Legends At The Grove LLC Petitioner Vs. Township Of Pittsfield Respondent
- Petitioner
- Legends At The Grove LLC
- Respondent
- Township Of Pittsfield
Case overview
- Docket number
- 26-000753-TT
- Status
- Ready Sched Prehearing Date Certain
- CaseType
- ET Property
- Division
- ET
- County
- Washtenaw
- Judge
- No judge assigned
Docket history
| Line # | Subject | Filer | Line Ref | Enter Date/Post Mark | Fee | Related Item |
|---|---|---|---|---|---|---|
| 7 | Stipulated Sub of Counsel | Not recorded | Not recorded | 10/13/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 6 | Prehearing General Call | Not recorded | Not recorded | 06/16/2026 | Not recorded | Download |
| 5 | Petition has been verified | PET | 1 | 06/08/2026 | 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 | 06/08/2026 | Not recorded | Download |
| 3 | Answer was received | Not recorded | Not recorded | 05/26/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 2 | Proof of service of petition was received. | Not recorded | Not recorded | 05/19/2026 | Not recorded | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
| 1 | A petition was received. | PET | Not recorded | 05/06/2026 | $600.00 | Download |
| Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Not recorded | Download |
Documents
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Page 1
STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Legends at the Grove LLC, Petitioner, v Pittsfield Township, Respondent. MTT Docket No. 26-000753 _____________________________________________________________________________/ LAURA M. HALLAHAN (P42101) HALLAHAN & ASSOCIATES, P.C. Attorney for Petitioner 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302 (248) 731-3089 ALANA E. KNOX (P 85859) SECREST WARDLE Attorney for Respondent 2600 Troy Center Drive P.O. Box 5025 Troy, MI 48007-5025 (248) 851-9500 _____________________________________________________________________________/ PETITIONER’S SUBSTITUTION OF AUTHORIZED REPRESENTATIVE Laura M. Hallahan of Hallahan & Associates, P.C. substitutes in place of Stewart L. Mandell of Honigman LLP as authorized representative for Petitioner Legends at the Grove LLC and requests that she be copied on all future matters in the above docket. _/s/ Stewart L. Mandell________________ STEWART L. MANDELL (P33781) HONIGMAN LLP Dated: October 13, 2026 /s/ Laura M. Hallahan______________ LAURA M. HALLAHAN (P42101) SETH A. O’LOUGHLIN (P80257) KELSEA M. MELCHER (P85821) HALLAHAN & ASSOCIATES, P.C. Dated: October 13, 2026
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2 PROOF OF MAILING On the date below I sent by electronic mail a copy of the foregoing Petitioner’s Substitution of Authorized Representative to: Alana E. Knox Aknox@secrestwardle.com I declare that the statement above is true to the best of my information, knowledge and belief. /s/ Laura M. Hallahan_____________ Dated: October 13, 2026 Laura M. Hallahan
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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 MICHIGAN TAX TRIBUNAL Docket Number: 26-000753 Is this case currently pending in the Small Claims Division? No Party Filing Document Petitioner Files Document Type: Substitution of Counsel Attachment File Name: Sub Auth Rep - Legends Fee Information Filing Fee: $ 0.00 Payment Information Payment: $ 0.00
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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 MAY 17- 28, 2027 PREHEARING GENERAL CALL AND ORDER OF PROCEDURE Legends at the Grove LLC, Petitioner, v Township Of Pittsfield, Respondent. MTT Docket No. 26-000753 Please be advised that 26-000753 has been placed on a two-week Prehearing General Call commencing May 17, 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. 26-000753 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 January 19, 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 January 19, 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 January 19, 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 May 17, 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
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MT
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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)
Jackie J. Cook (P68781)
Honigman LLP
Attorneys for Petitioner
2290 First National Building
660 Woodward Avenue
Detroit, MI 48226-3506
(313) 465-7420
slmandell@honigman.com
jcook@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"). Petitioner’s Property
is known as Legends Grove. Respondent’s records identify Petitioner’s Property as being on
Freedom Drive. Petitioner’s Property is located in Pittsfield Twp., Washtenaw County, Michigan.Page 2
2 3. Respondent, Pittsfield Twp., assesses and collects property taxes on Petitioner's Property. 4. In 2026, Respondent determined the taxable value of Petitioner's Property to be $23,984,566 and assessed Petitioner's Property at $23,984,566, which will result in a state equalized value in the same amount based upon the tentative equalization factor. 5. Petitioner's Property is classified as commercial improved. 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. 6. 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. The 2026 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;
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3 (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 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 2026 assessed value, state equalized value, and taxable value from $23,984,566 to $16,750,000; (ii) requiring payment to Petitioner of the refunds attributable to such reductions, plus interest and costs; and (iii) awarding Petitioner any other relief to which it is entitled. Dated: May 6, 2026 Respectfully submitted, HONIGMAN LLP Attorneys for Petitioner By: Stewart L. Mandell (P33781) Jackie J. Cook (P68781) 2290 First National Building 660 Woodward Avenue Detroit, MI 48226-3506 (313) 465-7420 slmandell@honigman.com jcook@honigman.com
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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 Local Unit of Government First Name M.I. Last Name/Company Name Legends at the Grove LLC Home Address (No., Street, P.O. Box or Rural Route) 6400 Telegraph Rd. Suite 2500 City or Town Bloomfield Hills State Michigan ZIP Code 48301 Telephone Number 3134657420 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. L. 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 22 ZIP Code 48304 Telephone Number 3134657420 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) ljoseph@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] Freedom Drive Pittsfield Twp.
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING ORLENE HAWKS DIRECTOR Michigan 48108 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.) No 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: L-12-14-300-019 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: 23984566 Current Taxable Value as established by the Board of Review: 23984566 What do you believe is the fair market value (also known as True Cash Value)? 33500000 Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value). 16750000 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 ORLENE HAWKS 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: 26050684234468 Supporting Waiver Documents:
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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.: 26-000753 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: June 8, 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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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. 26-000753-TT 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 that Pittsfield Township levies and collects property taxes on the subject property under appeal. 4. Answering paragraph 4, Respondent admits that the subject property’s 2026 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 $23,984,566 $23,984,566 which assessed value will result in a state equalized value in the same amount based upon the tentative equalization factor. 5. Answering paragraph 5, 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 5 for lack of sufficient knowledge or information upon which to form a belief and leaves Petitioner to its proofs. 6. Answering paragraph 6, Respondent neither admits nor denies 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. 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.
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3 S E C R E S T W A R D L E 9. Answering paragraph 9 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. 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: May 26, 2026 (248) 851-9500 AFFIRMATIVE DEFENSES For its further Answer to Petitioner’s Entire Tribunal Property Tax Petition and by way of its Affirmative Defenses, Respondent respectfully requests unto this Honorable Tribunal as follows: 1. Petitioner fails to allege specific and sufficient facts to set forth a cause of action against Respondent and to support its claim for relief. 2. Petitioner fails to allege specific and sufficient facts to establish fraud, error of law, discrimination, application of wrong principles or illegality on the part of the Respondent. 3. Petitioner fails to allege that the mode and method of appraising its property failed to conform with the mode and method applied in the case of all of the properties in the
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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. 26-000753 Section 1: Respondent’s Contact Information Filer Type: Local Unit of Government Local Unit of Government Township of Pittsfield (WASHTENAW) 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 Alana M.I. Last Name Knox Firm Name (if any) Secrest Wardle Address (No., Street, P.O. Box or Rural Route) 2600 Troy Center Dr. PO Box 5025 City or Town Troy State Michigan ZIP Code 48007-5025 Telephone Number 248-851-9500 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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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Legends at the Grove LLC, Petitioner, _ MTT Docket No. 2 bp -pp> 73 5 v- Parcel No. L-12-14-300-019 Pittsfield Twp., Respondent. Stewart L. Mandell (P33781) Jackie J. Cook (P68781) Honigman LLP Attorneys for Petitioner 2290 First National Building 660 Woodward Avenue Detroit, MI 48226-3506 (313) 465-7420 slmandell@honigman.com jcook@honigman.com Proof of Service Lisa Joseph states that on YY [1S [3 2 , she did serve a copy of Petitioner's Petition, with docket number, upon the parties named on the attached list. /5 Han Qracph Dated: s/ / £ / Hp ) Lisa Joseph /
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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
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1 of 1 Docket #: 26-000753 Party Filing Document Party Filing Document: Petitioner Petitioner If 'other', Identify: File Document Type: fuFile:
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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)
Jackie J. Cook (P68781)
Honigman LLP
Attorneys for Petitioner
2290 First National Building
660 Woodward Avenue
Detroit, MI 48226-3506
(313) 465-7420
slmandell@honigman.com
jcook@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"). Petitioner’s Property
is known as Legends Grove. Respondent’s records identify Petitioner’s Property as being on
Freedom Drive. Petitioner’s Property is located in Pittsfield Twp., Washtenaw County, Michigan.Page 2
2 3. Respondent, Pittsfield Twp., assesses and collects property taxes on Petitioner's Property. 4. In 2026, Respondent determined the taxable value of Petitioner's Property to be $23,984,566 and assessed Petitioner's Property at $23,984,566, which will result in a state equalized value in the same amount based upon the tentative equalization factor. 5. Petitioner's Property is classified as commercial improved. 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. 6. 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. The 2026 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;
Page 3
3 (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 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 2026 assessed value, state equalized value, and taxable value from $23,984,566 to $16,750,000; (ii) requiring payment to Petitioner of the refunds attributable to such reductions, plus interest and costs; and (iii) awarding Petitioner any other relief to which it is entitled. Dated: May 6, 2026 Respectfully submitted, HONIGMAN LLP Attorneys for Petitioner By: Stewart L. Mandell (P33781) Jackie J. Cook (P68781) 2290 First National Building 660 Woodward Avenue Detroit, MI 48226-3506 (313) 465-7420 slmandell@honigman.com jcook@honigman.com
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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 Local Unit of Government First Name M.I. Last Name/Company Name Legends at the Grove LLC Home Address (No., Street, P.O. Box or Rural Route) 6400 Telegraph Rd. Suite 2500 City or Town Bloomfield Hills State Michigan ZIP Code 48301 Telephone Number 3134657420 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. L. 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 22 ZIP Code 48304 Telephone Number 3134657420 E-mail Address (do not enter unless you want MTT to send all correspondence via e-mail) ljoseph@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] Freedom Drive Pittsfield Twp.
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STATE OF MICHIGAN GRETCHEN WHITMER GOVERNOR DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS LANSING ORLENE HAWKS DIRECTOR Michigan 48108 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.) No 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: L-12-14-300-019 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: 23984566 Current Taxable Value as established by the Board of Review: 23984566 What do you believe is the fair market value (also known as True Cash Value)? 33500000 Multiply the True Cash Value by 50% and enter here. This is your contention of Assessed Value (also known as State Equalized Value). 16750000 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 ORLENE HAWKS 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: 26050684234468 Supporting Waiver Documents:
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