Canyon Venture III LLC v Township of Saginaw (26-001448) Respondent's Answer to Amended Petition.pdf

Canyon Venture III LLC Petitioner Vs. Township Of Saginaw Respondent · 26-001448-TT

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

CANYON VENTURE III LLC, 

Petitioner, 

MTT Docket No.: 26-001448 

v 

TOWNSHIP OF SAGINAW, 

Respondent. 

LAW OFFICES OF AARON M. FALES, P.C. 

BRAUN KENDRICK FINKBEINER P.L.C. 

By: 

Aaron M. Fales (P72864) 

By: 

Francis J. Keating (P39223) 

Attorney Petitioner 

Attorneys for Respondent 

330 Hamilton Row, Suite 350 

4301 Fashion Square Blvd. 

Birmingham, MI 48009 

Saginaw, MI 48603 

(248) 767-9840 

(989) 498-2100 

afaleslaw(@gmail.com 

frakea@braunkendrick.com 

RESPONDENT’S ANSWER TO AMENDED PETITION 

NOW COMES Respondent, Township of Saginaw, by and through its attorneys, Braun 

Kendrick Finkbeiner P.L.C., and for its Answer to Amended Petition, states as follows: 

1. 

Respondent admits that real property tax parcel no. 23-12-4-16-3008-006 is also 

known 

as 4598 

State 

Street, Saginaw, Michigan 48603. 

Respondent lacks knowledge 

or 

information sufficient to form a belief as to the truth of the remaining allegations in paragraph 1. 

2. 

Admitted. 

3. 

Admitted. 

4. 

Respondent admits that the subject property is classified Commercial Improved. 

Respondent lacks knowledge or information sufficient to form a belief as to the truth of the 

remaining allegations in paragraph 4. 

4896-9211-3879, v. 1

5. 

Respondent lacks knowledge or information sufficient to form a belief as to the 

truth of the allegations in paragraph 5. 

6. 

Respondent lacks knowledge or information sufficient to form a belief as to the 

truth of the allegations in paragraph 6. 

7. 

Respondent denies as untrue the allegations in paragraph 7. 

7a. 

Respondent denies as untrue the allegations in paragraph 7a. 

7b. 

Respondent denies as untrue the allegations in paragraph 7b. 

Tc. 

Respondent denies as untrue the allegations in paragraph 7c. 

7d. 

Respondent denies as untrue the allegations in paragraph 7d. 

NEW MATTERS AND AFFIRMATIVE DEFENSES 

1. 

Petitioner has failed to allege specific and sufficient facts to set forth a cause of 

action against Respondent. 

2. 

Petitioner has failed 

to allege specific and sufficient facts 

to establish fraud, 

discrimination, or illegality on the part of the Respondent. 

3. 

Petitioner may not be the real party in interest to bring this tax appeal. 

4. 

Petitioner may not have standing to bring this tax appeal. 

S. 

Petitioner has failed to show that any factor other than fifty percent (50%) was 

applied to the true cash value of Petitioner’s property, as well as all others, to arrive 

at the 

respective assessments appearing on the roll, and also fails to allege specific and sufficient facts 

to support its allegations that the property’s taxable value is improper. 

6. 

Respondent 

has 

properly 

and 

lawfully 

assessed 

Petitioner's 

property 

and 

established its taxable value in accordance with statutory and constitutional requirements. 

4896-9211-3879, v. 1

7: 

Respondent reserves the right to assert additional affirmative defenses during the 

pendency of this action. 

WHEREFORE, 

Respondent, 

Township 

of Saginaw, 

respectfully 

requests 

that 

this 

Honorable Tribunal provide it with the following relief: 

A. 

Dismiss the Petition with prejudice, and award Respondent its costs and attorney 

fees wrongfully incurred in the defense of this action; and 

B. 

Provide Respondent with such other relief as the Tribunal deems appropriate. 

BRAUN KENDRICK FINKBEINER P.L.C. 

Dated: October /Z 

,2026 

BY: Ta KEATING (P39223) 

Attorney 

for Respondent 

4896-9211-3879, v. 1

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