Lreh Michigan, LLC Petitioner Vs. City Of Auburn Hills 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 SEPTEMBER 16- 30, 2027 PREHEARING GENERAL CALL AND 

ORDER OF PROCEDURE

LREH Michigan, LLC,

Petitioner,

v

 

 

City Of Auburn Hills,

Respondent.

 MTT Docket No. 26-001090

Please be advised that 26-001090 has been placed on a two-week Prehearing General 

Call commencing September 16, 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covered by the order will not be published.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. 26-001090

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 May 20, 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 May 20, 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 

May 20, 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 

September 16, 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 subsequent to the completion date for this 

Prehearing General Call. Parties will, however, be notified in writing approximately one 

week before they are scheduled to appear. 

By:_____________________________________

Patricia L. Halm, Tribunal Chair

Entered: October 16, 2026

Page 3

MTT Docket No. 26-001090

Page 3 of 3

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 provide by those parties, attorneys, or authorized 

representatives.

By: Tribunal Clerk

Page 4

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 SEPTEMBER 16- 30, 2027 PREHEARING GENERAL CALL AND 

ORDER OF

Page 5

MT

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

LREH Michigan, LLC, 

 

 

 

Petitioner, 

 

v 

 

City of Auburn Hills, 

 

 

 

Respondent. 

 

 

 

MTT Docket No. 26-001090 

Parcel No. 02-14-13-301-012 

 

_____________________________________________________________________________/ 

 

JASON C. LONG (P59244) 

WILLIAMS, WILLIAMS, RATTNER & 

PLUNKETT, P.C. 

Attorneys for Petitioner 

380 N. Old Woodward Avenue, Suite 300 

Birmingham, MI 48009 

(248) 642-0333 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

HALLAHAN & ASSOCIATES, P.C. 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

_____________________________________________________________________________/ 

 

ANSWER TO PETITION 

AND 

AFFIRMATIVE DEFENSES 

 

ANSWER 

 

Respondent, City of Auburn Hills, by and through its attorneys, Hallahan & Associates, 

P.C., responds to the allegations made in Petitioner’s Petition as follows: 

The Parties 

1. 

Respondent lacks the knowledge and information necessary to respond to the truth 

of the allegations set forth in Paragraph 1 and, therefore, leaves Petitioner to its proofs. 

 

2. 

Respondent admits the allegations in Paragraph 2. 

 

The Subject Property 

 

3. 

Respondent admits the allegations in Paragraph 3 as to parcel number and 

corresponding address. Respondent lacks the knowledge and information necessary to respond to

Page 2

2

the remainder of the allegations set forth in Paragraph 3 and, therefore, leaves Petitioner to its 

proofs. 

 

4. 

Respondent admits the allegations in Paragraph 4. 

 

5. 

Respondent admits the allegations in Paragraph 5. 

 

The 2026 Assessment 

 

6. 

Respondent admits the allegations in Paragraph 6. 

 

7. 

Respondent admits the allegations in Paragraph 7. 

 

8. 

Respondent acknowledges Petitioner’s contention of value but denies that it reflects 

the property’s fair market value as of December 31, 2025. In further answer, the assessed, state 

equalized and/or taxable values do not exceed permitted amounts, do not exceed the percentage of 

true cash value permitted by law, were correctly determined and are based upon correct application 

of proper principles, and the values and Respondent’s mode of assessment are non-discriminatory 

and constitutional. 

 

9. 

Respondent acknowledges Petitioner’s belief as to a dispute in the subject 

property’s valuation but denies Petitioner’s contentions of value have merit and further denies 

Petitioner is entitled to relief. In further answer, the assessed, state equalized and/or taxable values 

do not exceed permitted amounts, do not exceed the percentage of true cash value permitted by 

law, were correctly determined and are based upon correct application of proper principles, and 

the values and Respondent’s mode of assessment are non-discriminatory and constitutional. 

 

10. 

Respondent acknowledges the issues raised by Petitioner but denies that those 

issues have merit and denies Petitioner is entitled to relief. Respondent admits there is no issue 

relative to an addition or loss but denies Petitioner has a right to raise any additional claims at a 

later date. 

 

11. 

Respondent denies the allegations in Paragraph 11, including subparagraphs (a)-

(d), for the reason that the same are untrue. In further answer, the assessed, state equalized and/or 

taxable values do not exceed permitted amounts, do not exceed the percentage of true cash value 

permitted by law, were correctly determined and are based upon correct application of proper 

principles, and the values and Respondent’s mode of assessment are non-discriminatory and 

constitutional. 

 

12. 

Respondent admits the subject property’s assessment is uniform but denies it 

overestimated the subject property’s value. 

 

Conclusion and Request for Relief 

 

13. 

Respondent acknowledges the relief requested by Petitioner in the final paragraph 

of its Petition but denies that Petitioner is entitled to said relief for the reasons set forth above.

Page 3

3

 

 

 

WHEREFORE, Respondent, City of Auburn Hills, requests the Tribunal dismiss the 

Petition, affirm Respondent’s assessed and taxable values, subject to county and state equalization, 

and award Respondent its costs and attorney fees. 

HALLAHAN & ASSOCIATES, P.C. 

 

/s/Laura M. Hallahan______________ 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

KELSEA M. MELCHER (P85821) 

Attorneys for Respondent 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

Dated: September 8, 2026 

 

 

 

(248) 731-3089 

 

 

 

AFFIRMATIVE DEFENSES 

 

Respondent, City of Auburn Hills, asserts the following affirmative defenses: 

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. 

The Tribunal is charged with finding a property’s true cash value to determine the 

property’s lawful assessment. Alhi Development Co v Orion Twp, 110 Mich App 764, 767 (1981). 

3. 

Petitioner has the burden of establishing the property’s true cash value. See 

MCL 205.737(3) and Kern v Pontiac Twp, 93 Mich App 612 (1974). 

4. 

Petitioner has failed to allege specific and sufficient facts to establish fraud, error 

of law, discrimination, application of wrong principles, or illegality on the part of Respondent or 

its agents.

Page 4

4

5. 

Petitioner has failed to allege that the mode and method of assessing the subject 

property fails to conform to the mode and method applied in the case of all other properties in 

Respondent’s taxing unit for the year in question. 

6. 

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

applied to the true cash value of Petitioner’s property, as well as all others, to arrive at the 

respective assessments appearing on the roll, and also fails to allege specific and sufficient facts 

to support its allegations that the property’s taxable value is improper. 

7. 

Petitioner asks

Page 5

5

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MTT DOCKET NO. 26-001090

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government

City Of Auburn Hills (OAKLAND)

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

Laura

M.I.

M

Last Name

Halahan

Firm Name (if any)

Hallahan & Associates PC

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

1750 S. Telegraph Road

Suite 202

City or Town

Bloomfield Hills

State

 Michigan

ZIP Code

48302-2073

Telephone Number

2487313090

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

lhallahan@hallahanlaw.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Laura M. Hallahan

/s/

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

LREH Michigan, LLC, 

Docket No. 26-001090 

Petitioner, 

Parcel No. 02-14-13-301-012 

v. 

City of Auburn Hills, 

Respondent. 

Jason C. Long (P59244) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

Attorneys for Petitioner 

Proof of Service of Petition and Notice of Docket Number

Page 2

Proof of Service of Petition and Notice of Docket Number 

Monica Athanas states that she personally served copies of the Entire Tribunal 

Property Tax Petition, Notice of Docket Number, and this Proof of Service, on the 

persons listed below, by the means identified, by placing those documents in a duly 

stamped, addressed envelopes and placing the envelopes in the United States mail 

on August 11, 2026. 

PERSONS SERVED: 

Certified Mail 

Clerk 

City of Auburn Hills 

1827 N. Squirrel Rd. 

Auburn Hills, MI 48326 

Assessor 

City of Auburn Hills 

1827 N. Squirrel Rd. 

Auburn Hills, MI 48326 

First Class Mail 

Clerk 

Oakland County 

1200 N. Telegraph Rd. 

Building 12E 

Pontiac, MI 48341 

Director of Equalization 

Oakland County 

250 Elizabeth Lake Rd. 

Ste. 1000W 

Pontiac, MI 48341 

Secretary of School Board 

Pontiac School District 

47200 Woodward Ave. 

Pontiac, MI 48342 

State Treasurer Michigan 

Department of Treasury 

Austin Building 

430 W. Allegan 

Lansing, MI 

48922 

Mowe Quied 

Monica Athanas

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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: 26-001090

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

Party Filing Document 

Petitioner

Files

Document Type: Proof of Service: Petition

Attachment File Name: POS - Petition - LREH Wellington

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

 

LREH Michigan, LLC, 

 

 

 

 

 

 

 

 

Docket No. 26- 

 

Petitioner, 

 

 

 

 

 

Parcel No. 02-14-13-301-012 

 

v. 

 

City of Auburn Hills, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Jason C. Long (P59244) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

Attorneys for Petitioner 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Entire Tribunal Property Tax Petition 

 

 

Petitioner LREH Michigan, LLC, by and through its attorneys, Williams, 

Williams, Rattner & Plunkett, PC, states as follows for its Entire Tribunal Property 

Tax Petition. 

The Parties 

1. 

Petitioner LREH Michigan, LLC is a Michigan limited liability company 

with its principal place of business in Michigan located at 1111 W. Long Lake Road, 

350, Troy, Michigan 48098. 

2. 

Respondent the City of Auburn Hills is a Michigan city with its principal 

offices located at 1827 N. Squirrel Road, Auburn Hills, Michigan 48326.

Page 2

The Subject Property 

3. 

Petitioner owns property identified as Parcel No. 02-14-13-301-012 and 

commonly known as 3250 University Dr., Auburn Hills, Michigan 48326 (the “Subject 

Property”). 

4. 

The Subject Property is located in Oakland County and is within the 

Pontiac School District. 

5. 

Respondent possesses jurisdiction to assess and collect property taxes 

for the Subject Property. 

The 2026 Assessment 

6. 

For the 2026 tax year, Respondent classified the Subject Property as 

commercial real property. 

7. 

For the 2026 tax year, Respondent established the Subject Property’s 

assessment for property taxes as follows: 

True Cash Value 

Assessed Value 

Taxable Value 

 9,341,460 

 4,670,730 

 4,670,730 

 

8. 

Petitioner contends that a lawful assessment of the Subject Property for 

the 2026 tax year cannot exceed the following amounts: 

True Cash Value 

Assessed Value 

Taxable Value 

 7,000,000 

 3,500,000 

 3,500,000 

 

9. 

The amounts in dispute therefore are as follows: 

True Cash Value 

Assessed Value 

Taxable Value 

 2,341,460 

 1,170,730 

 1,170,730 

 

10. 

This Petition presents issues involving the Subject Property’s valuation 

for assessment purposes. Petitioner does not believe that this Petition presents any

Page 3

issues arising out of “additions” or “losses” as the General Property Tax Act, MCL 

211.1 et seq. (the “GPTA”), defines those terms, but reserves its right to assert issues 

involving losses should information supporting such issues become available. 

11. 

The Subject Property’s 2026 assessment (a) violates the Michigan 

Constitution, the GPTA, and other Michigan law, (b) is based on erroneous principles 

and information, (c) is based on the misapplication of valuation principles, and (d) 

otherwise violates Petitioner’s rights. 

12. 

Petitioner does not assert that the Subject Property’s 2026 assessment 

is not uniform aside from the lack of uniformity resulting from Respondent 

overestimating the Subject Property’s values. 

Conclusion and Request for Relief 

WHEREFORE, Petitioner respectfully requests that this honorable Tribunal 

enter judgment revising the Subject Property’s 2026 assessment to be consistent with 

the values set forth in Paragraph 8 of this Petition and granting Petitioner all other 

relief to which it is entitled under Michigan law. 

 

 

 

 

 

Respectfully Submitted, 

 

 

 

 

 

 

WILLIAMS, WILLIAMS, RATTNER & 

 

 

 

 

 

 

PLUNKETT, PC 

 

 

 

 

 

 

 

By: /s/ Jason C. Long 

 

 

 

 

 

 

 

 

 Jason C. Long (P59244) 

Dated: May 18, 2026 

 

 

Attorneys for Petitioner

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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

LREH Michigan, LLC

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

1111 W. Long Lake Road, 350

City or Town

Troy

State

Michigan

ZIP Code

48098

Telephone Number

2486420333

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

jpesick@wwrplaw.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Jerome

M.I.

P

Last Name

Pesick

Firm Name (if any)

Williams, Williams, Rattner & Plunkett, PC

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

380 N. Old Woodward, Ste 300

City or Town

Birmingham

State

Michigan

ZIP Code

48009

Telephone Number

2486420333

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

jpesick@wwrplaw.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]

3250 University Dr.

Auburn Hills

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48326

Taxing Authority (City or Township)

City Of Auburn Hills (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:

02-14-13-301-012

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:

4670730

Current Taxable Value as established by the Board of Review:

4670730

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

7000000

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

3500000

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

3500000

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/ Jerome P. Pesick

Payment Information

Amount: 600

Success: True

Message: ""

Waiver Code:

Transaction Number: 26051886000394

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

LREH Michigan, LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-001090

City Of Auburn Hills, 

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 16, 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 ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

 

LREH Michigan, LLC, 

 

 

 

 

 

 

 

 

Docket No. 26- 

 

Petitioner, 

 

 

 

 

 

Parcel No. 02-14-13-301-012 

 

v. 

 

City of Auburn Hills, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Jason C. Long (P59244) 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

(248) 642-0333 

Attorneys for Petitioner 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Entire Tribunal Property Tax Petition 

 

 

Petitioner LREH Michigan, LLC, by and through its attorneys, Williams, 

Williams, Rattner & Plunkett, PC, states as follows for its Entire Tribunal Property 

Tax Petition. 

The Parties 

1. 

Petitioner LREH Michigan, LLC is a Michigan limited liability company 

with its principal place of business in Michigan located at 1111 W. Long Lake Road, 

350, Troy, Michigan 48098. 

2. 

Respondent the City of Auburn Hills is a Michigan city with its principal 

offices located at 1827 N. Squirrel Road, Auburn Hills, Michigan 48326.

Page 2

The Subject Property 

3. 

Petitioner owns property identified as Parcel No. 02-14-13-301-012 and 

commonly known as 3250 University Dr., Auburn Hills, Michigan 48326 (the “Subject 

Property”). 

4. 

The Subject Property is located in Oakland County and is within the 

Pontiac School District. 

5. 

Respondent possesses jurisdiction to assess and collect property taxes 

for the Subject Property. 

The 2026 Assessment 

6. 

For the 2026 tax year, Respondent classified the Subject Property as 

commercial real property. 

7. 

For the 2026 tax year, Respondent established the Subject Property’s 

assessment for property taxes as follows: 

True Cash Value 

Assessed Value 

Taxable Value 

 9,341,460 

 4,670,730 

 4,670,730 

 

8. 

Petitioner contends that a lawful assessment of the Subject Property for 

the 2026 tax year cannot exceed the following amounts: 

True Cash Value 

Assessed Value 

Taxable Value 

 7,000,000 

 3,500,000 

 3,500,000 

 

9. 

The amounts in dispute therefore are as follows: 

True Cash Value 

Assessed Value 

Taxable Value 

 2,341,460 

 1,170,730 

 1,170,730 

 

10. 

This Petition presents issues involving the Subject Property’s valuation 

for assessment purposes. Petitioner does not believe that this Petition presents any

Page 3

issues arising out of “additions” or “losses” as the General Property Tax Act, MCL 

211.1 et seq. (the “GPTA”), defines those terms, but reserves its right to assert issues 

involving losses should information supporting such issues become available. 

11. 

The Subject Property’s 2026 assessment (a) violates the Michigan 

Constitution, the GPTA, and other Michigan law, (b) is based on erroneous principles 

and information, (c) is based on the misapplication of valuation principles, and (d) 

otherwise violates Petitioner’s rights. 

12. 

Petitioner does not assert that the Subject Property’s 2026 assessment 

is not uniform aside from the lack of uniformity resulting from Respondent 

overestimating the Subject Property’s values. 

Conclusion and Request for Relief 

WHEREFORE, Petitioner respectfully requests that this honorable Tribunal 

enter judgment revising the Subject Property’s 2026 assessment to be consistent with 

the values set forth in Paragraph 8 of this Petition and granting Petitioner all other 

relief to which it is entitled under Michigan law. 

 

 

 

 

 

Respectfully Submitted, 

 

 

 

 

 

 

WILLIAMS, WILLIAMS, RATTNER & 

 

 

 

 

 

 

PLUNKETT, PC 

 

 

 

 

 

 

 

By: /s/ Jason C. Long 

 

 

 

 

 

 

 

 

 Jason C. Long (P59244) 

Dated: May 18, 2026 

 

 

Attorneys for Petitioner

These are text excerpts, not the complete document. Text recognition and reading order can contain errors. Check the PDF for complete wording, formatting, and context.

Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Entire Tribunal Case Information Sheet - Petitioner

MTT DOCKET NO. 

 

Section 1: Petitioner’s Contact Information

Filer type: 

Organization 

Local Unit of Government

First Name

M.I.

Last Name/Company Name

LREH Michigan, LLC

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

1111 W. Long Lake Road, 350

City or Town

Troy

State

Michigan

ZIP Code

48098

Telephone Number

2486420333

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

jpesick@wwrplaw.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Jerome

M.I.

P

Last Name

Pesick

Firm Name (if any)

Williams, Williams, Rattner & Plunkett, PC

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

380 N. Old Woodward, Ste 300

City or Town

Birmingham

State

Michigan

ZIP Code

48009

Telephone Number

2486420333

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

jpesick@wwrplaw.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]

3250 University Dr.

Auburn Hills

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48326

Taxing Authority (City or Township)

City Of Auburn Hills (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:

02-14-13-301-012

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:

4670730

Current Taxable Value as established by the Board of Review:

4670730

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

7000000

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

3500000

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

3500000

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/ Jerome P. Pesick

Payment Information

Amount: 600

Success: True

Message: ""

Waiver Code:

Transaction Number: 26051886000394

Supporting Waiver Documents:

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.