission by personal service is considered filed on the date the submission is received. 

A submission through the tribunal’s e-filing system by 11:59 p.m. on a business day is considered filed on 

that business day. A submission by email to the email address designated by the tribunal by 11:59 p.m. 

on a business day is considered filed on that business day. A submission on a Saturday, a Sunday, or a 

holiday is considered filed on the following business day, as provided by section 35a of the tax tribunal 

act, MCL 205.735a.” TTR 225(5).

Page 2

MTT Docket No. 26-001127

Page 2 of 2

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

Harborside Residences LLC,

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 26-001127

City of Detroit,

Respondent.

ORDER OF DEFAULT

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

Respondent has failed to file an answer. As such, Respondent must file and serve an 

answer to the petition and file proof demonstrating service of the answer within 14 days 

of the entry of this order. See TTR 235 and 227. Tribunal rules and information on 

Entire Tribunal answers can be found on our website at www.michigan.gov/taxtrib. 

Therefore,

IT IS ORDERED that Respondent is HELD IN DEFAULT.

IT IS FURTHER ORDERED that the defaulted party shall cure the default, as indicated 

above, within 14 days of the entry of this order.2 

Failure to comply with this order will result in the defaulted party being required to file a 

motion to set aside the default (with appropriate filing fee).

By: /s/ Patricia L. Halm

Entered: July 27, 2026

2 “A submission by mail is considered filed on the date indicated by the United States Postal Service 

postmark on the envelope containing the submission. A submission without a postmark or with an illegible 

postmark is considered filed on the date the submission is received by the tribunal. A submission by 

commercial delivery service is considered filed on the date the submission is given to the commercial 

service for delivery to the tribunal as indicated by the receipt date on the package containing the 

submission. A submission by personal service is considered filed on the date the submission is received. 

A submission through the tribunal’s e-filing system by 11:59 p.m. on a business day is considered filed on 

that business day. A submission by email to the email address designated by the tribunal by 11:59 p.m. 

on a business day is considered filed on that business day. A submission on a Saturday, a Sunday, or a 

holiday is considered filed on the following business day, as provided by

Page 4

MTT

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Page 1

26-0009 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Harborside Residences, LLC, 

Petitioner, 

v. 

City of Detroit, 

Respondent. 

MTT Docket No. ________ 

Parcel No. 13000114.003 

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 

Harborside Residences, 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 13000114.003 ("Petitioner's Property"), with an address of 3500 E. Jefferson, 

Detroit, MI, located in Wayne County. 

2.

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

Property.

Page 2

2 

75616932.1 

3.

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

$574,984 and assessed Petitioner's Property at $2,759,100, which will result in a state equalized 

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

4.

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. 

5.

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

constitutionally required equal protection, due process, and uniformity. 

6.

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

7.

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 

75616932.1 

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

2026 assessed values and state equalized values from $2,759,100, to $1,200,000, 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

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

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 Residences 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)

39400 Woodward Avenue

Suite 101

City or Town

Bloomfield Hills

State

Michigan

ZIP Code

48304

Telephone Number

313-465-7420

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:

13000114.003

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:

2759100

Current Taxable Value as established by the Board of Review:

574984

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

2400000

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

1200000

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: 26051986163005

Supporting Waiver Documents:

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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 Residences LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-001127

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

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 & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Harborside Residences, LLC, 

Petitioner, 

i 

MTT Docket No. A lo -C0O [A 7 

v. 

Parcel No. 13000114.003 

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 May 

Sh 9 

/ 2b 

, she did serve a copy of Petitioner's 

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

5) Fon pec 

LisaJoseph 

7 

7 

26-0009 

75616932.1

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 

26-0025 

75616932.1

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Docket #: 26-001127

Party Filing Document

Party Filing Document: 

 Petitioner

 Petitioner

 

 

If 'other', Identify: 

File

Document Type: 

 

 

fuFile:

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26-0009 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Harborside Residences, LLC, 

Petitioner, 

v. 

City of Detroit, 

Respondent. 

MTT Docket No. ________ 

Parcel No. 13000114.003 

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 

Harborside Residences, 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 13000114.003 ("Petitioner's Property"), with an address of 3500 E. Jefferson, 

Detroit, MI, located in Wayne County. 

2.

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

Property.

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75616932.1 

3.

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

$574,984 and assessed Petitioner's Property at $2,759,100, which will result in a state equalized 

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

4.

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. 

5.

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

constitutionally required equal protection, due process, and uniformity. 

6.

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

7.

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.

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75616932.1 

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

2026 assessed values and state equalized values from $2,759,100, to $1,200,000, 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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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 Residences 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)

39400 Woodward Avenue

Suite 101

City or Town

Bloomfield Hills

State

Michigan

ZIP Code

48304

Telephone Number

313-465-7420

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

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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:

13000114.003

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:

2759100

Current Taxable Value as established by the Board of Review:

574984

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

2400000

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

1200000

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.

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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: 26051986163005

Supporting Waiver Documents:

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