Pacific Holdings 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

Pacific Holdings LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-002034

City Of Auburn Hills,

Respondent.

ORDER GRANTING JOINT MOTION TO WITHDRAW

ORDER OF DISMISSAL

The Tribunal has reviewed the file in the above-captioned case and finds that the parties 

have filed a Joint Motion to Withdraw the appeal. Therefore,

IT IS ORDERED that the parties’ Joint Motion to Withdraw is GRANTED. 

IT IS FURTHER ORDERED that this case is DISMISSED. 

This order resolves all pending issues and closes the case.

By:_____________________________________

Patricia L. Halm, Tribunal Chair

Entered: April 22, 2026

PROOF OF SERVICE

I certify that a copy of the foregoing was sent on the entry date indicated above to the 

parties or their attorneys or authorized representatives, if any, utilizing either the mailing 

or email addresses on file, as provided by those parties, attorneys, or authorized 

representatives.

By: Tribunal Clerk

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

MICHIGAN TAX TRIBUNAL · 611 W. OTTAWA ST., LANSING, MI 48933 · 517-335-9760

PO BOX 30232, LANSING, MI 48909 · Other Carriers: 2407 N. GRAND RIVER AVE., LANSING, MI 48906

Pacific Holdings LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-002034

City Of Auburn Hills,

Respondent.

ORDER GRANTING JOINT MOTION TO WITHDRAW

ORDER OF DISMISSAL

The Tribunal has reviewed the file in the above-captioned case and finds that the parties 

have filed a Joint Motion to Withdraw the appeal. Therefore,

IT IS ORDERED that the parties’ Joint Motion to Withdraw is GRANTED. 

IT IS FURTHER ORDERED that this case is DISMISSED. 

This order resolves all pending issues and closes the case.

By:_____________________________________

Patricia L. Halm, Tribunal Chair

Entered: April 22, 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

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

75267106.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Pacific Holdings LLC, 

Petitioner, 

v 

City of Auburn Hills, 

Respondent. 

MTT Docket No. 25-002034 

_____________________________________________________________________________ 

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

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 

lhallahan@hallahanlaw.com

soloughlin@hallahanlaw.com

kmelcher@hallahanlaw.com

_____________________________________________________________________________ 

Joint Motion to Withdraw Appeal 

For this Motion, the Parties state: 

The Parties agree to the Petition being withdrawn under MTTR 792.10237(4). The 

Tribunal has authority to grant this Joint Motion to Withdraw Appeal. 

WHEREFORE, the Parties request that the Tribunal enter an Order withdrawing the 

Petition, with each Party bearing its own costs for this matter.

Page 2

2 

75267106.1 

Honigman LLP 

Hallahan & Associates, P.C. 

Attorneys for Petitioner, 

Attorneys for Respondent, 

By:

By:

Jackie J. Cook (P68781) 

2290 First National Building 

660 Woodward Avenue 

Detroit, MI 48226-3506 

(313) 465-7270 

jcook@honigman.com

Laura M. Hallahan (P42101) 

Seth A. O’Loughlin (P80257) 

Kelsea M. Melcher (P85821) 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

lhallahan@hallahanlaw.com

soloughlin@hallahanlaw.com

kmelcher@hallahanlaw.com

Dated: _____________ 

Dated: _____________

/s/ Jackie J. Cook 

 

 

 /s/ Laura M. Hallahan (w/permission)

April 22, 2025 

 

 

 

 

 

April 22, 2025

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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 DECEMBER 16 - 30, 2026 PREHEARING GENERAL CALL AND 

ORDER OF PROCEDURE

Pacific Holdings LLC,

Petitioner,

v

 

 

City Of Auburn Hills,

Respondent.

 MTT Docket No. 25-002034

Please be advised that 25-002034 has been placed on a two-week Prehearing General 

Call commencing December 16, 2026. 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. 25-002034

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 August 19, 2026. 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 August 19, 2026. 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 

August 19, 2026, 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 

December 16, 2026, 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: January 16, 2026

Page 3

MTT Docket No. 25-002034

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 DECEMBER 16 - 30, 2026 PREHEARING GENERAL CALL AND

Page 5

MTT

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Page 1

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

 

 

PACIFIC HOLDINGS LLC, 

 

Petitioner, 

v 

CITY OF AUBURN HILLS, 

 

Respondent. 

MTT Docket No. 25-002034 

Parcel No. 02-14-04-476-014 

 

_____________________________________________________________________________/ 

 

JACKIE J. COOK (P68781) 

HONIGMAN LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304 

(248) 566-8474 

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: 

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. 

3. 

Respondent admits the allegations in Paragraph 3. 

4. 

Respondent admits the allegations in Paragraph 4.

Page 2

2

5. 

Respondent admits the allegations in Paragraph 5. 

6. 

Respondent admits the allegations in Paragraph 6. 

7. 

Respondent admits the allegations in Paragraph 7. 

8. 

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

of the allegations set forth in Paragraph 8 and, therefore, leaves Petitioner to its proofs. 

9. 

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

of the allegations set forth in Paragraph 9 and, therefore, leaves Petitioner to its proofs. 

 

10. 

Respondent acknowledges the issues raised by Petitioner in Paragraph 10 but denies 

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

11. 

Respondent acknowledges Petitioner’s belief of a dispute relative to the value of a 

loss but denies any such loss has occurred. 

12. 

Respondent acknowledges Petitioner’s belief of a dispute relative to the value of an 

addition but denies any merit to Petitioner’s belief. 

13. 

Respondent neither admits nor denies the allegations in Paragraph 13 as the General 

Property Tax Act speaks for itself. 

14. 

Respondent denies the allegations in Paragraph 14, 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.

Page 3

3

15. 

Respondent acknowledges the relief requested by Petitioner in the final paragraph 

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

the above Paragraphs. 

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: August 20, 2025 

(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).

Page 4

4

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. 

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 the Tribunal to grant it preference by application of a self-chosen 

method of assessment contrary to the intent, purpose and law of this State. 

8. 

Petitioner, in essence, asks the Tribunal to grant it an illegal preference by 

application of a method of assessment different from that employed in the assessment of other 

properties in Respondent’s taxing unit. 

9. 

Petitioner, in essence, seeks by petition to challenge the process of county and state 

equalization as to which it has no legal standing and cannot maintain a cause of action. 

10. 

Any decrease in the value of Petitioner’s property was a result of its own intentional 

acts and/or negligence and cannot be allowed to reduce Petitioner’s otherwise equitable tax burden. 

11. 

Respondent has properly and lawfully assessed Petitioner’s property and 

established its taxable value in

Page 5

5

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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. 25-002034

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

City Of Auburn Hills (OAKLAND)

Local Unit of Government/First Name

M.I.

Last Name

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

City or Town

State

Michigan

ZIP Code

Telephone Number

Fax 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

Hallahan

Firm Name (if any)

Hallahan & Associates, P.C.

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

248-731-3087

Fax Number

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: 

Kelsea M. Melcher

/s/

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Page 1

RECEIVED, 

_ 

Q 

N06 

Sx 

MICHIGAN TAX TRIBUNAL 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Pacific Holdings LLC, 

Petitioner, 

. 

7) 

— 

MTT Docket Nosed i O 2 A O > 7 

Vi 

Parcel No. 02-14-04-476-014 

City of Auburn Hills, 

Respondent. 

Jackie J. Cook (P68781) 

Honigman LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(313) 465-7420 

jcook@honigman.com 

Proof of Service 

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

that on 

Cf 2/ 25 

, she did serve a copy of Petitioner's Entire Tribunal Property Tax 

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

o/ 

of 

Fa 

Dated: 

b 

2/25 

Lisa Joseph

Page 2

BY CERTIFIED UNITED STATES MAIL, RETURN RECEIPT REQUESTED: 

CLERK 

AUBURN HILLS 

1827 N. SQUIRREL ROAD 

AUBURN HILLS, MI 48326-2753 

ASSESSOR 

AUBURN HILLS 

1827 N. SQUIRREL ROAD 

AUBURN HILLS, MI 48326-2753 

AND BY FIRST-CLASS UNITED STATES MAIL: 

CLERK 

OAKLAND COUNTY 

1200 N. TELEGRAPH ROAD 

PONTIAC, MI 48341-0413 

DIRECTOR OF EQUALIZATION 

OAKLAND COUNTY 

1200 N. TELEGRAPH ROAD 

PONTIAC, MI 48341-0413 

SECRETARY OF SCHOOL BOARD 

PONTIAC SCHOOL DISTRICT 

47200 WOODWARD AVENUE 

PONTIAC, MI 48342-2243 

STATE TREASURER 

MICHIGAN DEPARTMENT OF TREASURY 

TREASURY BUILDING 

430 W. ALLEGAN ST. 

LANSING, MI 48922 

25-0112

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Page 1

60723182.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Pacific Holdings LLC, 

Petitioner, 

v. 

City of Auburn Hills, 

Respondent. 

 

 

 

MTT Docket No. ________ 

Parcel No. 02-14-04-476-014 

 

 

Jackie J. Cook (P68781) 

Honigman LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(248) 566-8474 

jcook@honigman.com

 

Entire Tribunal Property Tax Petition 

Pacific Holdings LLC (“Petitioner”), through its attorneys, Honigman LLP, says: 

1. 

Petitioner's principal office address is 27750 Stansbury Blvd., Suite 200, 

Farmington Hills, MI 48334. 

2. 

Petitioner is a party in interest with respect to property taxes on tax parcel number 

02-14-04-476-014 ("Petitioner's Property"). 

3. 

Petitioner’s Property has an address of 1220 Pacific Drive, Auburn Hills, MI 48326. 

4. 

Petitioner’s Property is located in Oakland County, Michigan. 

5. 

Respondent, City of Auburn Hills, assesses and collects property taxes on 

Petitioner's Property.

Page 2

2 

60723182.1 

6. 

In 2025, Respondent determined the taxable value of Petitioner's Property to be 

$4,733,490 and assessed Petitioner's Property at $4,787,420, which will result in a state equalized 

value in the same amount based on the tentative equalization factor. 

7. 

Petitioner's Property is classified as industrial improved. 

8. 

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

9. 

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

industrial purposes. 

10. 

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

value, and (d) uniformity. 

11. 

At this time, Petitioner believes, as it relates to the calculation of taxable value, that 

there is a dispute relative to the value of any losses under MCL 211.27a(2)(a). 

12. 

At this time, Petitioner believes, as it relates to the calculation of taxable value, that 

there is a dispute relative to the value of any additions under MCL 211.27a(2)(a). 

13. 

A board of review protest was not required for Petitioner’s Property. 

14. 

The 2025 assessment, including state equalized value and taxable value, imposed 

on Petitioner's Property, and the taxes to be levied and collected on Petitioner’s Property, are 

invalid and unlawful for the following reasons: 

(a) 

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

exceeds the amount permitted by the Michigan Constitution and applicable 

statutes; 

(b) 

The assessment, including state equalized value and/or taxable value, is at 

a higher percentage of true cash value than permissible under the Michigan 

Constitution and applicable statutes;

Page 3

3 

60723182.1 

(c) 

The assessment, including taxable value and/or state equalized value, is 

based on an erroneous determination of the true cash value of that portion 

of Petitioner's Property that is taxable under Michigan law, and is 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 Respondent, discriminate against 

Petitioner and deny Petitioner its constitutional rights to uniformity, equal 

protection, and due process of law. 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order: (i) reducing the 

2025 taxable value of Petitioner's Property from $4,733,490 to $203,090; (ii) reducing the 2025 

assessed and state equalized value of Petitioner's Property from $4,787,420 to $203,090; 

(iii) requiring payment to Petitioner of the refunds attributable to such reductions, plus interest and 

costs; and (iv) awarding Petitioner any other relief to which it is entitled. 

 

 

 

 

 

 

 

 

 

Dated: May 30, 2025 

HONIGMAN LLP 

Attorneys for Petitioner 

 

 

By: _______________________________________ 

Jackie J. Cook (P68781) 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(248) 566-8474 

jcook@honigman.com

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

Pacific Holdings LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-002034

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: August 7, 2025

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

60723182.1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Pacific Holdings LLC, 

Petitioner, 

v. 

City of Auburn Hills, 

Respondent. 

 

 

 

MTT Docket No. ________ 

Parcel No. 02-14-04-476-014 

 

 

Jackie J. Cook (P68781) 

Honigman LLP 

Attorneys for Petitioner 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(248) 566-8474 

jcook@honigman.com

 

Entire Tribunal Property Tax Petition 

Pacific Holdings LLC (“Petitioner”), through its attorneys, Honigman LLP, says: 

1. 

Petitioner's principal office address is 27750 Stansbury Blvd., Suite 200, 

Farmington Hills, MI 48334. 

2. 

Petitioner is a party in interest with respect to property taxes on tax parcel number 

02-14-04-476-014 ("Petitioner's Property"). 

3. 

Petitioner’s Property has an address of 1220 Pacific Drive, Auburn Hills, MI 48326. 

4. 

Petitioner’s Property is located in Oakland County, Michigan. 

5. 

Respondent, City of Auburn Hills, assesses and collects property taxes on 

Petitioner's Property.

Page 2

2 

60723182.1 

6. 

In 2025, Respondent determined the taxable value of Petitioner's Property to be 

$4,733,490 and assessed Petitioner's Property at $4,787,420, which will result in a state equalized 

value in the same amount based on the tentative equalization factor. 

7. 

Petitioner's Property is classified as industrial improved. 

8. 

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

9. 

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

industrial purposes. 

10. 

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

value, and (d) uniformity. 

11. 

At this time, Petitioner believes, as it relates to the calculation of taxable value, that 

there is a dispute relative to the value of any losses under MCL 211.27a(2)(a). 

12. 

At this time, Petitioner believes, as it relates to the calculation of taxable value, that 

there is a dispute relative to the value of any additions under MCL 211.27a(2)(a). 

13. 

A board of review protest was not required for Petitioner’s Property. 

14. 

The 2025 assessment, including state equalized value and taxable value, imposed 

on Petitioner's Property, and the taxes to be levied and collected on Petitioner’s Property, are 

invalid and unlawful for the following reasons: 

(a) 

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

exceeds the amount permitted by the Michigan Constitution and applicable 

statutes; 

(b) 

The assessment, including state equalized value and/or taxable value, is at 

a higher percentage of true cash value than permissible under the Michigan 

Constitution and applicable statutes;

Page 3

3 

60723182.1 

(c) 

The assessment, including taxable value and/or state equalized value, is 

based on an erroneous determination of the true cash value of that portion 

of Petitioner's Property that is taxable under Michigan law, and is 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 Respondent, discriminate against 

Petitioner and deny Petitioner its constitutional rights to uniformity, equal 

protection, and due process of law. 

WHEREFORE, Petitioner requests that the Tax Tribunal enter an Order: (i) reducing the 

2025 taxable value of Petitioner's Property from $4,733,490 to $203,090; (ii) reducing the 2025 

assessed and state equalized value of Petitioner's Property from $4,787,420 to $203,090; 

(iii) requiring payment to Petitioner of the refunds attributable to such reductions, plus interest and 

costs; and (iv) awarding Petitioner any other relief to which it is entitled. 

 

 

 

 

 

 

 

 

 

Dated: May 30, 2025 

HONIGMAN LLP 

Attorneys for Petitioner 

 

 

By: _______________________________________ 

Jackie J. Cook (P68781) 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 48304-5151 

(248) 566-8474 

jcook@honigman.com

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

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

Pacific Holdings LLC

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

27750 Stansbury Blvd., Ste. 200

City or Town

Farmington Hills

State

Michigan

ZIP Code

48334

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 2: Attorney/Authorized Representative’s Contact Information

First Name

Jackie

M.I.

J.

Last Name

Cook

Firm Name (if any)

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)

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.)

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:

02-14-04-476-014

Classification of Property: Real 

Industrial

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

4787420

Current Taxable Value as established by the Board of Review:

4733490

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

406180

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

203090

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

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.