Temperance Solar, LLC Petitioner Vs. Township Of Erie Respondent

Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

TEMPERANCE SOLAR, LLC, 

MTT DOCKET NO. 26-001323 

Petitioner, 

APPEARANCE; NOTICE OF 

APPEARANCE; PROOF OF 

vs. 

SERVICE 

ERIE TOWNSHIP, 

Respondent. 

Adam J. Brody (P62035) 

Deborah I. Ondersma (P55907) 

Attorneys for Petitioner 

Varnum LLP 

333 Bridge Street, N.W. 

P.O. Box 352 

Grand Rapids, MI 49501-0352 

Telephone: (616) 336-6000 

Email: ajbrody@varnumlaw.com 

Email: diondersma@varnumlaw.com 

Philip D. Goldsmith (P37650) 

Attorney for Respondent 

Lennard, Graham & Goldsmith, P.L.C. 

222 Washington Street 

Monroe, MI 48161 

Telephone: (734) 242-9500 

Facsimile: (734) 242-9509 

Email: pgoldsmith@Iggplc.com

Page 2

FILING OF APPEARANCE 

TO: 

MICHIGAN TAX TRIBUNAL 

PLEASE TAKE NOTICE AND FILE 

in 

this matter my Appearance on behalf of 

Respondent, Erie Township. 

Respectfully submitted, 

LENNARD, GRAHAM & GOLDSMITH, P.L.C. 

Dated: September 3, 2026 

: 

Philip D. 

Gefdsknith 

(P7650), 

NOTICE OF APPEARANCE 

TO: 

Mr. Adam J. Brody 

Mr. Deborah I. Ondersma 

Varnum LLP 

333 Bridge Street, N.-W. 

P.O. Box 352 

Grand Rapids, MI 49501-0352 

PLEASE TAKE NOTICE in this matter of the filing of my Appearance on behalf of 

Respondent, Erie Township. 

Respectfully submitted, 

LENNARD, GRAHAM & GOLDSMITH, P.L.C. 

Dated: September 3, 2026 

By: 

4 Col pnnddi— 

Philip D. Goldsmith (P7450), 

Attorney for Respondent

Page 3

PROOF OF SERVICE 

The undersigned certifies that he caused a copy of the foregoing Filing and Notice of 

Appearance, to be served upon Erie Township Assessor, Stephanie Renius at P.O. Box 187, 

Erie, 

Michigan 48133; 

Erie Township 

Clerk, 

Kimberly Cousino 

at 

P.O. 

Box 

187, 

Erie, 

Michigan 48133; Monroe County Equalization Director, Michael Woolford at 51 South Macomb 

Street, Monroe, Michigan 48161; Monroe County Clerk, Annamarie Osment at 106 East First 

Street, Monroe, 

Michigan 48161; 

Mason Consolidated School 

District, 

Attn: 

Ms. 

Rachel 

Englad, 

Secretary 

of School Board 

at 2400 Mason Eagles Drive, 

Erie, Michigan 48133; 

Michigan Department 

of Treasury, 

Attn: 

State Treasurer 

at 430 West Allegan, 

Lansing, 

Michigan 48922; and Adam J. Brody and Deborah 

I. Ondersma at Varnum LLP, 333 Bridge 

Street, N.W., 

P.O. Box 352, Grand Rapids, Michigan 49501-0352, by placement of said 

pleading, instrument, document, or paper, 

in a sealed envelope for each person to be served, 

addressed to the person or persons to be served, and having inscribed therein the return address 

of Lennard, Graham & Goldsmith, P.L.C., 222 Washington Street, Monroe, Michigan 48161- 

2146, and causing said envelope or envelopes to be either mailed or delivered with contents 

included, to the person or persons to be served, at the above-stated address or addresses, and via 

email 

at 

ajbrody@varnumlaw.com 

and diondersma@varnumlaw.com, 

on 

the 

3“ 

day 

of 

September, 2026. 

I declare that this Proof of Service has been examined by me and that the contents thereof 

are true to the best of my information, knowledge and belief. 

/ 

Philip Di Gol 

mith 

(37650), 

Attorney 

nden 

PDG/blg 

ERIE\TEMPERANCESOLAR\appearance

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 - Respondent

MTT DOCKET NO. 26-001323

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government

Township Of Erie (MONROE)

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

Philip

M.I.

D.

Last Name

Goldsmith

Firm Name (if any)

Lennard, Graham & Goldsmith, PLC

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

222 Washington Street

City or Town

Monroe

State

 Michigan

ZIP Code

48161

Telephone Number

(734)242-9500

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

pgoldsmith@lggplc.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Philip D. Goldsmith

/s/

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 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

TEMPERANCE SOLAR, LLC, 

MTT DOCKET NO. 26-001323 

Petitioner, 

PROOF OF SERVICE 

vs. 

ERIE TOWNSHIP, 

Respondent. 

Adam J. Brody (P62035) 

Deborah I. Ondersma (P55907) 

Attorneys for Petitioner 

Varnum LLP 

333 Bridge Street, N.W. 

P.O. Box 352 

Grand Rapids, MI 49501-0352 

Telephone: (616) 336-6000 

Email: ajbrody@varnumlaw.com 

Email: diondersma@varnumlaw.com 

Philip D. Goldsmith (P37650) 

Attorney for Respondent 

Lennard, Graham & Goldsmith, P.L.C. 

222 Washington Street 

Monroe, MI 48161 

Telephone: (734) 242-9500 

Facsimile: (734) 242-9509 

Email: pgoldsmith@lggplc.com

Page 2

PROOF OF SERVICE 

The undersigned certifies that he caused a copy of (1) the Entire Tribunal Property Tax 

Answer; (2) Notice of Affirmative Defenses; and (3) Proof of Service, to be served upon Erie 

Township Assessor, Stephanie Renius at P.O. Box 187, Erie, Michigan 48133; Erie Township 

Clerk, Kimberly Cousino at P.O. Box 187, Erie, Michigan 48133; Monroe County Equalization 

Director, Michael Woolford at 51 South Macomb Street, Monroe, Michigan 48161; Monroe 

County Clerk, Annamarie Osment at 106 East First Street, Monroe, Michigan 48161; Mason 

Consolidated School District, 

Attn: Ms. Rachel Englad, Secretary of School Board 

at 2400 

Mason Eagles Drive, Erie, Michigan 48133; Michigan Department of Treasury, Attn: State 

Treasurer at 430 West Allegan, Lansing, Michigan 48922; and Adam J. Brody and Deborah I. 

Ondersma at Varnum LLP, 333 Bridge Street, N.W., P.O. Box 352, Grand Rapids, Michigan 

49501-0352, by placement of said pleading, instrument, document, or paper, in a sealed envelope 

for each person to be served, addressed to the person or persons to be served, and having 

inscribed therein the return address of Lennard, Graham & Goldsmith, P.L.C., 222 Washington 

Street, Monroe, Michigan 

48161-2146, and causing said envelope or envelopes to be either 

mailed or delivered with contents included, to the person or persons to be served, at the above- 

stated 

address 

or 

addresses, 

and 

via 

email 

at 

ajbrody@varnumlaw.com 

and 

diondersma@varnumlaw.com, on the 3" day of September, 2026. 

I declare that this Proof of Service has been examined by me and that the contents thereof 

are true to the best of my information, knowledge and belief. 

Philig P. 

fo (P37650), 

Attorni 

spendent 

PDG/blg 

ERIE\TEMPERANCESOLAR 

proof

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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. 26-001323

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government

Township Of Erie (MONROE)

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

Philip

M.I.

D.

Last Name

Goldsmith

Firm Name (if any)

Lennard, Graham & Goldsmith, PLC

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

222 Washington Street

City or Town

Monroe

State

 Michigan

ZIP Code

48161

Telephone Number

(734)242-9500

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

pgoldsmith@lggplc.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Philip D. Goldsmith

/s/

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 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

TEMPERANCE SOLAR, LLC, 

Petitioner, 

VS. 

ERIE TOWNSHIP, 

Respondent. 

Adam J. Brody (P62035) 

Deborah I. Ondersma (P55907) 

Attorneys for Petitioner 

Varnum LLP 

333 Bridge Street, N.W. 

P.O. Box 352 

Grand Rapids, MI 49501-0352 

Telephone: (616) 336-6000 

Email: ajbrody@varnumlaw.com 

Email: diondersma@varnumlaw.com 

Philip D. Goldsmith (P37650) 

Attorney for Respondent 

Lennard, Graham & Goldsmith, P.L.C. 

222 Washington Street 

Monroe, MI 48161 

Telephone: (734) 242-9500 

Facsimile: (734) 242-9509 

Email: pgoldsmith@lggplc.com 

MTT DOCKET NO. 26-001323 

RESPONDENT, ERIE TOWNSHIP’S 

ANSWER TO PETITION; NOTICE 

OF AFFIRMATIVE DEFENSES

Page 2

RESPONDENT, ERIE TOWNSHIP’S ANSWER TO PETITION 

NOW COMES Respondent, 

Erie Township, by and through 

its attorneys, Lennard, 

Graham & Goldsmith, P.L.C., and for its Answer to the Petition filed by Temperance Solar, 

LLC, states as follows: 

1. 

Respondent neither admits nor denies the allegations set forth in paragraph 

1 of 

the Petition for the reason that Respondent is without sufficient information to form a belief as 

to the truth of the allegations and therefore Petitioner is left to its strict proofs. 

2. 

Respondent neither admits nor denies the allegations set forth in paragraph 2 of 

the Petition for the reason that Respondent is without sufficient information to form a belief as 

to the truth of the allegations and therefore Petitioner is left to its strict proofs. 

Responding 

further, Respondent affirmatively states that the personal property parcel no. 

set forth in the 

Petition is assigned to BGTF 11 Adonis Aggregator, LLC. 

3. 

Respondent admits that no real property is under appeal in the subject Petition. 

Responding further, the real property upon which the subject personal property 

is located 

is 

identified by permanent Parcel No. 58-05-030-027-00, which shows ownership in EEV Holdings 

Temperance, 

LLC. 

Permanent 

Parcel 

No. 

58-02-025-030-20 

is 

situated 

within 

Bedford 

Township, Monroe County, Michigan, and is not part of this Petition. 

4. 

Respondent admits the allegations set forth in paragraph 4 of the Petition insofar 

as the allegations relate to personal property Parcel No. 58-05-300-027-00 and permanent Parcel 

No. 58-05-030-027-00. 

5. 

Respondent admits the allegations set forth in paragraph 5 of the Petition. 

6. 

Respondent admits the allegations set forth in paragraph 6 of the Petition. 

7. 

Respondent admits the allegations set forth in paragraph 7 of the Petition. 

8. 

Respondent admits the allegations set forth in paragraph 8 of the Petition. 

9. 

Respondent admits the allegations set forth in paragraph 9 of the Petition. 

10. 

Respondent admits the allegations set forth in paragraph 10 of the Petition.

Page 3

11. 

Respondent acknowledges Petitioner’s contention regarding the values for the 

subject personal property, but denies that said values are accurate. 

12. 

Respondent admits the values in dispute identified by Petitioner. 

13. 

Respondent denies that Petitioner is entitled to a reduction of the property’s true 

cash, assessed, 

State equalized and taxable values as requested by Petitioner. 

Responding 

further, Respondent denies that Petitioner is entitled to a refund with interest of taxes paid due 

to the original assessment as requested by Petitioner. 

Responding further, Respondent denies 

that Respondent’s assessment was incorrect, as said assessment was based upon the process and 

procedures to value the subject personal property as outlined in the State Tax Commission 

Memorandum dated April 5, 2022. 

Finally, Respondent denies that Petitioner is entitled to any 

other relief from the Tribunal. 

14. 

Respondent neither admits nor denies the allegations set forth in paragraph 14 of 

the Petition for the reason that Respondent is without sufficient information to form a belief as 

to the truth of the allegations and therefore Petitioner is left to its strict proofs. 

15. 

Respondent denies each and every allegation set forth in paragraph 

15 of the 

Petition, including, but not limited to the allegations set forth in subparagraphs (a), (b), (c), and 

(d). 

Responding further, the Respondent affirmatively states that the 2026 values imposed on 

the subject property and the taxes to be levied and collected thereon, are valid, and were arrived 

at by Respondent following the process and procedures to value the subject personal property as 

outlined in the State Tax Commission Memo dated April 5, 2022. 

WHEREFORE,

Page 4

1.

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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. 26-001323

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government

Township Of Erie (MONROE)

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

Philip

M.I.

D.

Last Name

Goldsmith

Firm Name (if any)

Lennard, Graham & Goldsmith, PLC

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

222 Washington Street

City or Town

Monroe

State

 Michigan

ZIP Code

48161

Telephone Number

(734)242-9500

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

pgoldsmith@lggplc.com

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

Respondent or Authorized Attorney/Representative’s Signature: 

Philip D. Goldsmith

/s/

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 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

TEMPERANCE SOLAR, LLC 

 

 

 

Petitioner, 

 

 

 

MTT Docket No. 26-001323-TT 

v. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Property No.: 58-05-300-027-00 

ERIE TOWNSHIP, 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

Adam J. Brody (P62035) 

Deborah I. Ondersma (P55907) 

VARNUM LLP 

Attorneys for Petitioner 

333 Bridge Street, N.W. 

P.O. Box 352 

Grand Rapids, MI 49501-0352 

(616) 336-6000 

ajbrody@varnumlaw.com 

diondersma@varnumlaw.com

 

_____________________________________ 

 

PROOF OF SERVICE 

On the date below, I sent by U.S. certified mail, return receipt requested, a copy of the 

(1) Entire Tribunal Property Tax Petition; (2) Notice of Docket Number MTT Docket No. 

26-001323-TT; and (4) Proof of Service to: 

ASSESSOR 

Stephanie Renius, Assessor 

Erie Township 

P.O. Box 187 

Erie, MI 48133 

TOWNSHIP CLERK 

Kimberly Cousino, Clerk 

Erie Township Clerk 

P.O. Box 187 

Erie, MI 48133

Page 2

2 

 

On the date below, I sent by U.S. first class mail, a copy of the foregoing documents to: 

EQUALIZATION DIRECTOR 

Michael Woolford, Equalization Director 

Monroe County 

51 S. Macomb 

Monroe, MI 48161 

COUNTY CLERK 

Annamarie Osment, Clerk 

Monroe County 

106 E. First Street 

Monroe, MI 48161 

 

SECRETARY OF SCHOOL BOARD 

Rachel England, Secretary 

Mason Consolidated School District 

2400 Mason Eagles Drive 

Erie, MI 48133 

STATE TREASURER 

Michigan Department of Treasury 

State Treasurer 

430 West Allegan 

Lansing, MI 48922 

 

I declare that the statement above is true to the best of my information, knowledge and 

belief. 

 

Dated: August 7, 2026 

 

 

 

 

__/s/ Debbie Ryerson ____ 

 

 

 

 

 

 

 

 

Debbie Ryerson 

 

 

29426320.1

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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: 26-001323

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: TEMPERANCE SOLAR - PROOF re 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

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

TEMPERANCE SOLAR, LLC 

 

 

 

Petitioner, 

 

 

 

MTT Docket No. _______________ 

v. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Property No.: 58-05-300-027-00 

ERIE TOWNSHIP, 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

Adam J. Brody (P62035) 

Deborah I. Ondersma (P55907) 

VARNUM LLP 

Attorneys for Petitioner 

333 Bridge Street, N.W. 

P.O. Box 352 

Grand Rapids, MI 49501-0352 

(616) 336-6000 

ajbrody@varnumlaw.com 

diondersma@varnumlaw.com

 

_____________________________________ 

 

PETITION 

 

Petitioner, Temperance Solar, LLC (“Petitioner”), by and through its attorneys, 

VARNUM, LLP, states the following for its Petition against Respondent, Erie Township: 

1. 

Petitioner is a Delaware limited liability company with its principal address at 8400 

Normandale Lake Blvd, Suite 1200, Bloomington, MN 55437. 

2. 

Petitioner is the owner of and/or the party in interest with respect to the subject 

personal property (the "Property") which is located in Erie Township, Monroe County, Michigan 

and is more particularly described as:

Page 2

2 

 

 

Parcel No. 

Property Address 

58-05-300-027-00 

Personal property associated with the contiguous real 

property parcels at the following address: 820 Sterns 

Rd., Erie, Michigan 48133

 

3. 

No real property is under appeal in this Petition. However, the Property consists of 

all personal property that is located upon the contiguous real property with the following 

permanent parcel numbers: 58-05-030-027-00 and 58-02-025-030-20. 

4. 

Respondent, Erie Township, ("Respondent"), assesses, levies and collects the 

property taxes on the Property. 

5. 

The Property is in Monroe County and is located within the Mason Consolidated 

School District (also known as the Erie-Mason Consolidated School District). 

6. 

The 2026 Personal Property Statement for the subject Property was timely filed on 

February 17, 2026. Given the timely filing of the Personal Property Statement, no appeal to the 

March 2026 Board of Review was required. However, an appeal to the March Board of Review 

was made. The 2026 March Board of Review denied Petitioner’s requested relief. 

7. 

The Property is classified as industrial personal property (351). 

8. 

The Property is used as part of a solar energy facility. 

9. 

The tax year at issue is tax year 2026. 

10. 

The Tax Year 2026 values for the Property as established by Respondent through 

its Board of Review are as follows: 

Tax Year 

Parcel/Address 

True 

Cash 

Value

Assessed/State 

Equalized Value

Taxable Value 

2026

58-05-300-027-00

$32,619,738

$16,309,869

$16,309,869

Page 3

3 

 

11. 

Petitioner contends the correct values for the Property are: 

Tax Year 

Parcel/Address 

True 

Cash 

Value

Assessed/State 

Equalized Value

Taxable Value 

2026

58-05-300-027-00

$17,000,000

$8,500,000

$8,500,000

 

12. 

The values in dispute for the Property are: 

Tax Year 

Parcel/Address 

True 

Cash 

Value

Assessed/State 

Equalized Value

Taxable Value 

2026

58-05-300-027-00

$15,619,738

$7,809,869

$7,809,869

 

13. 

Petitioner requests a reduction of the Property's true cash, assessed, state equalized 

and taxable values as outlined above, which values are based on the relevant market. Petitioner 

further requests a refund with interest of taxes paid due to the original, incorrect assessment, as 

well as any other relief this Tribunal deems appropriate. 

14. 

This matter involves issues relating to (a) assessment, (b) true cash value and (c) 

taxable value. 

15. 

The 2026 values imposed on the Property, and the taxes to be levied and collected 

thereon, are invalid and unlawful and operate as fraud upon the taxpayer for the reason that: 

(a) 

The assessed, state equalized, and/or taxable values exceed the amounts 

permitted by the Michigan Constitution and applicable statutes and do not 

reflect the sales of similar properties. 

 

(b) 

The assessed, state equalized and/or taxable values are at higher percentages 

of true cash value than permissible under the Michigan Constitution and 

applicable statutes. 

 

(c) 

The assessed, state equalized and/or taxable values are based upon an 

erroneous determination of the true cash value of Petitioner’s Property and 

are based upon the application of wrong principles. 

 

(d) 

The assessed, state equalized and/or taxable values, and the mode of 

assessment adopted by Respondent, discriminate against Petitioner, its 

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

Page 4

4 

 

WHEREFORE, Petitioner requests that the

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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

Temperance Solar, LLC

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

8400 Normandale Lake Blvd.

Suite 1200

City or Town

Bloomington

State

Minnesota

ZIP Code

55437

Telephone Number

616-336-6561

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

diondersma@varnumlaw.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Deborah

M.I.

I.

Last Name

Ondersma

Firm Name (if any)

Varnum LLP

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

P.O. Box 352

City or Town

Grand Rapids

State

Michigan

ZIP Code

49501-0352

Telephone Number

616-336-6561

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

diondersma@varnumlaw.com

 

Section 3: Issue 

Please designate one: 

Valuation 

 

Section 4: Subject Property Information 

How many parcels are you 

appealing?

1

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

820 Sterns

Erie

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48133

Taxing Authority (City or Township)

Township Of Erie (MONROE) 

County

Monroe

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

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

N/A

 

 

Section 5: Check which of the following you are appealing (check all that apply) 

True Cash and Taxable Values

If “Other”, please explain:

 

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

58-05-300-027-00

Classification of Property: Personal (check one)

Industrial (check one)

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

16309869

Current Taxable Value as established by the Board of Review:

16309869

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

17000000

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

8500000

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

7809869

Fee Information

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

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

appealed.

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

 

 $100,000.00 and under $250.00

 $100,000.01 to $500,000.00 $400.00

 $Over $500,000.00 $600.00

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

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

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

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

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

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

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

Petitioner or Attorney/Authorized Representative’s Signature: 

/s/ /s/ Deborah I. Ondersma

Payment Information

Amount: 600

Success: True

Message: ""

Waiver Code:

Transaction Number: 26052386707377

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.

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

Temperance Solar, LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-001323

Township Of Erie, 

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 6, 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

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

TEMPERANCE SOLAR, LLC 

 

 

 

Petitioner, 

 

 

 

MTT Docket No. _______________ 

v. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Property No.: 58-05-300-027-00 

ERIE TOWNSHIP, 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

Adam J. Brody (P62035) 

Deborah I. Ondersma (P55907) 

VARNUM LLP 

Attorneys for Petitioner 

333 Bridge Street, N.W. 

P.O. Box 352 

Grand Rapids, MI 49501-0352 

(616) 336-6000 

ajbrody@varnumlaw.com 

diondersma@varnumlaw.com

 

_____________________________________ 

 

PETITION 

 

Petitioner, Temperance Solar, LLC (“Petitioner”), by and through its attorneys, 

VARNUM, LLP, states the following for its Petition against Respondent, Erie Township: 

1. 

Petitioner is a Delaware limited liability company with its principal address at 8400 

Normandale Lake Blvd, Suite 1200, Bloomington, MN 55437. 

2. 

Petitioner is the owner of and/or the party in interest with respect to the subject 

personal property (the "Property") which is located in Erie Township, Monroe County, Michigan 

and is more particularly described as:

Page 2

2 

 

 

Parcel No. 

Property Address 

58-05-300-027-00 

Personal property associated with the contiguous real 

property parcels at the following address: 820 Sterns 

Rd., Erie, Michigan 48133

 

3. 

No real property is under appeal in this Petition. However, the Property consists of 

all personal property that is located upon the contiguous real property with the following 

permanent parcel numbers: 58-05-030-027-00 and 58-02-025-030-20. 

4. 

Respondent, Erie Township, ("Respondent"), assesses, levies and collects the 

property taxes on the Property. 

5. 

The Property is in Monroe County and is located within the Mason Consolidated 

School District (also known as the Erie-Mason Consolidated School District). 

6. 

The 2026 Personal Property Statement for the subject Property was timely filed on 

February 17, 2026. Given the timely filing of the Personal Property Statement, no appeal to the 

March 2026 Board of Review was required. However, an appeal to the March Board of Review 

was made. The 2026 March Board of Review denied Petitioner’s requested relief. 

7. 

The Property is classified as industrial personal property (351). 

8. 

The Property is used as part of a solar energy facility. 

9. 

The tax year at issue is tax year 2026. 

10. 

The Tax Year 2026 values for the Property as established by Respondent through 

its Board of Review are as follows: 

Tax Year 

Parcel/Address 

True 

Cash 

Value

Assessed/State 

Equalized Value

Taxable Value 

2026

58-05-300-027-00

$32,619,738

$16,309,869

$16,309,869

Page 3

3 

 

11. 

Petitioner contends the correct values for the Property are: 

Tax Year 

Parcel/Address 

True 

Cash 

Value

Assessed/State 

Equalized Value

Taxable Value 

2026

58-05-300-027-00

$17,000,000

$8,500,000

$8,500,000

 

12. 

The values in dispute for the Property are: 

Tax Year 

Parcel/Address 

True 

Cash 

Value

Assessed/State 

Equalized Value

Taxable Value 

2026

58-05-300-027-00

$15,619,738

$7,809,869

$7,809,869

 

13. 

Petitioner requests a reduction of the Property's true cash, assessed, state equalized 

and taxable values as outlined above, which values are based on the relevant market. Petitioner 

further requests a refund with interest of taxes paid due to the original, incorrect assessment, as 

well as any other relief this Tribunal deems appropriate. 

14. 

This matter involves issues relating to (a) assessment, (b) true cash value and (c) 

taxable value. 

15. 

The 2026 values imposed on the Property, and the taxes to be levied and collected 

thereon, are invalid and unlawful and operate as fraud upon the taxpayer for the reason that: 

(a) 

The assessed, state equalized, and/or taxable values exceed the amounts 

permitted by the Michigan Constitution and applicable statutes and do not 

reflect the sales of similar properties. 

 

(b) 

The assessed, state equalized and/or taxable values are at higher percentages 

of true cash value than permissible under the Michigan Constitution and 

applicable statutes. 

 

(c) 

The assessed, state equalized and/or taxable values are based upon an 

erroneous determination of the true cash value of Petitioner’s Property and 

are based upon the application of wrong principles. 

 

(d) 

The assessed, state equalized and/or taxable values, and the mode of 

assessment adopted by Respondent, discriminate against Petitioner, its 

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

Page 4

4 

 

WHEREFORE, Petitioner requests that the

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

Temperance Solar, LLC

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

8400 Normandale Lake Blvd.

Suite 1200

City or Town

Bloomington

State

Minnesota

ZIP Code

55437

Telephone Number

616-336-6561

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

diondersma@varnumlaw.com

 

 

Section 2: Attorney/Authorized Representative’s Contact Information

First Name

Deborah

M.I.

I.

Last Name

Ondersma

Firm Name (if any)

Varnum LLP

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

P.O. Box 352

City or Town

Grand Rapids

State

Michigan

ZIP Code

49501-0352

Telephone Number

616-336-6561

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

diondersma@varnumlaw.com

 

Section 3: Issue 

Please designate one: 

Valuation 

 

Section 4: Subject Property Information 

How many parcels are you 

appealing?

1

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

820 Sterns

Erie

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

48133

Taxing Authority (City or Township)

Township Of Erie (MONROE) 

County

Monroe

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

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

N/A

 

 

Section 5: Check which of the following you are appealing (check all that apply) 

True Cash and Taxable Values

If “Other”, please explain:

 

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

58-05-300-027-00

Classification of Property: Personal (check one)

Industrial (check one)

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

16309869

Current Taxable Value as established by the Board of Review:

16309869

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

17000000

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

8500000

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

7809869

Fee Information

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

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

appealed.

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

 

 $100,000.00 and under $250.00

 $100,000.01 to $500,000.00 $400.00

 $Over $500,000.00 $600.00

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

Page 3

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

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

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

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

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

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

Petitioner or Attorney/Authorized Representative’s Signature: 

/s/ /s/ Deborah I. Ondersma

Payment Information

Amount: 600

Success: True

Message: ""

Waiver Code:

Transaction Number: 26052386707377

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.