Warren Manor Equities LLC, Petitioner Vs. City Of Warren, 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

Warren Manor Equities LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-002540

City Of Warren,

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: November 25, 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

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

Warren Manor Equities LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-002540

City Of Warren,

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: November 25, 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

Page 3

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

Warren Manor Equities LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-002540

City Of Warren,

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: November 25, 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

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

Warren Manor Equities LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

 

 ENTIRE TRIBUNAL

v 

 MTT Docket No. 25-002540

City Of Warren,

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: November 25, 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

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 TAX TRIBUNAL 

‘Warren Manor Equities LLC 

Petitioner, 

v. 

DOCKET#: 

25-002540 

City of Warren, 

Respondent. 

Parcel ID: 

12-13-31-301-013 

12-13-31-301-012. 

STIPULATION TO WITHDRAW PETITION 

Petitioner, Warren Manor Equities, LLC, and Respondent, City of Warren, through their 

respective authorized representatives, hereby stipulate and agree as follows: 

1. 

Withdrawal of Petition. 

Petitioner voluntarily withdraws the above-captioned property tax appeal filed with the 

Michigan Tax Tribunal concerning the assessment ofthe property identified hereinabove. 

2. 

No Further Tribunal Action Needed. 

The parties agree that this withdrawal resolves all issues raised in this appeal and that no 

further action by the Tribunal is required, except for entry ofan order acknowledging the 

withdrawal. 

3. 

No Admission.

Page 2

4. 

Costs and Fees. 

Each party shall be responsible for its own costs, fees, and expenses incurred in 

connection with this appeal, unless otherwise stated below: 

5. 

Authority to Sign. 

The individuals executing this stipulation represent that they are authorized to do so on 

behalf oftheir respective parties. 

Signatures 

PETITIONER 

Name: Stephen 

Polter (P72591) Title/Capacity: 

Counsel 

for 

Pgtitioner 

Signature! 

A IMAD-(2 

Date: Nov 

ag 

RESPONDENT 

Name: Laura Sullivaf) 

(P42021) 

Title/Capacity: A; 

t=3 

ttorney III 

yan 

er 18,2025 

p—

Page 3

POLTER LAW GROUP 

2600 W. BIG BEAVER, SUITE L100 

| TROY, MI 48084 

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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

NOTICE OF OCTOBER 1 - 15, 2026 PREHEARING GENERAL CALL AND ORDER 

OF PROCEDURE

Warren Manor Equities LLC,

Petitioner,

v

 

 

City Of Warren,

Respondent.

 MTT Docket No. 25-002540

Please be advised that 25-002540 has been placed on a two-week Prehearing General 

Call commencing October 01, 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. 25-002540

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 June 4, 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 June 4, 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 

June 4, 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 

October 1, 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: November 3, 2025

Page 3

MTT Docket No. 25-002540

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

Page 4

STA

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Page 1

RECEIVED 

JUL 2 9 2025 

MICHIGAN TAX TRIBUNAL 

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

Warren Manor Equities LLC: 

, 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

v 

MTT Docket No.25-002540 

City of Warren 

Respondent(s) 

PROOF OF SERVICE FOR PROPERTY TAX PETITION 

*To be filed after the Tribunal issues the Notice of Docket Number* 

Stephen Polter 

states that on July22, 2025 

he/she 

[Name of person serving/mailing petition] 

[date of service] 

served a copy of the Petition relative to the above-captioned matter upon: 

[Provide name and address of the following entities] 

1. Assessor (via certified mail): 

1 City Square # 310, Warren, MI- 48093 

2. 

City Clerk or Township Supervisor/Clerk (via certified mail): 

1 City Square # 310, Warren, MI 48093 

3. 

County Equalization Director (via first class mail or personal service): 

1 S Main St 6th floor, Mt Clemens, MI 48043 

4. 

County Clerk (via first class mail or personal service): 

120 N Main St, Mt Clemens, MI 48043 

5. 

Secretary of the local school board (via first class mail or personal service): 

12900 Frazho, Warren MI 48089 

6. 

State Treasurer (via first class mail):

Page 2

Polter Lad Cre -EFTR 

sessed 

IRC 

: 

a 

a ASAE 

—- 

A 

<_ 

ew

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

V. 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

CITY OF WARREN, 

WARREN MANOR EQUITIES LLC, 

MTT Docket No. 25-002540 

Parcel ID Nos. 12-13-31-301-013, 

Petitioner, 

12-13-31-301-012 

Respondent. 

STEPHEN POLTER 

POLTER LAW GROUP 

Representative for Petitioner 

2600 W. Big Beaver Rd., Ste. L100 

Troy, MI 48084 

(248) 213-6800 

spolter@polterlaw.com 

MARY MICHAELS (P44601) 

LAURA SULLIVAN (P42021) 

WARREN CITY ATTORNEY'S OFFICE 

Attorneys for Respondent 

One City Square, Suite 400 

Warren, Michigan 48093 

(586) 574-4671 

Isullivan@cityofwarren.org 

RESPONSE TO PETITION 

NOW COMES Respondent, CITY OF WARREN, by and through 

its attorneys, MARY 

MICHAELS, Acting City Attorney, and LAURA SULLIVAN, Assistant City Attorney, and for its 

Response to the Petition states as follows: 

1. 

2. 

Paragraph 

1 is not contested. 

Paragraph 2 is not contested.

Page 2

7. 

Paragraph 7 is not applicable, as 

it does not state anything. 

8. 

Paragraph 8 is not applicable, as it does not state anything. 

9. 

Paragraph 9 is not applicable, as 

it does not state anything. 

10. 

Paragraph 10 is not contested. 

11. 

Paragraph 11 

is not contested. 

12. 

In response to Paragraph 

12, Respondent 

is without knowledge or information 

sufficient to form a belief as to Paragraph 12, and leaves Petitioner to its proofs. 

13. 

In response to Paragraph 

13, Respondent is without knowledge or information 

sufficient to form a belief as to Paragraph 13, and leaves Petitioner to its proofs. 

14. 

Paragraph 14 is not contested. 

15. 

In response to Paragraph 15 is not applicable, as it does not state anything. 

16. 

Paragraph 16 is not contested, except that the True Cash Values on the Subject 

Property Tax Records are $13,634,481 and $5,719,274, respectively. 

17. 

Paragraph 17 is not applicable, as 

it does not state anything except for “2025.” 

18. 

Paragraph 18 is not applicable, as 

it does not state anything except for “2025.” 

19. 

In response to Paragraph 19, Respondent denies that the Respondent's figures 

are not accurate and leaves Plaintiff's to its proofs. 

20. 

Paragraph 20 is not applicable, as it does not state anything. 

WHEREFORE, 

Respondent, 

CITY 

OF WARREN, 

requests 

the 

Tribunal 

deny 

the 

requested relief and dismiss the Petition with prejudice. 

Respectfully submitted,

Page 3

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

WARREN MANOR EQUITIES LLC, 

MTT Docket No. 25-002540 

Parcel ID Nos. 12-13-31-301-013, 

Petitioner, 

12-13-31-301-012 

V. 

CITY OF WARREN, 

Respondent. 

STEPHEN POLTER 

POLTER LAW GROUP 

Representative for Petitioner 

2600 W. Big Beaver Rd., Ste. L100 

Troy, MI 48084 

(248) 213-6800 

spolter@polterlaw.com 

MARY MICHAELS (P44601) 

LAURA SULLIVAN (P42021) 

WARREN CITY ATTORNEY'S OFFICE 

Attorneys for Respondent 

One City Square, Suite 400 

Warren, Michigan 48093 

(586) 574-4671 

Isullivan@cityofwarren.org 

RESPONSE TO MULTIPLE PARCEL PETITION 

NOW COMES Respondent, CITY OF WARREN, 

by and through 

its attorneys, MARY 

MICHAELS, Acting City Attorney, and LAURA SULLIVAN, Assistant City Attorney, and for its 

Response to the Multiple Parcel Petition states as follows: 

1. 

Paragraph 

1 is not contested. 

2. 

Paragraph 2 is not contested, except that the True Cash Values on the Subject

Page 4

4. 

In response to Paragraph 4 Respondent is without knowledge or information 

sufficient to form a belief as to the remainder of Paragraph 4, and leaves Petitioner to its proofs. 

WHEREFORE, 

Respondent, 

CITY OF WARREN, 

requests 

the 

Tribunal 

deny 

the 

requested relief and dismiss the Petition with prejudice. 

Respectfully submitted, 

[s/Laura Sullivan 

LAURA SULLIVAN (P42021) 

Assistant City Attorney Ill 

One City Square, Suite 400 

Warren, Michigan 48093 

(586) 574-4671 

Isullivan@cityofwarren.org 

Dated: 

July 18, 2025 

ID 113726

Page 5

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

WARREN MANOR EQUITIES LLC, 

MTT Docket No. 25-002540 

Parcel ID Nos. 12-13-31-301-013, 

Petitioner, 

12-13-31-301-012 

v. 

CITY OF WARREN, 

Respondent. 

STEPHEN POLTER 

POLTER LAW GROUP 

Representative for Petitioner 

2600 W. Big Beaver Rd., Ste. L100 

Troy, MI 48084 

(248) 213-6800 

spolter@polterlaw.com 

MARY MICHAELS (P44601) 

LAURA SULLIVAN (P42021) 

WARREN CITY ATTORNEY'S OFFICE 

Attorneys for Respondent 

One City Square, Suite 400 

Warren, Michigan 48093 

(586) 574-4671 

Isullivan@cityofwarren.org 

AFFIRMATIVE DEFENSES 

NOW COMES Respondent, CITY OF WARREN, by and through 

its attorneys, MARY 

MICHAELS, Acting City Attorney, and LAURA SULLIVAN, Assistant City Attorney, and for its 

Affirmative Defenses states as follows: 

1. 

Petitioner failed 

to allege specific and sufficient facts 

to set forth 

a cause 

of 

action.

Page 6

4. 

Petitioner failed to allege specific and sufficient facts to establish fraud, — of 

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

agents. 

5, 

Petitioner 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 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

Page 7

STAT

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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. 25-002540

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

City Of Warren (MACOMB)

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.

Last Name

Sullivan

Firm Name (if any)

City of Warren Attorney's Office

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

One City Square

Suite 400

City or Town

Warren

State

Michigan

ZIP Code

48093

Telephone Number

586-574-4671

Fax Number

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

lsullivan@cityofwarren.org

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

Respondent or Authorized Attorney/Representative’s Signature: 

Laura Sullivan

/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

V. 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

CITY OF WARREN, 

WARREN MANOR EQUITIES LLC, 

MTT Docket No. 25-002540 

Parcel ID Nos. 12-13-31-301-013, 

Petitioner, 

12-13-31-301-012 

Respondent. 

STEPHEN POLTER 

POLTER LAW GROUP 

Representative for Petitioner 

2600 W. Big Beaver Rd., Ste. L100 

Troy, MI 48084 

(248) 213-6800 

spolter@polterlaw.com 

MARY MICHAELS (P44601) 

CANDICE M. MAYER (P85421) 

WARREN CITY ATTORNEY'S OFFICE 

Attorneys for Respondent 

One City Square, Suite 400 

Warren, Michigan 48093 

(586) 574-4671 

cmayer@cityofwarren.org 

RESPONSE TO PETITION 

NOW COMES Respondent, CITY OF WARREN, by and through 

its attorneys, MARY 

MICHAELS, Acting City Attorney, and LAURA SULLIVAN, Assistant City Attorney, and for its 

Response to the Petition states as follows: 

1. 

2. 

Paragraph 

1 

is not contested. 

Paragraph 2 is not contested.

Page 2

7. 

Paragraph 7 is not applicable, as 

it does not state anything. 

8. 

Paragraph 8 is not applicable, as 

it does not state anything. 

9. 

Paragraph 9 is not applicable, as 

it does not state anything. 

10. 

Paragraph 10 is not contested. 

11. 

Paragraph 11 is not contested. 

12. 

In response to Paragraph 

12, Respondent is without knowledge or information 

sufficient to form a belief as to Paragraph 12, and leaves Petitioner to its proofs. 

13. 

In response to Paragraph 

13, Respondent is without knowledge or information 

sufficient to form a belief as to Paragraph 13, and leaves Petitioner to its proofs. 

14. 

Paragraph 14 is not contested. 

15. 

In response to Paragraph 15 is not applicable, as it does not state anything. 

16. 

Paragraph 16 is not contested, except that the True Cash Values on the Subject 

Property Tax Records are $13,634,481 and $5,719,274, respectively. 

17. 

Paragraph 17 is not applicable, as it does not state anything except for “2025.” 

18. 

Paragraph 18 is not applicable, as it does not state anything except for “2025.” 

19. 

In response to Paragraph 19, Respondent denies that the Respondent's figures 

are not accurate and leaves Plaintiff's to its proofs. 

20. 

Paragraph 20 is not applicable, as it does not state anything. 

WHEREFORE, 

Respondent, 

CITY 

OF WARREN, 

requests 

the 

Tribunal 

deny 

the 

requested relief and dismiss the Petition with prejudice. 

Respectfully submitted,

Page 3

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

WARREN MANOR EQUITIES LLC, 

MTT Docket No. 25-002540 

Parcel ID Nos. 12-13-31-301-013, 

Petitioner, 

12-13-31-301-012 

V. 

CITY OF WARREN, 

Respondent. 

STEPHEN POLTER 

POLTER LAW GROUP 

Representative for Petitioner 

2600 W. Big Beaver Rd., Ste. L100 

Troy, MI 48084 

(248) 213-6800 

spolter@polterlaw.com 

MARY MICHAELS (P44601) 

CANDICE M. MAYER (P85421) 

WARREN CITY ATTORNEY'S OFFICE 

Attorneys for Respondent 

One City Square, Suite 400 

Warren, Michigan 48093 

(586) 574-4671 

cmayer@cityofwarren.org 

RESPONSE TO MULTIPLE PARCEL PETITION 

NOW COMES Respondent, CITY OF WARREN, by and through 

its attorneys, MARY 

MICHAELS, Acting City Attorney, and LAURA SULLIVAN, Assistant City Attorney, and for its 

Response to the Multiple Parcel Petition states as follows: 

1. 

Paragraph 

1 is not contested. 

2. 

Paragraph 2 is not contested, except that the True Cash Values on the Subject

Page 4

4, 

In response to Paragraph 4 Respondent is without knowledge or information 

sufficient to form a belief as to the remainder of Paragraph 4, and leaves Petitioner to its proofs. 

WHEREFORE, 

Respondent, 

CITY 

OF WARREN, 

requests 

the 

Tribunal 

deny 

the 

requested relief and dismiss the Petition with prejudice. 

Respectfully submitted, 

[s/Laura Sullivan 

LAURA SULLIVAN (P42021) 

Assistant City Attorney Ill 

One City Square, Suite 400 

Warren, Michigan 48093 

(586) 574-4671 

Dated: 

July 18, 2025 

Isullivan@cityofwarren.org 

ID 113726

Page 5

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

WARREN MANOR EQUITIES LLC, 

MTT Docket No. 25-002540 

Parcel ID Nos. 12-13-31-301-013, 

Petitioner, 

12-13-31-301-012 

V. 

CITY OF WARREN, 

Respondent. 

STEPHEN POLTER 

POLTER LAW GROUP 

Representative for Petitioner 

2600 W. Big Beaver Rd., Ste. L100 

Troy, MI 48084 

(248) 213-6800 

spolter@polterlaw.com 

MARY MICHAELS (P44601) 

CANDICE M. MAYER (P85421) 

WARREN CITY ATTORNEY'S OFFICE 

Attorneys for Respondent 

One City Square, Suite 400 

Warren, Michigan 48093 

(586) 574-4671 

cmayer@cityofwarren.org 

AFFIRMATIVE DEFENSES 

NOW COMES Respondent, CITY OF WARREN, 

by and through 

its attorneys, MARY 

MICHAELS, Acting City Attorney, and LAURA SULLIVAN, Assistant City Attorney, and for its 

Affirmative Defenses states as follows: 

1. 

Petitioner failed 

to allege specific and sufficient facts 

to set forth 

a cause 

of 

action.

Page 6

4, 

Petitioner 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 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 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

Page 7

STAT

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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. 25-002540

Section 1: Respondent’s Contact Information

Filer Type: Local Unit of Government

City Of Warren (MACOMB)

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.

Last Name

Sullivan

Firm Name (if any)

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

One City Square

Suite 400

City or Town

Warren

State

Michigan

ZIP Code

48093

Telephone Number

586-574-4671

Fax Number

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

lsullivan@cityofwarren.org

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

Respondent or Authorized Attorney/Representative’s Signature: 

Laura Sullivan

/s/

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Page 1

RECEIVED 

JUN 02 2025 

MICHIGAN TAX TRIBUNAL 

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

WARREN MANOR EQUITIES LLC 

, 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

v 

MTT Docket No. 

CITY OF WARREN 

, 

Respondent(s) 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

1. 

Property Parcel No: attached 

(If more than one parcel is at issue, attach a completed Multiple Parcel Petition 

Form addressing all other parcels at issue.) 

2. 

The property identified above is 

Xx real ___ personal. 

3. 

If more than one parcel of real property is under appeal, are the properties 

contiguous? ___ Yes ___ No. 

(If no, separate Petitions are required for each non- 

contiguous parcel.) 

4. 

Are all of the parcels of personal property located on a parcel of real property 

under appeal? ___ Yes ___ No. 

(If no, separate Petitions are required for each 

parcel of personal property not located on a parcel of real property under 

appeal.) 

5. 

If parcels of personal property are under appeal, when were the personal 

property statements filed by parcel number (attach additional page if necessary): 

6. 

The property identified above is classified as 201Comm

Page 2

MTT Docket No. 

Page 2 of 4 

10. 

11. 

12. 

13. 

If a protest was required and no protest was made, list the separate and specific 

facts upon which Petitioner relies to invoke the Tribunal's authority over the 

assessment or assessments at issue (attach additional page if necessary): 

If the appeal was not submitted by the deadline for the filing of an appeal for the 

classification or classifications of the properties at issue (i.e., May 31 or July 31 

of the tax year involved), list the separate and specific facts upon which 

Petitioner relies to invoke the Tribunal’'s authority over the assessment or 

assessments at issue (attach additional page if necessary): 

The property or properties at issue are located in Macomb 

County. The 

property or properties’ address is: 

21516 Dequindre /2 £578 

Warren MI 

The assessment or assessments at issue were established by the (applicable 

local governmental unit): Warren 

Petitioner's legal residence or principal office address is: 

5308 13 Ave., Ste 270 

Bklyn, NY 11219 

This appeal involves issues relating to the (check all that are applicable): 

X 

the property or properties’ true cash and taxable values 

the property or properties’ taxable value only 

If the property or properties’ taxable value is at issue, is there a 

dispute as to the value of an addition or loss? ___ Yes ___No 

uniformity of the property or properties’ assessment

Page 3

MTT Docket No. 

Page 3 of 4 

15. 

If more than the current tax year is being appealed, list the separate and specific 

facts upon which Petitioner relies to invoke the Tribunal's authority over the prior 

tax vear or years (attach additional page if necessary): 

16. 

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 

2025 

attached 

17. 

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

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2025 

18. 

The values in dispute for the property identified above are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2025 

19. 

Petitioner requests the following relief (attach additional page if necessary): 

Reduction of TCV and accordingly AV/TV to more reflect these accurate figures based on comps, 

condition, income, vacancy, etc.

Page 4

MTT Docket No. 

Page 4 of 4 

Authorized Representative or, if none, Petitioner: 

Printed Name of Petitioner's Authorized Representative or, if none, Petitioner: 

Stephen Polter 

Email Address: spolter@polterlaw.com 

Mailing Address: 

2600 W Big Beaver, Ste L100, Troy, MI 48084 

Telephone Number: 248-213-6800 

Date: May 25, 2025

Page 5

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

LANSING 

MARLON I. BROWN, DPA 

DIRECTOR 

GRETCHEN WHITMER 

GOVERNOR 

WARREN MANOR EQUITIES LLC 

| 

MICHIGAN TAX TRIBUNAL 

Petitioner, 

v 

MTT Docket No. 

CITY OF WARREN 

; 

Respondent. 

MULTIPLE PARCEL PETITION FORM ___ OF ___ 

1. 

The classification of the property identified herein as established by 

Respondent's Board of Review is: 

Tax Year 

Parcel Number 

Real/Personal 

Classification 

2025 

12-13-31-301-013 

R 

201Comm 

2025 

12-13-31-301-012 

R 

201Comm 

2. 

The values for the property identified herein as established by Respondent's 

Board of Review are: 

Tax Year 

| Parcel Number 

| True Cash Value 

| Assessed Value 

| Taxable Value 

2025 

12-13-31-301-013 

[13,634,480 

6,817,240 

6,817,240 

2025 

12-13-31-301-012 

[5,719,280 

2,859,640 

2,859,640

Page 6

MTT Docket No. 

Page 2 of 2 

3. 

Petitioner contends that the values for the property identified herein are: 

Tax Year | Parcel Number | True Cash Value | State Equalized Value | Taxable Value 

2025 

12-13-31-301-013 

{11,000,000 

5,500,000 

5,500,000 

2025 

12-13-31-301-012 

4,700,000 

2,350,000 

2,350,000 

4. 

The values in dispute for the property identified herein are: 

Tax Year | Parcel Number | True Cash Value | State Equalized Value | Taxable Value 

2025 

12-13-31-301-013 

|2,634,480 

1,317,240 

1,317,240 

2025 

12-13-31-301-012 

[1,019,280 

509,640 

509,640

Page 7

May 27, 2025 

RECEIVED 

: 

MAY-8 

0 2025 

[= [= 

f FAN 

MICHIGAN TAX TRIBUNAL 

EXPRESS PROPERTY TAX APPEALS LLC 

A division of Polter Law Group 

2nd

Page 8

X

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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

Warren Manor Equities LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 25-002540

City Of Warren, 

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: June 25, 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

RECEIVED 

JUN 02 2025 

MICHIGAN TAX TRIBUNAL 

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

WARREN MANOR EQUITIES LLC 

, 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

v 

MTT Docket No. 

CITY OF WARREN 

, 

Respondent(s) 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

1. 

Property Parcel No: attached 

(If more than one parcel is at issue, attach a completed Multiple Parcel Petition 

Form addressing all other parcels at issue.) 

2. 

The property identified above is 

Xx real ___ personal. 

3. 

If more than one parcel of real property is under appeal, are the properties 

contiguous? ___ Yes ___ No. 

(If no, separate Petitions are required for each non- 

contiguous parcel.) 

4. 

Are all of the parcels of personal property located on a parcel of real property 

under appeal? ___ Yes ___ No. 

(If no, separate Petitions are required for each 

parcel of personal property not located on a parcel of real property under 

appeal.) 

5. 

If parcels of personal property are under appeal, when were the personal 

property statements filed by parcel number (attach additional page if necessary): 

6. 

The property identified above is classified as 201Comm

Page 2

MTT Docket No. 

Page 2 of 4 

10. 

11. 

12. 

13. 

If a protest was required and no protest was made, list the separate and specific 

facts upon which Petitioner relies to invoke the Tribunal's authority over the 

assessment or assessments at issue (attach additional page if necessary): 

If the appeal was not submitted by the deadline for the filing of an appeal for the 

classification or classifications of the properties at issue (i.e., May 31 or July 31 

of the tax year involved), list the separate and specific facts upon which 

Petitioner relies to invoke the Tribunal’'s authority over the assessment or 

assessments at issue (attach additional page if necessary): 

The property or properties at issue are located in Macomb 

County. The 

property or properties’ address is: 

21516 Dequindre /2 £578 

Warren MI 

The assessment or assessments at issue were established by the (applicable 

local governmental unit): Warren 

Petitioner's legal residence or principal office address is: 

5308 13 Ave., Ste 270 

Bklyn, NY 11219 

This appeal involves issues relating to the (check all that are applicable): 

X 

the property or properties’ true cash and taxable values 

the property or properties’ taxable value only 

If the property or properties’ taxable value is at issue, is there a 

dispute as to the value of an addition or loss? ___ Yes ___No 

uniformity of the property or properties’ assessment

Page 3

MTT Docket No. 

Page 3 of 4 

15. 

If more than the current tax year is being appealed, list the separate and specific 

facts upon which Petitioner relies to invoke the Tribunal's authority over the prior 

tax vear or years (attach additional page if necessary): 

16. 

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 

2025 

attached 

17. 

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

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2025 

18. 

The values in dispute for the property identified above are: 

Tax Year 

True Cash Value 

State Equalized Value 

Taxable Value 

2025 

19. 

Petitioner requests the following relief (attach additional page if necessary): 

Reduction of TCV and accordingly AV/TV to more reflect these accurate figures based on comps, 

condition, income, vacancy, etc.

Page 4

MTT Docket No. 

Page 4 of 4 

Authorized Representative or, if none, Petitioner: 

Printed Name of Petitioner's Authorized Representative or, if none, Petitioner: 

Stephen Polter 

Email Address: spolter@polterlaw.com 

Mailing Address: 

2600 W Big Beaver, Ste L100, Troy, MI 48084 

Telephone Number: 248-213-6800 

Date: May 25, 2025

Page 5

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

LANSING 

MARLON I. BROWN, DPA 

DIRECTOR 

GRETCHEN WHITMER 

GOVERNOR 

WARREN MANOR EQUITIES LLC 

| 

MICHIGAN TAX TRIBUNAL 

Petitioner, 

v 

MTT Docket No. 

CITY OF WARREN 

; 

Respondent. 

MULTIPLE PARCEL PETITION FORM ___ OF ___ 

1. 

The classification of the property identified herein as established by 

Respondent's Board of Review is: 

Tax Year 

Parcel Number 

Real/Personal 

Classification 

2025 

12-13-31-301-013 

R 

201Comm 

2025 

12-13-31-301-012 

R 

201Comm 

2. 

The values for the property identified herein as established by Respondent's 

Board of Review are: 

Tax Year 

| Parcel Number 

| True Cash Value 

| Assessed Value 

| Taxable Value 

2025 

12-13-31-301-013 

[13,634,480 

6,817,240 

6,817,240 

2025 

12-13-31-301-012 

[5,719,280 

2,859,640 

2,859,640

Page 6

MTT Docket No. 

Page 2 of 2 

3. 

Petitioner contends that the values for the property identified herein are: 

Tax Year | Parcel Number | True Cash Value | State Equalized Value | Taxable Value 

2025 

12-13-31-301-013 

{11,000,000 

5,500,000 

5,500,000 

2025 

12-13-31-301-012 

4,700,000 

2,350,000 

2,350,000 

4. 

The values in dispute for the property identified herein are: 

Tax Year | Parcel Number | True Cash Value | State Equalized Value | Taxable Value 

2025 

12-13-31-301-013 

|2,634,480 

1,317,240 

1,317,240 

2025 

12-13-31-301-012 

[1,019,280 

509,640 

509,640

Page 7

May 27, 2025 

RECEIVED 

: 

MAY-8 

0 2025 

[= [= 

f FAN 

MICHIGAN TAX TRIBUNAL 

EXPRESS PROPERTY TAX APPEALS LLC 

A division of Polter Law Group 

2nd

Page 8

X

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.