Napior Leasing, LLC Petitioner Vs. City Of Adrian Respondent

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77449536.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Napior Leasing, LLC, 

Petitioner, 

v. 

City of Adrian, 

Respondent. 

MTT Docket No. 26-000636 

Jackie J. Cook (P68781) 

Scott L. Damich (P74126) 

Honigman LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7270 

jcook@honigman.com

sdamich@honigman.com

Laura M. Hallahan (P42101)

Seth A. O’Loughlin (P80251)

Kelsea M. Melcher (P85821)

Hallahan & Associates, P.C. 

Attorneys for Respondent

1750 S. Telegraph Rd., Suite 202

Bloomfield Hills, MI 48302

(248) 731-3089 

lhallahan@hallahanlaw.com

soloughlin@hallahanlaw.com

kmelcher@hallahanlaw.com

PETITIONER’S MOTION TO COMPEL RESPONDENT’S ANSWERS TO 

INTERROGATORIES AND REQUESTS FOR PRODUCTION 

Petitioner, Napior Leasing LLC (“Petitioner”), by and through its attorneys, Honigman 

LLP, respectfully moves this Tribunal pursuant to MCR 2.313(A), as incorporated by TTR 201(5), 

for an order compelling Respondent City of Adrian ("Respondent") to provide complete, 

substantive answers to Interrogatory Nos. 4, 5, and 6, including subparts (A) through (D) for each 

Request for Admission that Respondent denied, partially denied, qualified, or was unable to admit 

in full, and to produce responsive documents concerning how Respondent valued the property. 

WHEREFORE, Petitioner respectfully requests that this Tribunal enter an order: [a] 

overruling Respondent's relevance, scope, pre-valuation discovery, MCR 2.309(A)(2), custody-

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77449536.1 

and-control, and possession objections to discovery concerning the September 19, 2025 sale of the 

subject property; [b] compelling Respondent to serve complete, substantive answers to 

Interrogatory Nos. 4, 5, and 6, including subparts (A) through (D) for each non-admitted Request 

for Admission, within fourteen (14) days, including but not limited to every fact upon which 

Respondent or its assessor relied in coding the sale “NOT USED/OTHER” on its 2026 property 

record card; [c] compelling production under Request for Production Nos. 6 and 7 of all responsive 

documents and requiring Respondent to identify any document it contends is already in Petitioner’s 

possession; [d] compelling Respondent to explain why the September 19, 2025 sale was excluded 

from its 2026 ECF Study and 2026 Land Study, to identify all sales considered and rejected for 

those studies, and to explain how the studies were applied in valuing the property; [e] compelling 

Respondent to serve answers verified under oath and signed by an authorized officer or agent of 

the City within fourteen (14) days; [f] awarding Petitioner its reasonable costs and attorney fees 

incurred in bringing this Motion pursuant to MCR 2.313(A)(5); and [g] granting such other and 

further relief as the Tribunal deems just and appropriate.

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77449536.1 

Respectfully submitted, 

HONIGMAN LLP 

Attorney for Petitioner 

By: ___/s/ Scott L. Damich 

Jackie J. Cook (P68781) 

Scott L. Damich (P74126) 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7270 

jcook@honigman.com

Dated: October 15, 2026 

sdamich@honigman.com

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77449536.1 

BRIEF IN SUPPORT OF PETITIONER’S MOTION TO COMPEL RESPONDENT’S 

ANSWERS TO INTERROGATORIES AND PRODUCTION 

I.

Introduction 

This motion turns on a simple question that Respondent refuses to answer: why does 

Respondent’s assessor believe the September 2025 sale of the subject property was not an arm’s-

length transaction? The assessor reviewed the September 2025 sale and coded it in a manner that 

appears as though the assessor believes was not arms-length. Exhibit A, Property Record Card. 

When Petitioners served discovery asking about facts bearing on the arms-length character of the 

sale, including the sale’s marketing, offers, price, type, voluntariness, and the relationship between 

buyer and seller, Respondent refused to answer, objecting that the sale is irrelevant and outside the 

scope of this appeal. Exhibit B, Respondent’s Responses to Petitioners’ Interrogatories; 

Exhibit C, Respondent’s Response to Petitioners’ Requests for Admission. Respondent’s 

assessor cannot withhold the basis for her determination the sale was not arm’s length when her 

conclusion that it wasn’t is on the assessment record. 

Respondent has not identified the facts, persons, or documents supporting its non-

admissions, has not explained how it considered the September 19, 2025 sale, and has not 

explained why its assessor coded that pre-tax-day sale “NOT USED/OTHER.” Respondent’s 

failure to provide complete and properly verified answers warrants an order compelling full 

responses. 

II.

Statement of Facts 

This matter involves the 2026 ad valorem property tax assessment of real property located 

at 1751 W. Beecher St., Adrian, Lenawee County, Michigan (Parcel No. XA0-109-1150-02). 

Respondent’s 2026 assessed and taxable value of the Property is $5,590,000, consisting of a land

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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: 26-000636

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

Party Filing Document 

Petitioner

Files

Document Type: Motion to Compel

Attachment File Name: Motion to Compel and Brief in Support - Napior Adrian (26-000636)

Fee Information

Filing Fee: $ 50.00

Payment Information

Payment: $ 50.00

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Page 1

76742601.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Napior Leasing, LLC, 

Petitioner, 

v. 

City of Adrian, 

Respondent. 

MTT Docket No. 26-000636 

Jackie J. Cook (P68781) 

Scott L. Damich (P74126) 

Honigman LLP 

Attorneys for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7270 

jcook@honigman.com

sdamich@honigman.com

Laura M. Hallahan (P42101)

Seth A. O’Loughlin (P80251)

Kelsea M. Melcher (P85821)

Hallahan & Associates, P.C. 

Attorneys for Respondent

1750 S. Telegraph Rd., Suite 202

Bloomfield Hills, MI 48302

(248) 731-3089 

lhallahan@hallahanlaw.com

soloughlin@hallahanlaw.com

kmelcher@hallahanlaw.com

Petitioner Napior Leasing, LLC’s Requests for Admission to Respondent City of Adrian 

Petitioner, Napior Leasing, LLC, by and through its attorneys, Honigman LLP, requests that 

Respondent City of Adrian respond to these Requests for Admission within 28 days of service in 

accordance with TTR 201 and MCR 2.312. 

Definitions 

1.

“Any” or “all” means “any and all.” 

2.

“Buyer” refers to Petitioner, Napior Leasing, LLC. 

3.

“Seller” refers to Fluresh, LLC. 

4.

“Case” refers to the above-captioned Tax Tribunal matter assigned Docket No. 26-

000636.

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76742601.1 

5.

“Person” includes any individual, corporation, partnership, group, association, 

union, fraternity, company, sole proprietor, store, establishment, place, firm, co-partnership, joint 

venture, government, governmental department, governmental agency or any other organization or 

entity. 

6.

“Petitioner” refers to Napior Leasing, LLC. 

7.

“Subject property” refers to the real property and personal property reported under 

tax parcel no. XA0-109-1150-02, located in Adrian, Michigan. 

8.

“Respondent,” “City,” “you,” or “your” refers to the City of Adrian, including but 

not limited to, its assessor, any member of the assessing department, the City’s March Board of 

Review members, and the City’s March Board of Review. 

Instructions 

1.

Unless specified otherwise, each Request for Admission relates to tax year 2026. 

2.

Under MCR 2.312, the answers to the Request for Admissions are to be signed and 

verified by you. 

3.

Your public assessment records for the subject property indicate Grantor Fluresh, 

LLC, sold the subject property on September 19, 2025, for $3,837,537 to Grantee Napior Leasing, 

LLC, and reference the warranty deed filed a Liber/Page 2690:0467 with your Register of Deeds. 

Any references herein to the sale of the subject property and/or purchase of the subject property 

and/or subject transaction, refer to this sale on September 19, 2025. 

Requests for Admission 

1.

Admit that Green Life Business Group, Inc. has an established relationship with 

cannabis operators worldwide. 

ANSWER

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76742601.1 

2.

Admit that Green Life Business Group, Inc. is recognized as a premier authority in 

cannabis mergers and acquisitions. 

ANSWER 

3.

Admit that Green Life Business Group, Inc. has closed over 300 cannabis 

transactions nationwide. 

ANSWER 

4.

Admit that Green Life Business Group, Inc. listed the subject property for sale on 

its national platform on March 28, 2025. 

ANSWER 

5.

Admit that Green Life Business Group, Inc. initiated a nationwide email blast 

campaign targeting cannabis operators and investors. 

ANSWER 

6.

Admit that calls for offers for the subject property were due May 16, 2025. 

ANSWER 

7.

Admit that at least three offers were made for the purchase of the subject property. 

ANSWER 

8.

Admit that Buyer signed the purchase agreement for the subject property on May 

31, 2025. 

ANSWER 

9.

Admit that Buyer purchased the subject property from Seller for $3,837,537 

ANSWER 

10.

Admit that Buyer purchased the subject property and the personal property located 

at the subject property from Seller for $6,000,000.

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76742601.1 

ANSWER 

11.

Admit that the Buyer purchased the subject property for less than the listing price. 

ANSWER 

12.

Admit that the sale of the subject property was not a private sale. 

ANSWER 

13.

Admit that the sale of the subject property was not conducted by public auction. 

ANSWER 

14.

Admit that the sale of the subject property was not a foreclosure sale. 

ANSWER 

15.

Admit that the sale of the subject property was not a sheriff’s sale. 

ANSWER 

16.

Admit that the sale of the subject property was not a tax foreclosure sale. 

ANSWER 

17.

Admit that sale of the subject property was not a bankruptcy sale. 

ANSWER 

18.

Admit that the sale of the subject property was not a liquidation sale. 

ANSWER 

19.

Admit that the sale of the subject property was not a forced sale. 

ANSWER 

20.

Admit that neither the Buyer nor the Seller was compelled by court order to 

consummate the sale. 

ANSWER 

21.

Admit that the Seller voluntarily offered the subject property for sale.

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76742601.1 

ANSWER 

22.

Admit that the Seller voluntarily entered into the purchase agreement. 

ANSWER 

23.

Admit that the Buyer and the Seller in the subjection

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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: 26-000636

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

Party Filing Document 

Petitioner

Files

Document Type: Documentation

Attachment File Name: Requests for Admission - Napior Adrian (26-000636)FINAL

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

NOTICE OF MAY 17- 28, 2027 PREHEARING GENERAL CALL AND ORDER OF 

PROCEDURE

Napior Leasing, LLC,

Petitioner,

v

 

 

City Of Adrian,

Respondent.

 MTT Docket No. 26-000636

Please be advised that 26-000636 has been placed on a two-week Prehearing General 

Call commencing May 17, 2027. Unless ordered otherwise, parties will be notified at 

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

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

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

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

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

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

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

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

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

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

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

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

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

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

Protective Order will be published.

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

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

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

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

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

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

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

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

of the Tribunal’s website. 

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

website for more information.

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MTT Docket No. 26-000636

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IT IS ORDERED that the parties shall:

a. If no valuation disclosure is required, notify the Tribunal and the opposing parties 

in writing within 21 days of entry of this order that no valuation disclosure is being 

filed. The notice shall indicate the reason or reasons why no valuation disclosure 

is required (i.e., exemption claim, etc.).

b. If a valuation disclosure is required, file and exchange their valuation disclosures 

by January 19, 2027. Valuation disclosures will not be admitted into evidence 

unless disclosed and furnished in accordance with this order (even though 

admissible) except upon a finding of good cause by the Tribunal.

IT IS FURTHER ORDERED that the parties shall file and exchange their Prehearing 

Statements by January 19, 2027. Witnesses, with the exception of rebuttal witnesses, 

will not be allowed to testify unless disclosed in the Prehearing Statement and the 

Prehearing Statement is furnished in accordance with this order except upon a finding 

of good cause by the Tribunal. Failure to file the Prehearing Statement may result in 

holding a party or parties in default. See TTR 237. 

IT IS FURTHER ORDERED that “Pre-Valuation Disclosure” discovery is CLOSED on 

January 19, 2027, which means all discovery has been requested, all Motions to 

Compel have been filed, and all requested or ordered discovery has been exchanged 

by that date. Discovery relative to the valuation disclosure prepared for purposes of 

litigating this case or the valuation expert that prepared that valuation disclosure is not 

permitted during “Pre-Valuation Disclosure” discovery.

IT IS FURTHER ORDERED that “Post-Valuation Disclosure” discovery is CLOSED on 

May 17, 2027, which means all discovery has been requested, all Motions to Compel 

have been filed, and all requested or ordered discovery has been exchanged by that 

date. “Post-Valuation Disclosure” discovery is limited to the opposing party’s valuation 

disclosure, the opposing party’s valuation expert, and the witnesses identified on the 

opposing party’s Prehearing Statement.

IT IS FURTHER ORDERED that if this case is not scheduled for a date certain 

prehearing conference during the time frame indicated it may be scheduled for a date 

certain prehearing conference at any time subsequent to

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25-0028 

75204532.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Napior Leasing, LLC, 

Petitioner, 

v 

City of Adrian, 

Respondent. 

MTT Docket No. ____________ 

Parcel No. XA0-109-1150-02 

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

Entire Tribunal Property Tax Petition 

Petitioner, Napior Leasing, LLC, by and through its attorneys, Honigman LLP, for its 

Petition against Respondent, City of Adrian, states as follows: 

1.

Petitioner, Napior Leasing, LLC (“Napior”), is a Michigan limited liability 

company. 

2.

Napior’s principal place of business is located at 2051 Traversefield Dr., Traverse 

City, MI 49686. 

3.

Napior owns and/or leases the real property assessed under tax parcel no. XA0-

109-1150-02, located at 1751 W. Beecher St. in Adrian, Lenawee County, Michigan (“the subject 

property”). 

4.

Napior is the taxpayer on the assessment roll for the subject property.

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75204532.1 

5.

For tax year 2026, the subject property parcel was classified “Commercial-

Improved.” 

6.

Napior is a party in interest with respect to the subject property’s taxable status and 

property tax assessment for the subject property under MCL 205.735a. 

7.

The subject property was designed and is presently used for agricultural purposes. 

8.

Respondent, City of Adrian (“City”), is a city located in Lenawee County, 

Michigan. 

9.

The Tax Tribunal has jurisdiction under MCL 205.735a. 

10.

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

value, and (d) uniformity. 

11.

For tax year 2026, the City and its board of review determined a taxable value of 

$5,590,000 and assessed value of $5,590,000 for the subject real property, reported under parcel 

no. XA0-109-1150-02, which will result in a state equalized value in the same amount based on 

the tentative equalization factor. 

12.

At this time, Napior believes that the assessed value is more than 50% of the subject 

real property’s true cash value and, thus, the taxable value is also improper. 

13.

Napior asserts the true cash value of the subject real property is $3,837,000, 

resulting in an assessed and taxable value of $1,918,500. 

14.

The value in contention, equal to the difference between the values on the tax roll 

and Napior’s contended value is $3,671,500 (assessed and taxable value). 

15.

The 2026 assessment, including state equalized value, and taxable value, on the 

subject real property, and the taxes to be levied and collected, are invalid, unlawful, and operate 

as a fraud on Napior as: 

a. 

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

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75204532.1 

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 state equalized value and/or taxable value, is based on 

an erroneous determination of the true cash value of that portion of the subject real 

property that is taxable under Michigan law and based on the application of wrong 

principles; and 

d. 

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

of assessment adopted by the City, discriminate against Napior and deny Napior its 

constitutional rights to uniformity, equal protection and due process of law. 

WHEREFORE, Napior respectfully requests that the Tax Tribunal enter an Order reducing 

the 2026 assessed value, state equalized value, and taxable value of the subject real property, 

reported under tax parcel no. XA0-109-1150-02, to $1,918,500, and requiring the City to pay 

Napior the refunds attributable to such reductions, plus interest, attorneys’ fees and costs. 

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

Dated: April 17, 2026

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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

Napior Leasing, LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-000636

City Of Adrian, 

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: May 27, 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 

 

Napior Leasing LLC, 

 

 

 

Petitioner, 

 

v 

 

City of Adrian, 

 

 

 

Respondent. 

 

 

 

MTT Docket No. 26-000636 

 

Parcel No. XA0-109-1150-02 

 

_____________________________________________________________________________/ 

 

JACKIE J. COOK (P68781) 

HONIGMAN LLP 

Attorney for Petitioner 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7270 

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 Adrian, by and through its attorneys, Hallahan & Associates, P.C., 

responds to the allegations made in Petitioner’s Petition as follows: 

1. 

Respondent lacks the information and knowledge necessary to respond to the 

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

2. 

Respondent lacks the information and knowledge necessary to respond to the 

truth of the allegations set forth in Paragraph 2 and, therefore, leaves Petitioner to its proofs.

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3. 

Respondent admits the identified address corresponds to the identified parcel of 

property. Respondent lacks the information and knowledge necessary to respond to the truth of 

the remaining allegations set forth in Paragraph 3 and, therefore, leaves Petitioner to its proofs. 

4. 

Respondent admits the allegations in Paragraph 4 as they pertain to the 2026 tax 

year. 

5. 

Respondent admits the allegations in Paragraph 5. 

6. 

Respondent neither admits nor denies the allegations set forth in Paragraph 6 and 

leaves Petitioner to its proofs. 

7. 

Respondent denies the allegations set forth in Paragraph 7 for the reason that the 

same are untrue. 

8. 

Respondent admits the allegations in Paragraph 8. 

9. 

Respondent neither admits nor denies the allegations set forth in Paragraph 9 as 

MCL 205.735a, the General Property Tax Act, and the Tax Tribunal Act speak for themselves. 

10. 

Respondent acknowledges the issues raised by Petitioner in Paragraph 10 but 

denies that Petitioner’s claims have merit or that Petitioner is entitled to any relief. 

11. 

The values for the property identified above as established by Respondent’s 

Board of Review are: 

Tax Year 

True Cash Value 

Assessed Value 

Taxable Value 

2026 

$11,180,000 

$5,590,000 

$5,590,000 

 

12. 

Respondent denies the allegations in Paragraph 12 for the reason that the same are 

untrue. 

13. 

Respondent contends that the values for the property identified above are: 

 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$11,180,000 

$5,590,000 

$5,590,000

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14. 

The values in dispute for the property identified above are: 

 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2026 

$0 

$0 

$0 

 

15. 

Respondent denies the allegations in Paragraph 15, including all subparagraphs, 

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. 

16. 

Respondent acknowledges the relief requested by Petitioner in the final paragraph 

of its Petition but denies that Petitioner is entitled to the requested relief due to the statements in 

the above Paragraphs. 

WHEREFORE, Respondent, City of Adrian, 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: May 15, 2026 

(248) 731-3089

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AFFIRMATIVE DEFENSES 

 

Respondent, City of Adrian, 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,

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Entire Tribunal Case Information Sheet - Respondent

MOAHR DOCKET NO. 26-000636

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government

City Of Adrian (LENAWEE)

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.

Last Name

Hallahan

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

Telephone Number

248-731-3089

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

mtt@hallahanlaw.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

/s/Kelsea M. Melcher

/s/

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Napior Leasing, LLC, 

Petitioner, 

v. 

MTT Docket No. Alo 

O80 vs lo 

Parcel No. XA0-109-1150-02 

City of Adrian, 

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 

that on 

4 [12 

[2 {_, she did serve a copy of Petitioner's Entire Tribunal Property Tax 

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

/5/ 

hh 

Dated: 

/ 

Lisa Joseph 

75204532.1

Page 2

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

ADRIAN 

135 E. MAUMEE STREET 

ADRIAN, MI 49221 

ASSESSOR 

ADRIAN 

135 E. MAUMEE STREET 

ADRIAN, MI 49221 

AND BY FIRST-CLASS UNITED STATES MAIL: 

CLERK 

LENAWEE COUNTY 

425 N. MAIN STREET 

ADRIAN, MI 49221-2103 

DIRECTOR OF EQUALIZATION 

LENAWEE COUNTY 

425 N. MAIN STREET 

ADRIAN, MI 49221-2103 

SECRETARY OF SCHOOL BOARD 

ADRIAN PUBLIC SCHOOLS 

785 RIVERSIDE AVE., STE. 

1 

ADRIAN, MI 49221-1404 

STATE TREASURER 

MICHIGAN DEPARTMENT OF TREASURY 

TREASURY BUILDING 

430 W. ALLEGAN ST. 

LANSING, MI 48922 

25-0028 

25-0028 

75204532.1

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Page 1

25-0028 

75204532.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Napior Leasing, LLC, 

Petitioner, 

v 

City of Adrian, 

Respondent. 

MTT Docket No. ____________ 

Parcel No. XA0-109-1150-02 

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

Entire Tribunal Property Tax Petition 

Petitioner, Napior Leasing, LLC, by and through its attorneys, Honigman LLP, for its 

Petition against Respondent, City of Adrian, states as follows: 

1.

Petitioner, Napior Leasing, LLC (“Napior”), is a Michigan limited liability 

company. 

2.

Napior’s principal place of business is located at 2051 Traversefield Dr., Traverse 

City, MI 49686. 

3.

Napior owns and/or leases the real property assessed under tax parcel no. XA0-

109-1150-02, located at 1751 W. Beecher St. in Adrian, Lenawee County, Michigan (“the subject 

property”). 

4.

Napior is the taxpayer on the assessment roll for the subject property.

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75204532.1 

5.

For tax year 2026, the subject property parcel was classified “Commercial-

Improved.” 

6.

Napior is a party in interest with respect to the subject property’s taxable status and 

property tax assessment for the subject property under MCL 205.735a. 

7.

The subject property was designed and is presently used for agricultural purposes. 

8.

Respondent, City of Adrian (“City”), is a city located in Lenawee County, 

Michigan. 

9.

The Tax Tribunal has jurisdiction under MCL 205.735a. 

10.

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

value, and (d) uniformity. 

11.

For tax year 2026, the City and its board of review determined a taxable value of 

$5,590,000 and assessed value of $5,590,000 for the subject real property, reported under parcel 

no. XA0-109-1150-02, which will result in a state equalized value in the same amount based on 

the tentative equalization factor. 

12.

At this time, Napior believes that the assessed value is more than 50% of the subject 

real property’s true cash value and, thus, the taxable value is also improper. 

13.

Napior asserts the true cash value of the subject real property is $3,837,000, 

resulting in an assessed and taxable value of $1,918,500. 

14.

The value in contention, equal to the difference between the values on the tax roll 

and Napior’s contended value is $3,671,500 (assessed and taxable value). 

15.

The 2026 assessment, including state equalized value, and taxable value, on the 

subject real property, and the taxes to be levied and collected, are invalid, unlawful, and operate 

as a fraud on Napior as: 

a. 

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

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3 

75204532.1 

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 state equalized value and/or taxable value, is based on 

an erroneous determination of the true cash value of that portion of the subject real 

property that is taxable under Michigan law and based on the application of wrong 

principles; and 

d. 

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

of assessment adopted by the City, discriminate against Napior and deny Napior its 

constitutional rights to uniformity, equal protection and due process of law. 

WHEREFORE, Napior respectfully requests that the Tax Tribunal enter an Order reducing 

the 2026 assessed value, state equalized value, and taxable value of the subject real property, 

reported under tax parcel no. XA0-109-1150-02, to $1,918,500, and requiring the City to pay 

Napior the refunds attributable to such reductions, plus interest, attorneys’ fees and costs. 

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

Dated: April 17, 2026

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Entire Tribunal Case Information Sheet - Petitioner

MOAHR DOCKET NO. 

Section 1: Petitioner’s Contact Information

Filer type: Organization

First Name/Company Name

M.I.

Last Name

Napior Leasing, LLC

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

2051 Traversefield Dr.

City or Town

Traverse City, MI

State

Michigan

ZIP Code

49686

Telephone Number

3134657270

Fax Number

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

ljoseph@honigman.com

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

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

248-566-8474

Fax Number

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

jcook@honigman.com

Section 5: Issue

Please designate one: 

Valuation – Fill out Sections 4, 5, & 6 below

Section 6: Subject Property Information

How many parcels are you 

appealing?1

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

Michigan

Taxing Authority (City or Township)

Township Of Adrian (LENAWEE)

County

Lenawee

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

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

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

Section 7: Check which of the following you are appealing (check all that apply)

True Cash and Taxable Values

Section 8: Valuation Information for Each Parcel under Appeal

Parcel Number:

XA0-109-1150-02

Classification of Property: Real 

Agricultural

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

5590000

Current Taxable Value as established by the Board of Review:

5590000

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

3837000

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

1918500

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

Section 9: Assessment Information

Type of Tax Assessment(s):

Assessment Number(s):

Check all that is being appealed: 

Check what action prompted this appeal:

If “other,” please explain:

Section 10: Special Assessment Information

Type of Special Assessment:

Did you protest the special assessment at the hearing held to confirm the special assessment roll? 

If Yes, what was the date of the hearing held to confirm the special assessment roll?

If No, please explain:

Section 11: Classification Information

Parcel Number:

Current Classification of Property as established by Board of Review: 

What do you believe is the property’s classification?

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

ORLENE HAWKS

DIRECTOR

If improved property, how is the property currently being used?

If improved property, for what use was the property designed?

Fee Information

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

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

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

 

 $100,000.00 and under $250.00

 $100,000.01 to $500,000.00 $400.00

 $Over $500,000.00 $600.00

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

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

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

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

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

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

Petitioner or Attorney/Authorized Representative’s Signature: 

/s/ Jackie J. Cook

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