Legends At The Grove LLC, Petitioner Vs. Township Of Pittsfield, Respondent

Page 1

RECEIVED 

ATE 

DEC 29 2005 (a 

MICHIGAN TA 

STATE OF MICHIGAN 

X TRIBUNAL 

COURT OF APPEALS 

Legends at the Grove LLC, 

Petitioner-Appeliant, 

Court of Appeals Case No. 

v 

. 

MTT Docket No. 25-002561 

Pittsfield Township, 

Respondent-Appellee. 

Stewart 1.. Mandell (P33781) 

Alana A. Knox (P85859) 

Jackie J. Cook (P68781) 

Secrest Wardle 

Honigman LLP 

Attorneys for Respondent-Appeliee 

Attorneys for Petitioner- Appellant 

2600 Troy Center Drive 

2290 First National Bldg., 660 Woodward Ave. 

P.O. Box 5025 

Detroit, MI 48226 

Troy, MI 48007-5025 

(313) 465-7420 

(248) 851-9500 

slmandell@honigman.com 

aknox@secrestwardle.com 

jcook@honigman.com 

Notice of Filing Claim of Appeal 

TO: 

Chief Clerk 

Michigan Tax Tribunal 

611 W. Ottawa 

Lansing, MI 48933 

PLEASE TAKE NOTICE that on December 29, 2025, the attached Claim of Appeal was 

filed electronically with the Court of Appeals. 

Respectfully submitted, 

Attorneys for Petitioner- Appellant 

HONIGMAN LLP 

By: /s/ Stewart L. Mandell 

Stewart L. Mandell (P33781)

Page 2

Certificate of Service 

The undersigned states that she is employed by Honigman LLP and on December 29, 2025, 

she served a copy of the Notice of Filing Claim of Appeal and Claim of Appeal upon the Michigan 

Tax Tribunal, by way of hand-delivery to the Michigan Tax Tribunal’s address of 611 W. Ottawa, 

Lansing, MI 48933. 

[s/ Lisa Joseph 

Dated: December 29, 2025 

Lisa Joseph

Page 3

JIS Code: COA 

STATE OF MICHIGAN 

JUDICIAL DISTRICT 

JUDICIAL CIRCUIT 

COUNTY 

IN THE COURT OF APPEALS 

CLAIM OF APPEAL 

CASE NO. 

CIRCUIT 

Michigan Tax Tribunal 

DISTRICT 

pocket No, 25-002561 

PROBATE 

Court address 

Court telephone no. 

Plaintiff s/Pelitioner's name(s) and address(es) 

[¥) appetiant 

Legends at the Grove LLC 

Ul appetiee 

Defendant's/Respondent’s name(s} and address(es) 

[m] Appellant 

Pittsfield Township 

Appelice 

Plaintiff's attorney, bar no., address, and telephone no. 

Stewart L. Mandell {P33781), Jackie J. Cook {P68781) 

Honigman LLP, 2290 First National Building 

660 Woodward Ave., Detroit, M! 48226 

(313) 465-7420 

Defendant's altorney, bar no., address, and telephone no. 

Alana A. Knox {P85859), Secrest Wardle 

2600 Troy Center Drive 

P.O. Box 5025, Troy, MI 48007-5025 

(248) 851-9500 

In the matter of 

Other interested party(ies) of probate matter 

1. 

Legends at the Grove LLC 

Name 

December 15, 2025 

in the Michigan Tax Tribunal 

claims an appeal from a final judgment or final order entered on 

Date 

Court name and number or county 

circuit judge 

[J probate judge 

by 

[district judge 

Court of the State of Michigan, 

[J district court magistrate 

Name of judge or district court magistrate 

2. Bond on appealis 

~~ [lfiled. 

 [Jattached. 

3. (a. The transcript has been ordered, 

[I b. The transcript has been filed. 

¢. No record was made. 

Owaived. 

Bar no, 

[not required.

Page 4

Claim of Appeal 

(9/23) 

oh 

Case No. 25-002561 

[/14. THIS CASE INVOLVES 

[Ja. 

ACONTEST AS TO THE CUSTODY OF A MINOR CHILD. 

[Jb. AN ADULT OR MINOR GUARDIANSHIP UNDER THE ESTATES AND PROTECTED INDIVIDUALS CODE OR 

UNDER THE MENTAL HEALTH CODE. 

Oc. AN INVOLUNTARY MENTAL HEALTH TREATMENT CASE UNDER THE MENTAL HEALTH CODE. 

d. 

ARULING THAT A PROVISION OF THE MICHIGAN CONSTITUTION, A MICHIGAN STATUTE, 

A RULE OR 

REGULATION INCLUDED IN THE MICHIGAN ADMINISTRATIVE CODE, 

OR ANY OTHER ACTION OF THE 

LEGISLATIVE OR EXECUTIVE BRANCH OF STATE GOVERNMENT IS INVALID. 

[J e. AN ADOPTION ORDER UNDER CHAPTER X OF THE PROBATE CODE. 

Jf. 

AFREEDOM OF INFORMATION ACT ISSUE. 

December 29, 2025 

/s/ Stewart L. Mandell 

Date 

AppellantfAttomey signature 

PROOF OF SERVICE 

| certify that copies of this claim of appeal and bond (if required} were served on 

Alana A Knox 

on 

12/29/25 

by 

personal service. 

Wiirst-class mail. 

Name 

Date 

on 

by 

[personalservice. 

[first-class mail. 

Name 

Date 

on 

by 

[personal service. 

first-class mail. 

Name 

Date 

December 29, 2025 

/s/ Lisa Joseph 

Date 

Signatiire

Page 5

Michigan Court of Appeals 

Lower Court/Tribunai: Michigan Tax Tribunal 

Jurisdictional Checklist 

25-002561 

Lower Court Case No. 

case Name: L€GENdS at the Grove LLC v Pittsfield Township 

INSTRUCTIONS: For a ¢ivil claim of appeal, please complete the following statements. 

[SELECT ONE] An appeal of right may be filed because the order is: 

MCR 7.203(A) 

il] 

A final order of the circuit court under MCR 7.202(6). Specify subsection: 

] 

A probate court order that falls within MCR 5.801(A). Specify subsection: 

MI Const, art 6, sec 28; MCL 205.753(1); MCR 7.203(A}(2) 

Appealable as of right by law or court rule, Specify law or rule: 

[SELECT ONE] This claim of appeal is timely because it is being filed: 

MCR 7.204(A) 

Within 21 days from entry of the order appealed from (as identified above). 

Within 21 days of an order deciding a motion for new trial, rehearing, reconsideration, or other relief from 

the order appealed, and the postiudgment motion was filed within 21 days of the order appealed from. 

Ol 

Other: 

INSTRUCTIONS: Please complete the checklist and file with your claim of appeal. 

Failure to file all required documents and requisite fees may result in rejection of 

MCR 7.201(B)(2) 

your claim of appeal. 

A signed claim of appeal. The caption must list all of the parties in each lower court 

MCR 7.204(B)(1) & (D) 

®» 

case appealed. 

bs 

A copy of the order you are appealing (as identified in Jurisdiction section). 

MCR 7.204(C)(1) 

@ 

& 

An official current register of actions from the

Page 6

O

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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

Legends at the Grove LLC, 

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-002561

Township Of Pittsfield,

Respondent.

ORDER OF DISMISSAL

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

The petition was not filed by May 31 or the next business day after the Tribunal offices 

were closed. See MCL 205.735a(6). As such, and inasmuch as the Tribunal has no 

equitable power to waive or otherwise disregard statutory filing requirements and 

deadlines, it has no authority to hear the appeal or grant the relief requested. See 

Sixarp, LLC v Byron Twp, __Mich__; __NW3d__ (2025). 

Therefore,

IT IS ORDERED that the case is DISMISSED.

This order resolves all pending issues and closes the case.

APPEAL RIGHTS

If you disagree with the final decision in this case, you may file a motion for 

reconsideration with the Tribunal or a claim of appeal with the Michigan Court of 

Appeals. 

A motion for reconsideration must be filed with the Tribunal with the required filing fee 

within 21 days from the date of entry of the final decision. Because the final decision 

closes the case, the motion cannot be filed through the Tribunal’s web-based e-filing 

system; it must be filed by mail or personal service. The fee for the filing of such 

motions is $50.00 in the Entire Tribunal and $25.00 in the Small Claims Division, unless 

the Small Claims decision relates to the valuation of property and the property had a 

principal residence exemption of at least 50% at the time the petition was filed or the 

decision relates to the grant or denial of a poverty or disabled veterans exemption and, 

if so, there is no filing fee. You are required to serve a copy of the motion on the 

opposing party by mail or personal service or by email if the opposing party agrees to 

electronic service, and proof demonstrating that service must be submitted with the 

motion. Responses to motions for reconsideration are prohibited and there are no oral 

arguments unless otherwise ordered by the Tribunal.

Page 2

MTT Docket No. 25-002561

Page 2 of 6

Alternatively, you may file a claim of appeal with the Michigan Court of Appeals. If the 

claim is filed within 21 days of the entry of the final decision, it is an “appeal of right.” If 

the claim is filed more than 21 days after the entry of the final decision, it is an “appeal 

by leave.” A copy of the claim of appeal must be filed with the Tribunal to certify the 

record on appeal. There is no certification fee. 

By:___________________________________

Patricia L. Halm, Tribunal Chair

Entered: December 15, 2025

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

Legends at the Grove LLC, 

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-002561

Township Of Pittsfield,

Respondent.

ORDER OF DISMISSAL

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

The petition was not filed by May 31 or the next business day after the Tribunal offices 

were closed. See MCL 205.735a(6). As such, and inasmuch as the Tribunal has no 

equitable power to waive or otherwise disregard statutory filing requirements and 

deadlines, it has no authority to hear the appeal or grant the relief requested. See 

Sixarp, LLC v Byron Twp, __Mich__; __NW3d__ (2025). 

Therefore,

IT IS ORDERED that the case is DISMISSED.

This order resolves all pending issues and closes the case.

APPEAL RIGHTS

If you disagree with the final decision in this case, you may file a motion for 

reconsideration with the Tribunal or a claim of appeal with the Michigan Court of 

Appeals. 

A motion for reconsideration must be filed with the Tribunal with the required filing fee 

within 21 days from the date of entry of the final decision. Because the final decision 

closes the case, the motion cannot be filed through the Tribunal’s web-based e-filing 

system; it must be filed by mail or personal service. The fee for the filing of such 

motions is $50.00 in the Entire Tribunal and $25.00 in the Small Claims Division, unless 

the Small Claims decision relates to the valuation of property and the property had a 

principal residence exemption of at least 50% at the time the petition was filed or the 

decision relates to the grant or denial of a poverty or disabled veterans exemption and, 

if so, there is no filing fee. You are required to serve a copy of the motion on the 

opposing party by mail or personal service or by email if the opposing party agrees to 

electronic service, and proof demonstrating that service must be submitted with the 

motion. Responses to motions for

Page 4

MTT

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Page 1

1

S E C R E S T W A R D L E 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

LEGENDS AT THE GROVE, LLC, 

 

 

Petitioner, 

MTT Docket No. 25-002561 

 

 

Parcel No. L-12-14-300-019 

 

-vs- 

 

 

 

 

 

 

 

PITTSFIELD TOWNSHIP, 

 

 

Respondent. 

_________________________________________________________________________________/ 

 

HONIGMAN LLP 

Stewart L. Mandell (P33781) 

Attorney for Petitioner 

39400 Woodward Ave., Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com 

SECREST WARDLE 

Alana A. Knox (P85859) 

Attorney for Respondent 

2600 Troy Center Drive 

P.O. Box 5025 

Troy, MI 48007-5025 

(248) 851-9500 

aknox@secrestwardle.com 

_________________________________________________________________________________/ 

 

 

RESPONDENT’S ANSWER TO PETITIONER’S 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

 

NOW COMES Respondent, PITTSFIELD TOWNSHIP, by and through its attorneys, 

SECREST WARDLE, and for its Answer to Petitioner’s Entire Tribunal Property Tax Petition, states 

as follows: 

1. 

Answering Paragraph 1, Respondent neither admits nor denies the allegations 

 contained in paragraph 1 for lack of sufficient knowledge or information upon which to form a belief 

and leaves Petitioner to its proofs. 

2. 

Answering paragraph 2, Respondent admits Petitioner is a party in interest and that the 

 property that is the subject of this appeal is identified as Parcel Number: L-12-14-300-019, has an 

address of Freedom Drive and is located in Pittsfield Township, Washtenaw County, Michigan.

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2

S E C R E S T W A R D L E 

Respondent neither admits nor denies the remainder of the allegations contained in paragraph 2 for 

lack of sufficient knowledge or information upon which to form a belief and leaves Petitioner to its 

proofs. 

3. 

Answering paragraph 3, Respondent admits Petitioner is a party in interest and that the 

property that is the subject of this appeal is identified as Parcel Number: L-12-14-300-019, has an 

address of Freedom Drive and is located in Pittsfield Township, Washtenaw County, Michigan. 

Respondent neither admits nor denies the remainder of the allegations contained in paragraph 3 for 

lack of sufficient knowledge or information upon which to form a belief and leaves Petitioner to its 

proofs. 

4. 

Answering paragraph 4, Respondent admits that Pittsfield Township levies and collects 

 property taxes on the subject property under appeal. 

5. 

Answering paragraph 5, Respondent admits that the subject property’s 2025 taxable 

value and assessed value on the Respondent’s assessment roll are as follows: 

PARCEL NUMBER 

TAXABLE VALUE 

ASSESSED VALUE 

L-12-14-300-019 

$26,008,277 

 $26,104,255 

which assessed value will result in a state equalized value in the same amount based upon the tentative 

equalization factor. 

6. 

Answering paragraph 6, Respondent admits that the parcel identified as tax 

 identification number L-12-14-300-019 is 201 commercial improved property. Respondent neither 

admits nor denies the remainder of the allegations contained in paragraph 6 for lack of sufficient 

knowledge or information upon which to form a belief and leaves Petitioner to its proofs. 

7. 

Answering paragraph 7, Respondent neither admits nor denies the allegations 

 contained in paragraph 7 for lack of sufficient knowledge or information upon which to form a belief 

and leaves Petitioner to its proofs.

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3

S E C R E S T W A R D L E 

8. 

Answering paragraph 8, Respondent neither admits nor denies the allegations 

 contained in paragraph 8 for lack of sufficient knowledge or information upon which to form a belief 

and leaves Petitioner to its proofs. 

9. 

Answering paragraph 9, Respondent neither admits nor denies the allegations 

 contained in paragraph 9 for lack of sufficient knowledge or information upon which to form a belief 

and leaves Petitioner to its proofs. 

10. 

Answering paragraph 10, Respondent neither admits nor denies the allegations 

 contained in paragraph 10 for lack of sufficient knowledge or information upon which to form a 

belief and leaves Petitioner to its proofs. 

11. 

Answering paragraph 11, Respondent neither admits nor denies the allegations 

 contained in paragraph 11 for lack of sufficient knowledge or information upon which to form a 

belief and leaves Petitioner to its proofs. 

12. 

Answering paragraph 12, Respondent neither admits nor denies the allegations 

 contained in paragraph 12 for lack of sufficient knowledge or information upon which to form a 

belief and leaves Petitioner to its proofs. 

13. 

Answering paragraph 13, and its subparts (a), (b), (c) and (d), Respondent denies the 

allegations contained therein for the reason that the same is untrue. 

 

WHEREFORE, Respondent, PITTSFIELD TOWNSHIP, denies that Petitioner is entitled to 

the relief it seeks and respectfully requests that the Respondent’s assessments and taxable values of 

the subject property be affirmed or increased, that Petitioner’s Entire Tribunal Property Tax Petition 

be dismissed with prejudice and that Respondent be granted costs and attorney fees so wrongfully 

incurred.

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4

S E C R E S T W A R D L E 

 

 

 

 

 

 

Respectfully submitted, 

SECREST WARDLE 

 

 

 

 

 

 

BY: 

 /s/ Alana E. Knox 

 

 

 

 ALANA E. KNOX (P85859) 

 

 

 

 

 

 

Attorney for Respondent 

 

 

 

 

 

 

2600 Troy Center Drive, P.O. Box 5025 

 

 

 

 

 

 

Troy, Michigan 48007-5025 

Dated: October 20, 2025 

 

 

(248)

Page 5

5

S E C

Page 6

6

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7

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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. 25-002561

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

Township Of Pittsfield (WASHTENAW)

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

Alana

M.I.

E.

Last Name

Knox

Firm Name (if any)

Secrest Wardle

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

2600 Troy Center Drive

PO Box 5025

City or Town

Troy

State

Michigan

ZIP Code

48007

Telephone Number

248-539-2820

Fax Number

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

aknox@secrestwardle.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Alana E. Knox

/s/

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Page 1

1

S E C R E S T W A R D L E 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

LEGENDS AT THE GROVE, LLC, 

 

 

Petitioner, 

MTT Docket No. 25-002561 

 

 

Parcel No. L-12-14-300-019 

 

-vs- 

 

 

 

 

 

 

 

PITTSFIELD TOWNSHIP, 

 

 

Respondent. 

_________________________________________________________________________________/ 

 

HONIGMAN LLP 

Stewart L. Mandell (P33781) 

Attorney for Petitioner 

39400 Woodward Ave., Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com 

SECREST WARDLE 

Alana A. Knox (P85859) 

Attorney for Respondent 

2600 Troy Center Drive 

P.O. Box 5025 

Troy, MI 48007-5025 

(248) 851-9500 

aknox@secrestwardle.com 

_________________________________________________________________________________/ 

 

 

RESPONDENT’S MOTION TO DISMISS FOR LACK OF SUBJECT MATTER 

JURISDICTION 

 

 

NOW COMES Respondent, PITTSFIELD TOWNSHIP, by and through its attorneys, 

SECREST WARDLE, and for its Motion to Dismiss for Lack of Jurisdiction, states as follows: 

1. 

On or about February 14th, 2025, Respondent sent notice to Petitioner via First Class 

Mail of an increased tax assessment on their commercial property, Parcel #L-12-14-300-019. 

(EXHIBIT 1). The address to which notice was sent is the same address in which the past two 

notices were sent, both of which were received and timely paid for by petitioner. 

2. 

On or about June 27, 2025, Petitioner, Legends at the Grove, LLC, untimely filed with 

the Michigan Tax Tribunal its Property Tax Petition challenging the 2025 assessment of

Page 2

2

S E C R E S T W A R D L E 

commercial real property located in Pittsfield Township, Washtenaw County, Michigan, Parcel 

#L-12-14-300-019. 

3. 

MCL 205.735a has long been interpreted as jurisdictional statutes which must be 

complied with in order for a Tax Tribunal to have subject matter jurisdiction over a 

petitioner’s Tax tribunal petition. W.A. Foote Mem. Hospital v. City of Jackson, 262 Mich. 

App. 333 (2004); Electronic Data Sys. Corp., 253 Mich. App. 538, 544 (2002) (After it is 

concluded that a petitioner lacks subject matter jurisdiction under MCL 205.735, a Tax 

Tribunal is “duty-bound” to dismiss petitioner’s claims); see also McLaren Health Care Corp., 

v. Grand Blanc Township, Unreported (Mich. App., 2021). 

4. 

MCL 205.735a expressly states, “jurisdiction of the tribunal over a [tax] assessment 

dispute of real commercial property is invoked by a party in interest by filing a petition on or 

before May 31 of the tax year involved.” MCL 205.735a(6). 

5. 

Petitioner in the instant case failed to timely file their property tax dispute before the 

May 31 deadline in order to properly invoke Michigan Tax Tribunal jurisdiction over their 

petition. Petitioner’s untimely filing deprives the Tribunal of subject matter jurisdiction over 

their petition as required by MCL 205.735a(6), and therefore, dismissal for lack of jurisdiction 

is proper. 

 

WHEREFORE, Respondent, PITTSFIELD TOWNSHIP, respectfully requests that the 

Petitioner’s entire Tribunal Property Tax Petition and this case be dismissed with prejudice and that 

Respondent be granted costs and attorney fees so wrongfully sustained in the defense of this action.

Page 3

3

S E C R E S T W A R D L E 

 

 

 

 

 

 

Respectfully submitted, 

SECREST WARDLE 

 

 

 

 

 

 

BY: 

 /s/ Alana E. Knox 

 

 

 

 ALANA E. KNOX (P85859) 

 

 

 

 

 

 

Attorney for Respondent 

 

 

 

 

 

 

2600 Troy Center Drive, P.O. Box 5025 

 

 

 

 

 

 

Troy, Michigan 48007-5025 

Dated: October 20, 2025 

 

 

(248) 851-9500 

 

PROOF OF SERVICE 

 

I hereby certify that on October 20, 2025, a copy of the foregoing document, Respondent’s 

Motion to Dismiss for Lack of Subject Matter Jurisdiction, was filed electronically with the Michigan 

Tax Tribunal, and was served upon: 

 

HONIGMAN LLP 

Stewart L. Mandell, Esq. 

39400 Woodward Ave., Suite 101 

Bloomfield Hills, MI 48304-5151 

by depositing same in the United States mail with postage fully prepaid thereon. 

/s/ Tamera Briggs 

 

Tamera Briggs 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

(10032394.1)

Page 4

4

S E C R E S T W A R D L E 

EXHIBIT 1

Page 5

From: mail@sf-notifications.com <mail@sf-notifications.com> 

Sent: Thursday, February 6, 2025 9:11 AM 

To: Assessing Email <assessing@pittsfield-mi.gov> 

Subject: You Have Uploaded Files To ShareFile 

CAUTION: This email originated from outside your organization. Exercise caution when opening 

attachments or clicking links, especially from unknown senders. 

 

1

Page 6

Warsha, 

This message is confirmation that you have uploaded the 

following files at 02/06/2025 9:10:38 am 

File Box 

 

 Change Notice - Real Properties 2.pdf 

Size 

57.75 MB 

Date 

02/06/2025 9:10:38 am 

User 

W. Kulkarni 

Click here to change how often ShareFile sends 

emails 

Dates are displayed in UTC -5 

Need help? We're here for you. 

Visit sharefile.com/support and look for “Start chat.” 

2

Page 7

From: Lauren Wilcox <LaurenW@kentcommunications.com> 

Sent: Thursday, February 6, 2025 9:21 AM 

To: Assessing Email <assessing@pittsfield-mi.gov> 

Subject: Upload Received - Pittsfield Twp ACN 

 

CAUTION: This email originated from outside your organization. Exercise caution when 

opening attachments or clicking links, especially from unknown senders. 

Hi, Warsha! 

 

I have received your file with a count of 11,269 notices. Scheduling to mail February 14th, we will process 

for a proof. 

 

Thank you, 

 

Lauren Wilcox / Account Manager 

*** Click here to upload

Page 8

$30Ud

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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. 25-002561

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

Township Of Pittsfield (WASHTENAW)

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

Alana

M.I.

E.

Last Name

Knox

Firm Name (if any)

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

2600 Troy Center Drive

PO Box 5025

City or Town

Troy

State

Michigan

ZIP Code

48007

Telephone Number

248-539-2820

Fax Number

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

aknox@secrestwardle.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Alana E. Knox

/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

9/25/2025

/s/ Lisa Joseph

September 25, 2025

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Legends at the Grove LLC, 

Petitioner, 

- 

o 

0 

MTT Docket No. 5 -09© 7 Sl 

v 

Parcel No. L-12-14-300-019 

Pittsfield Twp., 

Respondent. 

Stewart L. Mandell (P33781) 

Honigman LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

slmandell@honigman.com 

Proof of Service 

Lisa Joseph states that on 9/25/2025 

, she did serve a copy of Petitioner's Petition, 

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

/s/ Lisa Joseph 

Dated: September 25, 2025 

Lisa Joseph 

25-0029

Page 2

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

PITTSFIELD TWP. 

6201 W. MICHIGAN AVENUE 

ANN ARBOR, MI 48108-9721 

ASSESSOR 

PITTSFIELD TWP. 

6201 W. MICHIGAN AVENUE 

ANN ARBOR, MI 48108-9721 

AND BY FIRST-CLASS UNITED STATES MAIL: 

CLERK 

WASHTENAW COUNTY 

PO BOX 8645 

ANN ARBOR, MI 48107-8645 

DIRECTOR OF EQUALIZATION 

WASHTENAW COUNTY 

PO BOX 8645 

ANN ARBOR, MI 48107-8645 

SECRETARY OF SCHOOL BOARD 

ANN ARBOR PUBLIC SCHOOLS 

2555S. STATE STREET 

ANN ARBOR, MI 48104 

STATE TREASURER 

MICHIGAN DEPARTMENT OF TREASURY 

TREASURY BUILDING 

430 W. ALLEGAN ST. 

LANSING, MI 48922 

25-0090

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Page 1

25-0029

STATE OF MICHIGAN

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS

MICHIGAN TAX TRIBUNAL

Legends at the Grove LLC,

Petitioner,

v.

Pittsfield Twp.,

Respondent.

MTT Docket No. ________

Parcel No. L-12-14-300-019

Stewart L. Mandell (P33781)

Honigman LLP

Attorneys for Petitioner

39400 Woodward Avenue, Suite 101

Bloomfield Hills, MI 48304-5151

(313) 465-7420

slmandell@honigman.com

Petition

Legends at the Grove LLC (“Petitioner”), through its attorneys, Honigman LLP, says:

1.

Petitioner's principal office address is 6400 Telegraph Rd., Suite 2500, Bloomfield

Hills, MI 48301-1728.

2.

Petitioner is a party in interest with respect to property taxes on the property

identified by tax parcel number L-12-14-300-019 ("Petitioner's Property"), known as Legends

Grove.

The Respondent’s records identify Petitioner’s Property as being on Freedom Drive.

Petitioner’s Property is located in Pittsfield Twp., Washtenaw County, Michigan.

3.

Petitioner is a party in interest with respect to property taxes on tax parcel number

L-12-14-300-019 ("Petitioner's Property"), which has a property known as Legends Grove. The

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2

Respondent’s records identify Petiitoner’s Property as being on Freedom Drive.

Petitioner’s

Property is located in Pittsfield Twp., located in Washtenaw County, Michigan.

4.

Respondent, Pittsfield Twp., assesses and collects property taxes on Petitioner's

Property.

5.

In 2025, Respondent determined the taxable value of Petitioner's Property to be

$26,008,277 and assessed Petitioner's Property at $26,104,255, which has resulted in a state

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

6.

Petitioner's Property is classified as commercial improved.

On the subject

December 31, 2024 tax day, Petitioner’s commercial property was still under construction.

Petitioner's Property has been designed to be used for commercial purposes.

To the best

knowledge of the undersigned, the multifamily units comprising Petitioner’s Property are not

subject to a governmental regulatory agreement or a subsidy.

7.

This matter involves issues relating to: (a) valuation, (b) assessment, (c) taxable

value, (d) due process, (e) uniformity and (f) equal protection.

8.

No board of review protest was required for Petitioner’s Property.

9.

Only after June 2, 2025, did Petitioner learn of the 2025 assessment of Petitioner’s

Property.

10.

This year, the true cash value of Petitioner’s Property increased by approximately

$40 million. Had Petitioner received the assessment notice and been made aware of this enormous

increase, Petitioner would have appealed the assessment prior to June of this year.

11.

Under the due process and equal protection guarantees of the Constitution of the

United States, the Michigan Constitution, and precedent that includes and is not limited to

Parkview Mem Ass’n v City of Livonia, 183 Mich App 116; 454 NW2d 169 (1990) and Michigan

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3

State University v City of Lansing, unpublished opinion per curiam of the Court of Appeals, issued

February 15, 2005 (Docket No. 250813), the Tribunal has jurisdiction over this case.

12.

In Michigan State University v City of Lansing, unpublished opinion per curiam of

the Court of Appeals, issued February 15, 2005 (Docket No. 250813), the taxpayer was entitled to

pursue its Tribunal appeal where it filed its Tribunal Petition within thirty-five days of receiving

its summer tax bill in July because that was the first notice it received of the assessment. Here,

Petitioner also is filing this Petition within thirty-five days of receiving notice of the assessment

and therefore Petitioner is entitled to pursue this appeal.

13.

The 2025 assessment, including state equalized value and taxable value, imposed

on Petitioner's Property, and the taxes to be levied and collected thereon, are invalid and unlawful

for the reasons that:

(a)

The assessment, including state equalized value and/or taxable value,

exceeds the amount permitted by the Michigan Constitution and applicable

statutes;

(b)

The assessment, including state equalized value and/or taxable value, is at

a higher percentage of true cash value than permissible under the Michigan

Constitution and applicable statutes;

(c)

The assessment, including taxable value and/or 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 assessment, including state equalized value and/or taxable value, and

the mode of assessment adopted by Respondent, discriminate against

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4

Petitioner and deny Petitioner its constitutional rights to uniformity, equal

protection, and due process of law.

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

2025 assessed value and state equalized value from $26,104,255 to $15,500,000; (ii) reducting the

2025 taxable value of Petitioner's Property from $26,008,277 to $15,500,000; (iii) requiring

payment to Petitioner of the refunds attributable to such reductions, plus interest and costs; and

(iv) awarding Petitioner any other relief to which it is entitled.

Dated: June 27, 2025

Respectfully submitted,

HONIGMAN LLP

Attorneys for Petitioner

By:

Stewart L. Mandell (P33781)

39400 Woodward Avenue, Suite 101

Bloomfield Hills, MI 48304-5151

(313) 465-7420

slmandell@honigman.com

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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

Legends at the Grove LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-002561

Township Of Pittsfield, 

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: August 20, 2025

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

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Page 1

25-0029

STATE OF MICHIGAN

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS

MICHIGAN TAX TRIBUNAL

Legends at the Grove LLC,

Petitioner,

v.

Pittsfield Twp.,

Respondent.

MTT Docket No. ________

Parcel No. L-12-14-300-019

Stewart L. Mandell (P33781)

Honigman LLP

Attorneys for Petitioner

39400 Woodward Avenue, Suite 101

Bloomfield Hills, MI 48304-5151

(313) 465-7420

slmandell@honigman.com

Petition

Legends at the Grove LLC (“Petitioner”), through its attorneys, Honigman LLP, says:

1.

Petitioner's principal office address is 6400 Telegraph Rd., Suite 2500, Bloomfield

Hills, MI 48301-1728.

2.

Petitioner is a party in interest with respect to property taxes on the property

identified by tax parcel number L-12-14-300-019 ("Petitioner's Property"), known as Legends

Grove.

The Respondent’s records identify Petitioner’s Property as being on Freedom Drive.

Petitioner’s Property is located in Pittsfield Twp., Washtenaw County, Michigan.

3.

Petitioner is a party in interest with respect to property taxes on tax parcel number

L-12-14-300-019 ("Petitioner's Property"), which has a property known as Legends Grove. The

Page 2

2

Respondent’s records identify Petiitoner’s Property as being on Freedom Drive.

Petitioner’s

Property is located in Pittsfield Twp., located in Washtenaw County, Michigan.

4.

Respondent, Pittsfield Twp., assesses and collects property taxes on Petitioner's

Property.

5.

In 2025, Respondent determined the taxable value of Petitioner's Property to be

$26,008,277 and assessed Petitioner's Property at $26,104,255, which has resulted in a state

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

6.

Petitioner's Property is classified as commercial improved.

On the subject

December 31, 2024 tax day, Petitioner’s commercial property was still under construction.

Petitioner's Property has been designed to be used for commercial purposes.

To the best

knowledge of the undersigned, the multifamily units comprising Petitioner’s Property are not

subject to a governmental regulatory agreement or a subsidy.

7.

This matter involves issues relating to: (a) valuation, (b) assessment, (c) taxable

value, (d) due process, (e) uniformity and (f) equal protection.

8.

No board of review protest was required for Petitioner’s Property.

9.

Only after June 2, 2025, did Petitioner learn of the 2025 assessment of Petitioner’s

Property.

10.

This year, the true cash value of Petitioner’s Property increased by approximately

$40 million. Had Petitioner received the assessment notice and been made aware of this enormous

increase, Petitioner would have appealed the assessment prior to June of this year.

11.

Under the due process and equal protection guarantees of the Constitution of the

United States, the Michigan Constitution, and precedent that includes and is not limited to

Parkview Mem Ass’n v City of Livonia, 183 Mich App 116; 454 NW2d 169 (1990) and Michigan

Page 3

3

State University v City of Lansing, unpublished opinion per curiam of the Court of Appeals, issued

February 15, 2005 (Docket No. 250813), the Tribunal has jurisdiction over this case.

12.

In Michigan State University v City of Lansing, unpublished opinion per curiam of

the Court of Appeals, issued February 15, 2005 (Docket No. 250813), the taxpayer was entitled to

pursue its Tribunal appeal where it filed its Tribunal Petition within thirty-five days of receiving

its summer tax bill in July because that was the first notice it received of the assessment. Here,

Petitioner also is filing this Petition within thirty-five days of receiving notice of the assessment

and therefore Petitioner is entitled to pursue this appeal.

13.

The 2025 assessment, including state equalized value and taxable value, imposed

on Petitioner's Property, and the taxes to be levied and collected thereon, are invalid and unlawful

for the reasons that:

(a)

The assessment, including state equalized value and/or taxable value,

exceeds the amount permitted by the Michigan Constitution and applicable

statutes;

(b)

The assessment, including state equalized value and/or taxable value, is at

a higher percentage of true cash value than permissible under the Michigan

Constitution and applicable statutes;

(c)

The assessment, including taxable value and/or 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 assessment, including state equalized value and/or taxable value, and

the mode of assessment adopted by Respondent, discriminate against

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4

Petitioner and deny Petitioner its constitutional rights to uniformity, equal

protection, and due process of law.

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

2025 assessed value and state equalized value from $26,104,255 to $15,500,000; (ii) reducting the

2025 taxable value of Petitioner's Property from $26,008,277 to $15,500,000; (iii) requiring

payment to Petitioner of the refunds attributable to such reductions, plus interest and costs; and

(iv) awarding Petitioner any other relief to which it is entitled.

Dated: June 27, 2025

Respectfully submitted,

HONIGMAN LLP

Attorneys for Petitioner

By:

Stewart L. Mandell (P33781)

39400 Woodward Avenue, Suite 101

Bloomfield Hills, MI 48304-5151

(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

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

Legends at the Grove LLC

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

6400 Telegraph Road

Suite 2500

City or Town

Bloomfield Hills

State

Michigan

ZIP Code

48301

Telephone Number

2485668300

Fax Number

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

ljoseph@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

Detroit

State

Michigan

ZIP Code

48226

Telephone Number

313-465-7420

Fax Number

313-465-7421

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

slmandell@honigman.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]

Michigan

Taxing Authority (City or Township)

Township Of Pittsfield (WASHTENAW)

County

Washtenaw

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:

L-12-14-300-019

Classification of Property: Real 

Commercial

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

26104255

Current Taxable Value as established by the Board of Review:

26008277

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

31000000

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

15500000

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/ Stewart L. Mandell

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