Response to Petition, Affirmative Defenses and POS â RAC Ryan (ID 113753).pdf
Rac Ryan LLC, Petitioner Vs. City Of Warren, Respondent · 25-002385-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL RAC RYAN LLC MTT Docket No. 25-002385 Petitioner, Parcel ID No. 12-13-06-228-026 V. CITY OF WARREN, Respondent. JORDAN JONNA AF JONNA DEVELOPMENT Representative for Petitioner 4036 Telegraph Road, Suite 201 Bloomfield Hills, Michigan 48302 (248) 593-6200 MARY MICHAELS (P44601) LAURA SULLIVAN (P42021) CITY OF WARREN Attorneys for Respondent One City Square, Ste. 400 Warren, MI 48093 (586) 574-4671 / RESPONSE TO PETITION Respondent, City of Warren, by and through its attorneys, MARY MICHAELS, Acting City Attorney and LAURA SULLIVAN, Assistant City Attorney, in response to the Petition states as follows: 1. Paragraph 1 is not contested. 2. Paragraph 2 is not contested. 3. Paragraph 3 is not contested. 4, Paragraph 4 is not contested.
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7. Paragraph 7 is not contested. 8. Paragraph 8 is not contested except that the True Cash Value on the Subject Property Tax Record is $1,610,986.00. 9. In response to Paragraph 9, Respondent lacks sufficient knowledge or information to form a belief as to the truth of the allegations and therefore leaves Petitioner to its proofs. 10. In response to Paragraph 10, Respondent lacks sufficient knowledge or information to form a belief as to the truth of the allegations and therefore leaves Petitioner to its proofs. 11. In response to Paragraph 11, (a)-(d) is denied. THEREFORE, Respondent City of Warren requests this Tribunal deny the requested relief, dismiss the Petition with prejudice, and award Respondent costs it incurred in the defense of this appeal. Respectfully submitted, By: [s/Laura Sullivan LAURA SULLIVAN (P42021) Assistant City Attorney Attorneys for Respondent Dated: July 14, 2025 LS/vIt Response to Petition, Affirmative Defenses and POS — RAC Ryan LLC ID 113654
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL RAC RYAN LLC MTT Docket No. 25-002385 Petitioner, Parcel ID No. 12-13-06-228-026 V. CITY OF WARREN, Respondent. JORDAN JONNA AF JONNA DEVELOPMENT Representative for Petitioner 4036 Telegraph Road, Suite 201 Bloomfield Hills, Michigan 48302 (248) 593-6200 MARY MICHAELS (P44601) LAURA SULLIVAN (P42021) CITY OF WARREN Attorneys for Respondent One City Square, Ste. 400 Warren, MI 48093 (586) 574-4671 / AFFIRMATIVE DEFENSES Respondent, City of Warren, by and through its attorneys, MARY MICHAELS, Acting City Attorney and LAURA SULLIVAN, Assistant City Attorney, in response to the Petition, submit the following Affirmative Defenses: 1. Petitioner failed to allege specific and sufficient facts to set forth a cause of action. 2. Petitioner failed to allege specific and sufficient facts to establish illegality on part of Respondent, or its agent.
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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 failed to allege specific and sufficient facts to support its allegations that the property’s taxable value is improper. 7. Petitioner failed to submit any evidence warranting relief from the assessments to the Board of Review. 8. Petitioner, in essence, seeks by petition to challenge the process of county and state equalization as to which it has no legal standing and cannot maintain a cause of action. 9. Respondent reserves the right to raise additional defenses as may become known to it during the course of these proceedings. Respectfully submitted, By: /s/Laura Sullivan LAURA SULLIVAN (P42021) Assistant City Attorney Attorneys for Respondent Dated: July 14, 2025 LS/vIt Response to Petition, Affirmative Defenses and POS — RAC Ryan ID 113654
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL RAC RYAN LLC MTT Docket No. 25-002385 Petitioner, Parcel ID No. 12-13-06-228-026 V. CITY OF WARREN, Respondent. JORDAN JONNA AF JONNA DEVELOPMENT Representative for Petitioner 4036 Telegraph Road, Suite 201 Bloomfield Hills, Michigan 48302 (248) 593-6200 MARY MICHAELS (P44601) LAURA SULLIVAN (P42021) CITY OF WARREN Attorneys for Respondent One City Square, Ste. 400 Warren, MI 48093 (586) 574-4671 / PROOF OF SERVICE STATE OF MICHIGAN ) ) SS. COUNTY OF MACOMB ) On the date below, | sent via email to fkuza@afjonna.com a copy of Respondent City of Warren's Response to Petition, Affirmative Defenses and Proof of Service. | declare that the statements above are true to the best of my information, knowledge, and belief. [s/Valerie Tack Valerie Tack Dated: July 14, 2025