Willowbrook Mf Properties, LLC Petitioner Vs. City Of Coldwater 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

NOTICE OF SEPTEMBER 1- 15, 2027 PREHEARING GENERAL CALL AND ORDER 

OF PROCEDURE

Willowbrook MF Properties, LLC,

Petitioner,

v

 

 

City Of Coldwater,

Respondent.

 MTT Docket No. 26-000969

Please be advised that 26-000969 has been placed on a two-week Prehearing General 

Call commencing September 01, 2027. Unless ordered otherwise, parties will be 

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

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

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

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

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

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

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

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

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

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

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

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

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

covered by the order will not be published.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

Protective Order will be published.

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

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

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

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

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

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

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

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

of the Tribunal’s website. 

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

website for more information.

Page 2

MTT Docket No. 26-000969

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 May 5, 2027. Valuation disclosures will not be admitted into evidence unless 

disclosed and furnished in accordance with this order (even though admissible) 

except upon a finding of good cause by the Tribunal.

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

Statements by May 5, 2027. Witnesses, with the exception of rebuttal witnesses, will 

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

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

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

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

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

May 5, 2027, which means all discovery has been requested, all Motions to Compel 

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

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

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

during “Pre-Valuation Disclosure” discovery.

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

September 1, 2027, which means all discovery has been requested, all Motions to 

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

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

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

on the opposing party’s Prehearing Statement.

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

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

certain prehearing conference at any

Page 3

MTT

Page 4

ST

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Page 1

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON 1. BROWN, DPA 

GOVERNOR 

LANSING 

DIRECTOR 

Willowbrook MF Properties, LLC 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

v 

MTT Docket No. 26-000869-TT 

City of Coldwater 

Respondent(s) 

PROOF OF SERVICE 

Samantha Albright 

states that on 8/13/2026 

he/she 

[Name of person serving/mailing petition] 

[date of service] 

served a copy of the Answer sheet 

relative to the above-captioned matter upon: 

[Provide name and address of the party/people being served] 

Michigan Tax Tribunal, PO Box 30232 Lansing, Michigan 489009 

Willowbrook MF Properties, |.L.C 2700 Clemens Rd Hatfield, PA, 12440 

aa Alsi 

[Sigitatute of person who is sening/maitig copy] 

Samantha Albright

Page 2

laa 

CITY of COLDWATER 

Hexxy L. Brown Municipal Building 

One Grand Street 

Coldwater, MI 45036 

CITY of COLDWATER 

Henry L. Brown Municipal Building 

One Grand Street 

Coldwater, MI 49036 

Michigan Tax Tribunal 

PO Box 30232 

Lansing, Mi 48909 

Willowbrook MF Properties, LLC 

2700 Clemens Rd 

Hatfield, PA 19440

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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: 26-000969

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

Party Filing Document 

Respondent

Files

Document Type: Proof of Service: Misc Documents

Attachment File Name: 26-000969-TT Proof of Service

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 TAX TRIBUNAL 

 

Willowbrook MF Properties, LLC 

, 

 

 

MTT Docket No. 26-000969-TT 

 

Petitioner, 

V 

City of Coldwater 

 

, 

 

Respondent, 

 

 

 

 

/ 

City of Coldwater 

Samantha Albright, MAAO 

Assessor 

1 Grand St 

Coldwater, MI 49036 

(517)279-6932 

salbright@coldwater.org 

 

 

 

 

/ 

ANSWER TO PETITION 

1. Admit 

2. Admit 

3. Admit 

4. Admit 

5. Admit 

6. Admit 

7. Admit 

8. The 2026 values as established by Respondent’s Board of Review are: 

Tax Year 

Parcel # 

TCV 

AV/SEV 

TV 

2026 

302-000-002-100-03 

$52,774,100 

$26,387,050 

$26,387,050

Page 2

MTT Docket No. 26-000969-TT 

2 

 

9. Respondent contends the correct values for the Property are: 

Tax Year 

Parcel # 

TCV 

AV/SEV 

TV 

2026 

302-000-002-100-03 

$52,774,100 

$26,387,050 

$26,387,050 

 

10. Admit that the Petitioner’s calculations for SEV and TV appear to be correct 

11. Neither Admit nor Deny 

12. Neither Admit nor Deny 

13. Denied for the reason that this allegation and its subparts are not true as follows: 

a. Respondent’s assessment of the property complies with statues and constitutional 

limitations on assessments; 

b. Respondent’s assessment is not more than 50% of the true cash value and 

complies the statues and constitutional limitations on assessment; 

c. Respondent’s assessment is proper based on the standard practices for 

determining assessments in Michigan; 

d. Respondent’s assessment of Petitioner’s property does not discriminate against 

Petitioner because it is not at a higher level of true cash value than the average 

level of assessment within the assessment district and the assessment was 

determined using the same standard practice for all properties in the assessment 

district. 

WHEREFORE, Respondent request that the Petition be denied, that the assessment be sustained, 

and case dismissed. 

 Respectfully submitted, 

 

 

 

 

 

 

 City of Coldwater 

Dated: August 13, 2026 

 

 

 

By:

 

 

 

 

 

 

 

 

 

 

 

 

 Samantha Albright, MAAO 

 

 

 

 

 

 

 

 City of Coldwater Assessor

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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. 26-000969

Section 1: Respondent’s Contact Information

Filer Type: 

Local Unit of Government

Local Unit of Government

City Of Coldwater (BRANCH)

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

Samantha

M.I.

Last Name

Albright

Firm Name (if any)

City of Coldwater

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

One Grand St

City or Town

Coldwater

State

 Michigan

ZIP Code

49036

Telephone Number

5172796932

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

salbright@coldwater.org

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

Respondent or Authorized Attorney/Representative’s Signature: 

Samantha Albright

/s/

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

WILLOWBROOK MF PROPERTIES, LLC, 

 

 

 

Petitioner, 

 

 

 

MTT Docket No. 26-000969 

v. 

 

 

 

 

 

 

 

 

 

CITY OF COLDWATER, 

 

 

 

Respondent. 

 

 

 

 

 

 

 

 

Adam J. Brody (P62035) 

Deborah I. Ondersma (P55907) 

VARNUM LLP 

Attorneys for Petitioner(s) 

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) Petition, (2) Notice of Docket Number MTT Docket No. 26-000969; and (3) Proof of 

Service to: 

ASSESSOR

CITY CLERK 

Samantha Albright, Assessor 

City of Coldwater 

1 Grand Street 

Coldwater, MI 49036 

Shauna Chavez, City Clerk 

City of Coldwater 

1 Grand Street 

Coldwater, MI 49036

Page 2

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

EQUALIZATION DIRECTOR 

Lyndsey Shembarger 

Equalization Department of Branch County 

31 Division St. 

Coldwater, MI 49036 

COUNTY CLERK 

Terry A. Kubasiak, County Clerk 

31 Division St. 

Coldwater, MI 49036 

 

SECRETARY OF SCHOOL BOARD 

Clair Dean, Secretary 

Coldwater Board of Education 

Coldwater Community Schools 

401 Sauk River Drive 

Coldwater, MI 49036 

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: June 24, 2026 

 

 

 

 

__/s/ Debbie Ryerson ____ 

 

 

 

 

 

 

 

 

Debbie Ryerson 

 

29321562.1

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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: 26-000969

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: 2026.06.24 PROOF re Petition and Notice of Docket Number re 

Willowbrook MF Properties

Fee Information

Filing Fee: $ 0.00

Payment Information

Payment: $ 0.00

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

WILLOWBROOK MF PROPERTIES, LLC, 

 

 

 

Petitioner, 

 

 

 

MTT Docket No. _______________ 

v. 

 

 

 

 

 

 

 

 

 

CITY OF COLDWATER, 

 

 

 

Respondent. 

 

 

 

 

 

 

 

 

Adam J. Brody (P62035) 

Deborah I. Ondersma (P55907) 

VARNUM LLP 

Attorneys for Petitioner(s) 

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, Willowbrook MF Properties, LLC, by and through its attorneys, 

VARNUM,LLP, states the following for their Petition against Respondent, City of coldwater: 

1. 

Petitioner, Willowbrook MF Properties, LLC’s, principal place of business is 2700 

Clemens Road, Hatfield, PA 19440. 

2. 

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

property (the "Property") which is located in City of Coldwater, Branch County, Michigan, and is 

more particularly described as: 

Parcel No. 

 

 

 

 Property Address 

12-302-000-002-100-03 

 

421 N. Willowbrook Rd., Coldwater, MI 49036

Page 2

2 

 

3. 

Respondent, the City of Coldwater ("Respondent"), assesses, levies and collects the 

property taxes on the Property. 

4. 

The Property is located in Branch County and is located with the Coldwater 

Community Schools District. 

5. 

The Property is classified as Commercial-Improved real property. 

6. 

Because the Property is classified as commercial real property, no appeal to 

Respondent's Board of Review was required. 

7. 

The tax year(s) at issue are: 2026 

 

8. 

The Tax Year 2026 values for the Property as established by Respondent’s Board 

of Review are: 

Tax 

year

Permanent Parcel Number 

True Cash Value 

Assessed/State 

Equalized Value

Taxable 

Value

2026

12-302-000-002-100-03

$52,774,100

$26,387,050

$26,387,050

 

9. 

Petitioner contends the correct values for the Property are: 

Tax 

year

Permanent Parcel Number 

True Cash Value 

Assessed/State 

Equalized Value

Taxable 

Value

2026

12-302-000-002-100-03

$40,000,000

$20,000,000

$20,000,000

 

10. 

The values in dispute for the Property are: 

Tax 

year

Permanent Parcel Number 

True Cash Value 

Assessed/State 

Equalized Value

Taxable 

Value

2026

12-302-000-002-100-03

$12,774,100

$6,387,050

$6,387,050

 

11. 

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

equalized and taxable value as outlined above in paragraph 9. Petitioner further requests a refund 

with interest of taxes paid due to the original, incorrect assessment and any other relief this 

Tribunal deems appropriate.

Page 3

3 

 

12. 

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

value, (d) equal protection, and (e) uniformity. Petitioner is not aware of a dispute as to the value 

of an addition to the taxable value. 

13. 

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 because: 

(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 or the income potential of the Property 

or 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. 

 

 

WHEREFORE, Petitioner requests that the Tribunal grant the following relief: 

 

A. 

Reduce the assessed, state equalized and taxable values of the Property to 

$20,000,000 and order a refund with interest; and 

 

B. 

Provide such additional relief to Petitioner as this Tribunal deems appropriate. 

 

 

 

 

 

 

 

VARNUM, LLP 

 

 

 

 

 

 

Attorneys for Petitioner 

 

Dated: May 12, 2026 

 

 

By:__/s/ Deborah I. Ondersma 

Deborah I. Ondersma (P55907) 

 

 

 

 

 

 

Business Address/Telephone: 

 

 

 

 

 

 

 

333 Bridge Street, N.W. 

 

 

 

 

 

 

 

P.O. Box 352 

 

 

 

 

 

 

 

Grand Rapids, MI 49501-0352 

 

 

 

 

 

 

 

(616) 336-6000 

 

 

 

 

 

 

 

diondersma@varnumlaw.com 

 

28803073.1

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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 - 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

Willowbrook MF Properties, LLC

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

2700 Clemens Road

City or Town

Hatfield

State

Pennsylvania

ZIP Code

19440

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]

421 N. Willowbrook Rd.

Coldwater

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

49036

Taxing Authority (City or Township)

City Of Coldwater (BRANCH) 

County

Branch

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.)

No

 

 

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

True Cash and Taxable Values

If “Other”, please explain:

 

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

12-302-000-002-100-03

Classification of Property: Real (check one)

Commercial (check one)

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

26387050

Current Taxable Value as established by the Board of Review:

26387050

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

40000000

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

20000000

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

20000000

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: 26051285017457

Supporting Waiver Documents:

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Page 1

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA

DIRECTOR

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

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

Willowbrook MF Properties, LLC, 

Petitioner,

 MICHIGAN TAX TRIBUNAL

v

MTT Docket No.: 26-000969

City Of Coldwater, 

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 24, 2026

PROOF OF SERVICE

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

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

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

representatives.

By: Tribunal Clerk

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

 

WILLOWBROOK MF PROPERTIES, LLC, 

 

 

 

Petitioner, 

 

 

 

MTT Docket No. _______________ 

v. 

 

 

 

 

 

 

 

 

 

CITY OF COLDWATER, 

 

 

 

Respondent. 

 

 

 

 

 

 

 

 

Adam J. Brody (P62035) 

Deborah I. Ondersma (P55907) 

VARNUM LLP 

Attorneys for Petitioner(s) 

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, Willowbrook MF Properties, LLC, by and through its attorneys, 

VARNUM,LLP, states the following for their Petition against Respondent, City of coldwater: 

1. 

Petitioner, Willowbrook MF Properties, LLC’s, principal place of business is 2700 

Clemens Road, Hatfield, PA 19440. 

2. 

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

property (the "Property") which is located in City of Coldwater, Branch County, Michigan, and is 

more particularly described as: 

Parcel No. 

 

 

 

 Property Address 

12-302-000-002-100-03 

 

421 N. Willowbrook Rd., Coldwater, MI 49036

Page 2

2 

 

3. 

Respondent, the City of Coldwater ("Respondent"), assesses, levies and collects the 

property taxes on the Property. 

4. 

The Property is located in Branch County and is located with the Coldwater 

Community Schools District. 

5. 

The Property is classified as Commercial-Improved real property. 

6. 

Because the Property is classified as commercial real property, no appeal to 

Respondent's Board of Review was required. 

7. 

The tax year(s) at issue are: 2026 

 

8. 

The Tax Year 2026 values for the Property as established by Respondent’s Board 

of Review are: 

Tax 

year

Permanent Parcel Number 

True Cash Value 

Assessed/State 

Equalized Value

Taxable 

Value

2026

12-302-000-002-100-03

$52,774,100

$26,387,050

$26,387,050

 

9. 

Petitioner contends the correct values for the Property are: 

Tax 

year

Permanent Parcel Number 

True Cash Value 

Assessed/State 

Equalized Value

Taxable 

Value

2026

12-302-000-002-100-03

$40,000,000

$20,000,000

$20,000,000

 

10. 

The values in dispute for the Property are: 

Tax 

year

Permanent Parcel Number 

True Cash Value 

Assessed/State 

Equalized Value

Taxable 

Value

2026

12-302-000-002-100-03

$12,774,100

$6,387,050

$6,387,050

 

11. 

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

equalized and taxable value as outlined above in paragraph 9. Petitioner further requests a refund 

with interest of taxes paid due to the original, incorrect assessment and any other relief this 

Tribunal deems appropriate.

Page 3

3 

 

12. 

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

value, (d) equal protection, and (e) uniformity. Petitioner is not aware of a dispute as to the value 

of an addition to the taxable value. 

13. 

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 because: 

(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 or the income potential of the Property 

or 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. 

 

 

WHEREFORE, Petitioner requests that the Tribunal grant the following relief: 

 

A. 

Reduce the assessed, state equalized and taxable values of the Property to 

$20,000,000 and order a refund with interest; and 

 

B. 

Provide such additional relief to Petitioner as this Tribunal deems appropriate. 

 

 

 

 

 

 

 

VARNUM, LLP 

 

 

 

 

 

 

Attorneys for Petitioner 

 

Dated: May 12, 2026 

 

 

By:__/s/ Deborah I. Ondersma 

Deborah I. Ondersma (P55907) 

 

 

 

 

 

 

Business Address/Telephone: 

 

 

 

 

 

 

 

333 Bridge Street, N.W. 

 

 

 

 

 

 

 

P.O. Box 352 

 

 

 

 

 

 

 

Grand Rapids, MI 49501-0352 

 

 

 

 

 

 

 

(616) 336-6000 

 

 

 

 

 

 

 

diondersma@varnumlaw.com 

 

28803073.1

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

Willowbrook MF Properties, LLC

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

2700 Clemens Road

City or Town

Hatfield

State

Pennsylvania

ZIP Code

19440

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]

421 N. Willowbrook Rd.

Coldwater

Page 2

STATE OF MICHIGAN

GRETCHEN WHITMER

GOVERNOR

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS

LANSING

MARLON I. BROWN, DPA 

DIRECTOR

Michigan

49036

Taxing Authority (City or Township)

City Of Coldwater (BRANCH) 

County

Branch

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.)

No

 

 

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

True Cash and Taxable Values

If “Other”, please explain:

 

 

Section 6: Valuation Information for Each Parcel under Appeal

Parcel Number:

12-302-000-002-100-03

Classification of Property: Real (check one)

Commercial (check one)

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

26387050

Current Taxable Value as established by the Board of Review:

26387050

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

40000000

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

20000000

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

20000000

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: 26051285017457

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.