Lifted Industrial Partners LLC Petitioner Vs. Township Of Orion 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

Lifted Industrial Partners LLC,

Petitioner,

v

 

 

Township Of Orion,

Respondent.

 MTT Docket No. 26-001007

Please be advised that 26-001007 has been placed on a two-week Prehearing General 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

covered by the order will not be published.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

Protective Order will be published.

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

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

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

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

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

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

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

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

of the Tribunal’s website. 

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

website for more information.

Page 2

MTT Docket No. 26-001007

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”

Page 3

MTT

Page 4

STA

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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

Lifted Industrial Partners LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 26-001007

Township Of Orion,

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 20, 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

Lifted Industrial Partners LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 26-001007

Township Of Orion,

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 20, 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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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

LIFTED INDUSTRIAL PARTNERS LLC, 

 

 

Petitioner, 

 

 

 

 

 

MTT Docket No.: 26-002007 

 

 

 

 

 

Parcel No.: O-09-34-300-018 

v. 

 

 

 

 

 

 

 

 

 

TOWNSHIP OF ORION, 

Respondent. 

_____________________________________________________________________________ 

Jackie Cook (P68781) 

 

 

 

Zachary Learman (P71005) 

HONIGMAN LLP 

 

 

 

 

Daniel J. Kelly (P41315) 

Attorney for Petitioner 

 

 

 

THE KELLY FIRM, PLC 

2290 First National Building 

 

 

Attorneys for Respondent 

660 Woodward Avenue 

 

 

 

512 E. 11 Mile Rd 

Detroit, MI 48226-3506 

 

 

 

Royal Oak, MI 48067 

(313) 465-7270 

 

 

 

 

(248) 655-7025 

jcook@honigman.com 

 

 

 

zack@kellyfirmpc.com 

 

 

 

 

 

 

 

dan@kellyfirmpc.com 

 

RESPONDENT’S ANSWER TO PETITION, 

AFFIRMATIVE DEFENSES, AND PROOF OF SERVICE 

 

 

NOW COMES the Respondent, TOWNSHIP OF ORION, by its attorneys, THE KELLY 

FIRM, PLC, and for its answer to the Entire Tribunal Property Tax Petition, states as follows: 

1. In response to paragraph 1, Respondent neither admits nor denies same for lack of 

sufficient information and leave Petitioner to its proofs. 

2. In response to paragraph 2, Respondent neither admits nor denies same for lack of 

sufficient information and leave Petitioner to its proofs. 

3. In response to paragraph 3, Respondent admits the allegations contained therein. 

4. In response to paragraph 4, Respondent neither admits nor denies same for lack of 

sufficient information and leave Petitioner to its proofs.

Page 2

5. In response to paragraph 5, Respondent neither admits nor denies same for lack of 

sufficient information and leave Petitioner to its proofs. 

6. In response to paragraph 6, Respondent neither admits nor denies same for lack of 

sufficient information and leave Petitioner to its proofs. 

7. In response to paragraph 7, Respondent admits the allegations contained therein. 

8. In response to paragraph 8, Respondent neither admits nor denies same for lack of 

sufficient information and leave Petitioner to its proofs. 

9. In response to paragraph 9, Respondent admits the allegations contained therein. 

10. In response to paragraph 10, Respondent neither admits nor denies same for lack of 

sufficient information and leave Petitioner to its proofs. 

11. In response to paragraph 11, Respondent neither admits nor denies same for lack of 

sufficient information and leave Petitioner to its proofs. 

12. In response to paragraph 10, Respondent neither admits nor denies same for lack of 

sufficient information and leave Petitioner to its proofs. 

AFFIRMATIVE DEFENSES 

NOW COMES the Respondent, TOWNSHIP OF ORION, by its attorneys, THE 

KELLY FIRM, PLC, and files the following Affirmative Defenses in support of its 

Answer to the Petition: 

1. The facts as alleged by the Petitioner do not establish mutual mistake of fact. 

2. Petitioner has failed to allege specific and sufficient facts upon which the mode 

and method of appraising property fails to conform with mode and method applied to 

all other properties in the community.

Page 3

3. Petitioner has failed to show that any fact other than fifty percent (50%) was 

applied to the true cash value of the property. 

4. Petitioner’s claim, if prevailed upon, would create a windfall for Petitioner and 

create a burden upon the Township, schools, County taxes, and other property owners 

in the community. 

5. Petitioner is asking this Honorable Tribunal to make an underassessment based 

upon an arbitrary basis. 

6. A levy of all taxes is required to be made based upon the assessment of fifty 

percent (50%) of true cash value as ultimately determined by the process of County 

and State equalization. 

7. Respondent reserves the right to file additional Affirmative Defenses as may 

become apparent in this case. 

 

 

 

 

 

 

 

THE KELLY FIRM, PLC 

 

 

 

 

 

 

 

 

Respectfully submitted, 

 

 

Dated: July 30, 2026 

 

 

 

/s/ Zachary Learman 

 

 

 

 

 

 

 

 

Zachary Learman (P71005) 

 

 

 

 

 

 

 

Attorney for Plaintiff 

 

 

 

 

 

 

 

512 E. Eleven Mile Rd 

Royal Oak, Michigan 48067 

(248) 655-7025 

 

 

 

 

 

 

 

zack@kellyfirmpc.com 

 

 

PROOF OF SERVICE 

 

 

The undersigned states that on July 30, 2026, she electronically filed Appearance, 

Respondent's Answer to Petition, Affirmative Defenses, and this Proof of Service with the 

Michigan Tax Tribunal via the Tribunal's E-filing System and served a copy upon Representative 

for Petitioner via electronic mail to Petitioners address at jcook@honigman.com. 

 

 

/s/ Julian Slavsky 

 Julian Slavsky

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

LIFTED INDUSTRIAL PARTNERS LLC, 

 

 

Petitioner, 

 

 

 

 

 

MTT Docket No.: 26-002007 

 

 

 

 

 

Parcel No.: O-09-34-300-018 

v. 

 

 

 

 

 

 

 

 

 

TOWNSHIP OF ORION, 

Respondent. 

_____________________________________________________________________________ 

Jackie Cook (P68781) 

 

 

 

Zachary Learman (P71005) 

HONIGMAN LLP 

 

 

 

 

Daniel J. Kelly (P41315) 

Attorney for Petitioner 

 

 

 

THE KELLY FIRM, PLC 

2290 First National Building 

 

 

Attorneys for Respondent 

660 Woodward Avenue 

 

 

 

512 E. 11 Mile Rd 

Detroit, MI 48226-3506 

 

 

 

Royal Oak, MI 48067 

(313) 465-7270 

 

 

 

 

(248) 655-7025 

jcook@honigman.com 

 

 

 

zack@kellyfirmpc.com 

 

 

 

 

 

 

 

dan@kellyfirmpc.com 

 

APPEARANCE 

 

The undersigned hereby enters their appearance as attorney for Respondent, Charter 

Township of Orion, in the above-entitled cause. 

Respectfully submitted, 

 

 

 

 

 

 

 

THE KELLY FIRM, PLC 

 

Dated: July 30, 2026 

 

 

 

/s/ Zachary Learman 

 

 

 

 

 

 

 

 

Zachary Learman (P71005) 

 

 

 

 

 

 

 

Attorney for Plaintiff 

 

 

 

 

 

 

 

512 E. Eleven Mile Rd 

Royal Oak, Michigan 48067 

(248) 655-7025 

zack@kellyfirmpc.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

MICHIGAN TAX TRIBUNAL

Docket Number: 26-001007

Is this case currently pending in the Small Claims Division? No

Party Filing Document 

Respondent

Files

Document Type: Appearance

Attachment File Name: Appearance Learman Resp MTT 26-001007

Document Type: Response to Order - Answer

Attachment File Name: Resp Answer Affirm Defense POS MTT 26-001007

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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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

Lifted Industrial Partners LLC,

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 26-001007

Township Of Orion,

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. 26-001007

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

Lifted Industrial Partners LLC,

Petitioner, MICHIGAN TAX TRIBUNAL

 ENTIRE TRIBUNAL

v

 

MTT Docket No. 26-001007

Township Of Orion,

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

Page 4

MTT

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Page 1

26-0014 

75559770.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Lifted Industrial Partners LLC, 

Petitioner, 

v 

Orion Township,

Respondent. 

MTT Docket No. ________ 

Parcel No. O-09-34-300-018 

Jackie J. Cook (P68781) 

Honigman LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7270 

jcook@honigman.com

Petition 

Lifted Industrial Partners LLC (“Petitioner”), through its attorneys, HONIGMAN LLP, 

says: 

1.

Petitioner is a Michigan limited liability company with a principal office located at 

4611 Liberty Dr S., Orion Township, Michigan. 

2.

The subject real property, tax parcel number O-09-34-300-018, is located at 4611 

Liberty Dr. S., Orion Twp., MI, in Oakland County ("Petitioner's Property"). 

3.

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

Property. 

4.

In 2026, Respondent’s Board of Review set the taxable value of Petitioner's 

Property at $2,943,330 and assessed Petitioner's Property at $3,262,380.

Page 2

2 

75559770.1 

5.

Respondent’s Board of Review assessing Petitioner’s Property will result in a state 

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

6.

Petitioner's Property is misclassified as commercial real as the Property is used for 

agricultural operations and should be classified agricultural. 

7.

Petitioner's Property is presently used or available for use for agricultural purposes. 

8.

Petitioner believes that Petitioner's Property was originally designed to be used for 

agricultural purposes. 

9.

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

value, and (d) uniformity. 

10.

At this time, Petitioner believes, as it relates to taxable value, that there is a dispute 

relative to the value of a loss. 

11.

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

12.

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 

and operate as a fraud upon the taxpayer 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

Page 3

3 

75559770.1 

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 

th2026 taxable value of Petitioner's Property from $2,943,330 to $2,000,000; (ii) reducing the 2026 

assessed and state equalized value of Petitioner's Property from $3,262,380 to $2,000,000; (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: May 15, 2026

Respectfully submitted, 

Honigman LLP 

Attorneys for Petitioner 

By:

Jackie J. Cook (P68781) 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7270 

jcook@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

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

Lifted Industrial Partners LLC

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

4611 Liberty Drive S

City or Town

Orion Township

State

Michigan

ZIP Code

48360

Telephone Number

3134657279

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

jcook@honigman.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Jackie

M.I.

J.

Last Name

Cook

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)

jcook@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]

4611 Liberty Drive S

Orion Township

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48360

Taxing Authority (City or Township)

Township Of Orion (OAKLAND) 

County

Oakland

If you are appealing more than one parcel, are they contiguous or adjoining? 

(*If no, you must file separate appeals for each non-contiguous or non-adjoining parcel.)

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:

O-09-34-300-018

Classification of Property: Real (check one)

Agricultural (check one)

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

3262380

Current Taxable Value as established by the Board of Review:

2943330

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

4000000

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

2000000

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/ Jackie J. Cook

Payment Information

Amount: 600

Success: True

Message: ""

Waiver Code:

Transaction Number: 26051585556066

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

Lifted Industrial Partners LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-001007

Township Of Orion, 

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 13, 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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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Lifted Industrial Partners LLC, 

Petitioner, 

MTT Docket No. Al “O00 NS) 7 

v 

Parcel No. 0-09-34-300-018 

Orion Township, 

Respondent. 

Jackie J. Cook (P68781) 

Honigman LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7270 

jcook@honigman.com 

Proof of Service 

Lisa Joseph states that she is employed by HONIGMAN LLP, attorneys for Petitioner, and 

thaton 

_S_ [{ ¥ 

[ A b 

, she did serve a copy of Petitioner's Petition, with docket number, upon 

the parties named on the attached list. 

/7 Fan Spucph 

Lisa Joseph 

26-0014 

75559770.1

Page 2

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

ORION TWP. 

2525 JOSLYN ROAD 

LAKE ORION, MI 48360 

ASSESSOR 

ORION TWP. 

2525 JOSLYN ROAD 

LAKE ORION, MI 48360 

AND BY FIRST-CLASS UNITED STATES MAIL: 

CLERK 

OAKLAND COUNTY 

1200 N. TELEGRAPH ROAD 

PONTIAC, MI 48341-0413 

DIRECTOR OF EQUALIZATION 

OAKLAND COUNTY 

1200 N. TELEGRAPH ROAD 

PONTIAC, MI 48341-0413 

SECRETARY OF SCHOOL BOARD 

LAKE ORION COMMUNITY SCHOOLS 

315 N. LAPEER STREET 

LAKE ORION, MI 48362-3165 

STATE TREASURER 

MICHIGAN DEPARTMENT OF TREASURY 

TREASURY BUILDING 

430 W. ALLEGAN ST. 

LANSING, MI 48922 

26-0021 

75559770.1

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Page 1

1 of 1

Docket #: 26-001007

Party Filing Document

Party Filing Document: 

 Petitioner

 Petitioner

 

 

If 'other', Identify: 

File

Document Type: 

 

 

fuFile:

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Page 1

26-0014 

75559770.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Lifted Industrial Partners LLC, 

Petitioner, 

v 

Orion Township,

Respondent. 

MTT Docket No. ________ 

Parcel No. O-09-34-300-018 

Jackie J. Cook (P68781) 

Honigman LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7270 

jcook@honigman.com

Petition 

Lifted Industrial Partners LLC (“Petitioner”), through its attorneys, HONIGMAN LLP, 

says: 

1.

Petitioner is a Michigan limited liability company with a principal office located at 

4611 Liberty Dr S., Orion Township, Michigan. 

2.

The subject real property, tax parcel number O-09-34-300-018, is located at 4611 

Liberty Dr. S., Orion Twp., MI, in Oakland County ("Petitioner's Property"). 

3.

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

Property. 

4.

In 2026, Respondent’s Board of Review set the taxable value of Petitioner's 

Property at $2,943,330 and assessed Petitioner's Property at $3,262,380.

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2 

75559770.1 

5.

Respondent’s Board of Review assessing Petitioner’s Property will result in a state 

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

6.

Petitioner's Property is misclassified as commercial real as the Property is used for 

agricultural operations and should be classified agricultural. 

7.

Petitioner's Property is presently used or available for use for agricultural purposes. 

8.

Petitioner believes that Petitioner's Property was originally designed to be used for 

agricultural purposes. 

9.

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

value, and (d) uniformity. 

10.

At this time, Petitioner believes, as it relates to taxable value, that there is a dispute 

relative to the value of a loss. 

11.

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

12.

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 

and operate as a fraud upon the taxpayer 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

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3 

75559770.1 

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 

th2026 taxable value of Petitioner's Property from $2,943,330 to $2,000,000; (ii) reducing the 2026 

assessed and state equalized value of Petitioner's Property from $3,262,380 to $2,000,000; (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: May 15, 2026

Respectfully submitted, 

Honigman LLP 

Attorneys for Petitioner 

By:

Jackie J. Cook (P68781) 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7270 

jcook@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

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

Lifted Industrial Partners LLC

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

4611 Liberty Drive S

City or Town

Orion Township

State

Michigan

ZIP Code

48360

Telephone Number

3134657279

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

jcook@honigman.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Jackie

M.I.

J.

Last Name

Cook

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)

jcook@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]

4611 Liberty Drive S

Orion Township

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48360

Taxing Authority (City or Township)

Township Of Orion (OAKLAND) 

County

Oakland

If you are appealing more than one parcel, are they contiguous or adjoining? 

(*If no, you must file separate appeals for each non-contiguous or non-adjoining parcel.)

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:

O-09-34-300-018

Classification of Property: Real (check one)

Agricultural (check one)

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

3262380

Current Taxable Value as established by the Board of Review:

2943330

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

4000000

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

2000000

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/ Jackie J. Cook

Payment Information

Amount: 600

Success: True

Message: ""

Waiver Code:

Transaction Number: 26051585556066

Supporting Waiver Documents:

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