Moceri/Dm Investments, LLC Petitioner Vs. City Of Bloomfield Hills Respondent

Page 1

1

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

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

MOCERI/DM INVESTMENTS, LLC, 

 

 

Petitioner, 

MTT Docket No. 26-001625-TT 

 

 

Parcel No. 12-19-14-152-005 and 

 

-vs- 

 

 

 

 

 

Parcel No. 12-19-14-152-007 

 

CITY OF BLOOMFIELD HILLS, 

 

 

Respondent. 

_________________________________________________________________________________/ 

 

WILLIAMS, WILLIAMS, RATTNER & 

PLUNKETT, PC 

Jerome P. Pesick (P29039) 

Richard E. Rassel, III (P57540) 

Jason C. Long (P59244) 

Attorneys for Petitioner 

380 N. Old Woodward Ave., Suite 300 

Birmingham, MI 48009 

(248) 642-0333 

jpesick@wwrplaw.com 

rerassel@wwrplaw.com 

jlong@wwrplaw.com

SECREST WARDLE 

Alana E. 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 PETITIONERS’ 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

 

 

NOW COMES Respondent, CITY OF BLOOMFIELD HILLS, by and through its attorneys, 

SECREST WARDLE, and for its Answer to Petitioners’ 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 Petitioners to their proofs. 

2. 

Answering paragraph 2, Respondent admits the same.

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2

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

3. 

Answering paragraph 3, Respondent admits that Moceri/DM Investments, LLC is a 

party in interest with respect to parcel 12-19-14-152-005 and parcel 12-19-14-152-007, commonly 

known as 39515 Woodward Ave, in Bloomfield Hills, Michigan 48304. Respondent neither admits 

nor denies the remainder of the allegations contained in paragraph 3 for lack of sufficient knowledge 

or information upon which to form a belief and leaves Petitioners to their proofs. 

 4. 

Answering paragraph 4, Respondent admits that parcel 12-19-14-152-005 and parcel 

12-19-14-152-007 is located in Oakland County and within the Bloomfield Hills School District. 

5. 

Answering paragraph 5, Respondent admits the same. 

6. 

Answering paragraph 6, Respondent admits the same. 

7. 

Answering paragraph 7, Respondent admits that the subject property’s 2026 true cash, 

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

PARCEL NUMBER 

TRUE CASH VALUE

ASSESSED VALUE 

TAXABLE VALUE 

12-19-14-152-005 

$ 1,333,260 

 $ 666,630 

$ 664,410 

12-19-14-152-007 

$ 326,020 

$ 163,010 

$ 163,010 

 

8. 

Answering paragraph 8, Respondent denies that the subject property’s 2026 true cash, 

state equalized and taxable values were no higher than: 

PARCEL NUMBER 

TRUE CASH VALUE

STATE EQUALIZED 

VALUE 

TAXABLE VALUE 

12-19-14-152-005 

$ 640,000 

$ 320,000 

$ 320,000 

12-19-14-152-007 

$ 160,000 

$ 80,000 

$ 80,000 

 

9. 

Answering paragraph 9, Respondent neither admits nor denies the allegations 

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

and leaves Petitioners to their proofs.

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3

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

10. 

Answering paragraph 10, Respondent neither admits nor denies the allegations 

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

and leaves Petitioners to their proofs. 

11. 

Answering paragraph 11, Respondent denies that the 2026 assessment violates the 

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

information, and a misapplication of valuation principles. Respondent neither admits nor denies the 

remainder of the allegations contained in paragraph 11 for lack of sufficient knowledge or information 

upon which to form a belief and leaves Petitioners to their proofs. 

12. 

Answering paragraph 12, Respondent denies that it is overestimating the value for 

parcel 12-19-14-152-005 and parcel 12-19-14-152-007. Respondent neither admits nor denies the 

remainder of the allegations in paragraph 12 for lack of sufficient knowledge or information upon 

which to form a belief and leaves Petitioners to their proofs. 

 

WHEREFORE, Respondent, CITY OF BLOOMFIELD HILLS, denies that Petitioners are 

entitled to the relief they seek and Respondent respectfully requests that the Respondent’s assessment 

and taxable value of the subject property be affirmed or increased, that Petitioners’ 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 Dr., P.O. Box 5025 

 

 

 

 

 

 

 

Troy, MI 48007-5025 

 

 

 

 

 

 

 

(248) 851-9500 

Dated: September 15, 2026 

 

 

 

aknox@secrestwardle.com

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4

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

AFFIRMATIVE DEFENSES 

 

 

For its further Answer to Petitioners’ Entire Tribunal Property Tax Petition and by way of its 

Affirmative Defenses, Respondent respectfully requests unto this Honorable Tribunal as follows: 

 

1. 

Petitioners fail to allege specific and sufficient facts to set forth a cause of action 

against Respondent and to support its claim for relief. 

 

2. 

Petitioners fail 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. 

Petitioners fail 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 Respondent’s 

taxing unit for the year in question. 

 

4. 

Petitioners fail to allege specific and sufficient facts to establish the true cash value, 

assessed value and taxable value of its property. 

 

5. 

Petitioners fail to allege specific and sufficient facts to support

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5

S

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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. 26-001625

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government

City Of Bloomfield 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

Alana

M.I.

E.

Last Name

Knox

Firm Name (if any)

Secrest Wardle

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

2600 Troy Center Drive

City or Town

Troy

State

 Michigan

ZIP Code

48007

Telephone Number

2488519500

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

aknox@secrestwardle.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Alana E. Knox

/s/

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Moceri/DM Investments, LLC, 

Docket No. 26-001625 

Parcel Nos. 

12-19-14-152-005 

Petitioner, 

12-19-14-152-007 

v. 

City of Bloomfield Hills, 

Respondent. 

Jerome P. Pesick (P29039) 

Richard E Rassel, III (P57540) 

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 September 3, 2026. 

PERSONS SERVED: 

Certified Mail 

Clerk 

City of Bloomfield Hills 

45 E Long Lake Road 

Bloomfield Hills, MI 48304 

Assessor 

City of Bloomfield Hills 

45 E Long Lake Road 

Bloomfield Hills, MI 48304 

First Class Mail 

Clerk 

Secretary of School Board 

Oakland County 

Bloomfield Hills Public Schools 

1200 North Telegraph Rd 

7273 Wing Lake Road 

Building 12E 

Bloomfield Hills, MI 48301 

Pontiac, MI 48341 

Director of Equalization 

~~ State Treasurer 

Oakland County 

Michigan Dep’t of Treasury 

250 Elizabeth Lake Rd. 

Austin Building 

Suite 1000W 

430 W. Allegan 

Pontiac, MI 48341 

Lansing, MI 

48922 

"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: 26-001625

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: Moceri - Bloomfield Hills - POS - Petition

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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

Petition Page 1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

Moceri/DM Investments, LLC, 

 

 

Docket No. 26- 

 

 

 

 

 

 

 

 

Parcel Nos. 12-19-14-152-005 

Petitioner, 

 

 

 

 

 

 

 

12-19-14-152-007 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

v. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

City of Bloomfield Hills, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Jerome P. Pesick (P29039) 

Richard E Rassel, III (P57540) 

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 Moceri/DM Investments, LLC, by and through their attorneys, 

Williams Williams Rattner & Plunkett, PC, state as follows for their Entire Tribunal 

Property Tax Petition. 

The Parties 

1. 

Petitioner Moceri/DM Investments, LLC, is a Michigan limited liability 

company with its registered office located at 3005 University Dr, Auburn Hills, MI 

48326.

Page 2

Petition Page 2 

2. 

Respondent City of Bloomfield Hills is a Michigan city with its primary 

offices located at 45 E Long Lake Road, Bloomfield Hills, MI 48304. 

The Subject Properties 

3. 

Petitioner owns properties identified as follows: 

Parcel No. 

Property Address 

12-19-14-152-005 

39515 Woodward Ave 

12-19-14-152-007 

39515 Woodward Ave 

 

They are referred to collectively in this Petition as the “Subject Properties.” 

4. 

The Subject Properties are located in Oakland County and are within 

the Bloomfield Hills school district. 

5. 

Respondent possesses jurisdiction to assess and collect property taxes 

for the Subject Properties. 

The 2026 Assessments 

6. 

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

commercial real property. 

7. 

For the 2026 tax year, Respondent established the Subject Properties’ 

assessments for property taxes in the amounts set forth in paragraph 1 of the 

attached Multiple Parcel Form. 

8. 

Petitioner contends that lawful assessments of the Subject Properties 

for the 2026 tax year cannot exceed the amounts set forth in paragraph 2 of the 

attached Multiple Parcel Form. 

9. 

The amounts in dispute therefore equal the amounts identified in 

paragraph 3 of the attached Multiple Parcel Form.

Page 3

Petition Page 3 

10. 

This Petition presents issues involving the Subject Properties’ valuation 

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

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

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

involving losses should information supporting such issues become available. 

11. 

The Subject Properties’ 2026 assessments (a) violate the Michigan 

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

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

principles, and (d) otherwise violate Petitioner’s rights. 

12. 

Petitioner does not assert that the Subject Properties’ 2026 assessments 

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

overestimating the Subject Properties’ values. 

Conclusion and Request for Relief 

 

WHEREFORE, Petitioner respectfully requests that this honorable Tribunal 

enter judgment revising the Subject Properties’ 2026 assessments to amounts that do 

not exceed Petitioner’s contentions of value set forth in paragraph 2 of the attached 

Multiple Parcel Form and granting Petitioner all other relief to which it is entitled 

under Michigan law. 

Respectfully Submitted, 

 

 

 

 

 

 

WILLIAMS WILLIAMS RATTNER 

 

 

 

 

 

& PLUNKETT PC 

 

 

 

 

 

 

 

By: 

/s/ Jerome P. Pesick 

 

 

 

 

 

 

 

 Jerome P. Pesick (P29039) 

Dated: May 27, 2026 

 

 

Attorneys for Petitioners

Page 4

Multiple Parcel Form Page 1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

Moceri/DM Investments, LLC, 

 

 

Docket No. 26- 

 

 

 

 

 

 

 

 

Parcel Nos. 12-19-14-152-005 

Petitioner, 

 

 

 

 

 

 

 

12-19-14-152-007 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

v. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

City of Bloomfield Hills, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Jerome P. Pesick (P29039) 

Richard E Rassel, III (P57540) 

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 Petition Multiple Parcel Form 

 

 

1. 

The values established for the Subject Properties by Respondent’s 

March 2026 Board of Review are as follows: 

Parcel No. 

True Cash Value 

Assessed Value 

Taxable Value 

12-19-14-152-005 

 1,333,260 

 666,630 

 664,410 

12-19-14-152-007 

 326,020 

 163,010 

 163,010 

Totals: 

 1,659,280 

 829,640 

 827,420 

 

 

2. 

Petitioner contends that lawful 2026 assessments for the Subject 

Properties cannot exceed the following amounts:

Page 5

Multiple Parcel Form Page 2 

Parcel No. 

True Cash Value 

Assessed Value 

Taxable Value 

12-19-14-152-005 

 640,000 

 320,000 

 320,000 

12-19-14-152-007 

 160,000 

 80,000 

 80,000 

Totals: 

 800,000 

 400,000 

 400,000 

 

 

3. 

The amounts in dispute for the 2026 tax year are therefore as follows: 

Parcel No. 

True Cash Value 

Assessed Value 

Taxable Value 

12-19-14-152-005 

 693,260 

 346,630 

 344,410 

12-19-14-152-007 

 166,020 

 83,010 

 83,010 

Totals: 

 859,280 

 429,640 

 427,420

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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

Moceri/DM Investments, LLC

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

3005 University Dr, , MI

City or Town

Auburn Hills

State

Michigan

ZIP Code

48326

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?

2

Property Address (No., Street, City, ST, ZIP) [If multiple, list first property’s address]

39515 Woodward Ave

Bloomfield Hills

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48304

Taxing Authority (City or Township)

City Of Bloomfield 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.)

Yes

 

 

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:

12-19-14-152-005

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:

666630

Current Taxable Value as established by the Board of Review:

664410

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

640000

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

320000

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

320000

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

12-19-14-152-007

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:

163010

Current Taxable Value as established by the Board of Review:

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

163010

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

160000

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

80000

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

80000

Fee Information

The filing fee is based on the greater of State Equalized Value or Taxable Value in contention. If you are appealing more than one parcel, the parcel with the 

highest State Equalized Value or Taxable Value in contention will be used to determine your filing fee, plus $25.00 will be added for each additional parcel being 

appealed.

If the State Equalized Value or Taxable Value in contention is: Your filing fee is:

 

 $100,000.00 and under $250.00

 $100,000.01 to $500,000.00 $400.00

 $Over $500,000.00 $600.00

* Plus $25.00 for each additional parcel, not to exceed a total filing fee of $2,000.00.

A fee of $250.00 is required for the filing of a Special Assessment Appeal.

A fee of $250.00 is required for the filing of an Equalization Tax Appeal.

A fee of $250.00 is required for the filing of a Non-Property Tax Appeal.

A fee of $150.00 is required for the filing of a Classification Tax Appeal

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

Petitioner or Attorney/Authorized Representative’s Signature: 

/s/ Jerome P. Pesick

Payment Information

Amount: 425

Success: True

Message: ""

Waiver Code:

Transaction Number: 26052787107359

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

Moceri/DM Investments, LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-001625

City Of Bloomfield 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: 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

Petition Page 1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

Moceri/DM Investments, LLC, 

 

 

Docket No. 26- 

 

 

 

 

 

 

 

 

Parcel Nos. 12-19-14-152-005 

Petitioner, 

 

 

 

 

 

 

 

12-19-14-152-007 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

v. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

City of Bloomfield Hills, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Jerome P. Pesick (P29039) 

Richard E Rassel, III (P57540) 

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 Moceri/DM Investments, LLC, by and through their attorneys, 

Williams Williams Rattner & Plunkett, PC, state as follows for their Entire Tribunal 

Property Tax Petition. 

The Parties 

1. 

Petitioner Moceri/DM Investments, LLC, is a Michigan limited liability 

company with its registered office located at 3005 University Dr, Auburn Hills, MI 

48326.

Page 2

Petition Page 2 

2. 

Respondent City of Bloomfield Hills is a Michigan city with its primary 

offices located at 45 E Long Lake Road, Bloomfield Hills, MI 48304. 

The Subject Properties 

3. 

Petitioner owns properties identified as follows: 

Parcel No. 

Property Address 

12-19-14-152-005 

39515 Woodward Ave 

12-19-14-152-007 

39515 Woodward Ave 

 

They are referred to collectively in this Petition as the “Subject Properties.” 

4. 

The Subject Properties are located in Oakland County and are within 

the Bloomfield Hills school district. 

5. 

Respondent possesses jurisdiction to assess and collect property taxes 

for the Subject Properties. 

The 2026 Assessments 

6. 

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

commercial real property. 

7. 

For the 2026 tax year, Respondent established the Subject Properties’ 

assessments for property taxes in the amounts set forth in paragraph 1 of the 

attached Multiple Parcel Form. 

8. 

Petitioner contends that lawful assessments of the Subject Properties 

for the 2026 tax year cannot exceed the amounts set forth in paragraph 2 of the 

attached Multiple Parcel Form. 

9. 

The amounts in dispute therefore equal the amounts identified in 

paragraph 3 of the attached Multiple Parcel Form.

Page 3

Petition Page 3 

10. 

This Petition presents issues involving the Subject Properties’ valuation 

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

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

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

involving losses should information supporting such issues become available. 

11. 

The Subject Properties’ 2026 assessments (a) violate the Michigan 

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

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

principles, and (d) otherwise violate Petitioner’s rights. 

12. 

Petitioner does not assert that the Subject Properties’ 2026 assessments 

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

overestimating the Subject Properties’ values. 

Conclusion and Request for Relief 

 

WHEREFORE, Petitioner respectfully requests that this honorable Tribunal 

enter judgment revising the Subject Properties’ 2026 assessments to amounts that do 

not exceed Petitioner’s contentions of value set forth in paragraph 2 of the attached 

Multiple Parcel Form and granting Petitioner all other relief to which it is entitled 

under Michigan law. 

Respectfully Submitted, 

 

 

 

 

 

 

WILLIAMS WILLIAMS RATTNER 

 

 

 

 

 

& PLUNKETT PC 

 

 

 

 

 

 

 

By: 

/s/ Jerome P. Pesick 

 

 

 

 

 

 

 

 Jerome P. Pesick (P29039) 

Dated: May 27, 2026 

 

 

Attorneys for Petitioners

Page 4

Multiple Parcel Form Page 1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

Moceri/DM Investments, LLC, 

 

 

Docket No. 26- 

 

 

 

 

 

 

 

 

Parcel Nos. 12-19-14-152-005 

Petitioner, 

 

 

 

 

 

 

 

12-19-14-152-007 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

v. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

City of Bloomfield Hills, 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Jerome P. Pesick (P29039) 

Richard E Rassel, III (P57540) 

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 Petition Multiple Parcel Form 

 

 

1. 

The values established for the Subject Properties by Respondent’s 

March 2026 Board of Review are as follows: 

Parcel No. 

True Cash Value 

Assessed Value 

Taxable Value 

12-19-14-152-005 

 1,333,260 

 666,630 

 664,410 

12-19-14-152-007 

 326,020 

 163,010 

 163,010 

Totals: 

 1,659,280 

 829,640 

 827,420 

 

 

2. 

Petitioner contends that lawful 2026 assessments for the Subject 

Properties cannot exceed the following amounts:

Page 5

Multiple Parcel Form Page 2 

Parcel No. 

True Cash Value 

Assessed Value 

Taxable Value 

12-19-14-152-005 

 640,000 

 320,000 

 320,000 

12-19-14-152-007 

 160,000 

 80,000 

 80,000 

Totals: 

 800,000 

 400,000 

 400,000 

 

 

3. 

The amounts in dispute for the 2026 tax year are therefore as follows: 

Parcel No. 

True Cash Value 

Assessed Value 

Taxable Value 

12-19-14-152-005 

 693,260 

 346,630 

 344,410 

12-19-14-152-007 

 166,020 

 83,010 

 83,010 

Totals: 

 859,280 

 429,640 

 427,420

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

Moceri/DM Investments, LLC

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

3005 University Dr, , MI

City or Town

Auburn Hills

State

Michigan

ZIP Code

48326

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?

2

Property Address (No., Street, City, ST, ZIP) [If multiple, list first property’s address]

39515 Woodward Ave

Bloomfield Hills

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48304

Taxing Authority (City or Township)

City Of Bloomfield 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.)

Yes

 

 

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:

12-19-14-152-005

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:

666630

Current Taxable Value as established by the Board of Review:

664410

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

640000

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

320000

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

320000

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

12-19-14-152-007

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:

163010

Current Taxable Value as established by the Board of Review:

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

163010

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

160000

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

80000

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

80000

Fee Information

The filing fee is based on the greater of State Equalized Value or Taxable Value in contention. If you are appealing more than one parcel, the parcel with the 

highest State Equalized Value or Taxable Value in contention will be used to determine your filing fee, plus $25.00 will be added for each additional parcel being 

appealed.

If the State Equalized Value or Taxable Value in contention is: Your filing fee is:

 

 $100,000.00 and under $250.00

 $100,000.01 to $500,000.00 $400.00

 $Over $500,000.00 $600.00

* Plus $25.00 for each additional parcel, not to exceed a total filing fee of $2,000.00.

A fee of $250.00 is required for the filing of a Special Assessment Appeal.

A fee of $250.00 is required for the filing of an Equalization Tax Appeal.

A fee of $250.00 is required for the filing of a Non-Property Tax Appeal.

A fee of $150.00 is required for the filing of a Classification Tax Appeal

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

Petitioner or Attorney/Authorized Representative’s Signature: 

/s/ Jerome P. Pesick

Payment Information

Amount: 425

Success: True

Message: ""

Waiver Code:

Transaction Number: 26052787107359

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.