EIG14T PRI v Georgetown - Answer and Affirmative Defenses with Certificate of Service -- 26-949-TT.pdf
Eig14T Pri Mi Jenison Baldwin LLC Petitioner Vs. Township Of Georgetown Respondent · 26-000949-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL EIG14T PRI MI Jenison Baldwin LLC, Petitioner, v. Georgetown Charter Township, Respondent. ___________________________________/ MTT Docket No. 26-000949-TT Steve Johnson Michigan Tax Appeal Services Representative for Petitioner 436 N. Center St. Northville, MI 48167 (248) 392-4342 info@mitaxappeal.com __________________________________/ Ryan M. Shannon (P74535) Dickinson Wright PLLC Counsel for Respondent 123 W. Allegan St., Suite 900 Lansing, MI 48933 (517) 410-5443 rshannon@dickinsonwright.com ANSWER AND AFFIRMATIVE DEFENSES Respondent, through undersigned counsel, responds to the Petition filed in the above-captioned matter by like-numbered paragraphs as follows, and states thereafter its Affirmative Defenses: 1. Respondent’s records do not reflect the existence of a parcel with ID number 70-14-15-290-046. Petitioner appears to have pleaded in error and to have mis-identified the property. The tax rolls reflect that Petitioner owns a parcel designated 70-14-15-279-046 at the same address listed in the Petition. Without waiving any arguments concerning jurisdiction, Respondent refers to this latter parcel as the “Subject Property” and interposes the following answers with respect to the Subject Property.
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MTT Docket No. 26-000949 Page 2 Respondent otherwise denies as untrue all allegations with respect to Parcel 70-14-15-290-046. 2. Admitted. 3. No allegation of fact or law has been made to which a response is required. 4. No allegation of fact or law has been made to which a response is required. 5. No allegation of fact or law has been made to which a response is required. 6. Admitted. 7. No allegation of fact or law has been made to which a response is required. 8. No allegation of fact or law has been made to which a response is required. 9. No allegation of fact or law has been made to which a response is required. 10. Admitted. 11. Admitted. 12. Respondent neither admits nor denies as it is without sufficient information, and leaves Petitioner to its proofs. 13. Respondent neither admits nor denies as it is without sufficient information, and leaves Petitioner to its proofs. 14. Admitted. 15. No allegation of fact or law has been made to which a response is required. 16. Admitted. 17. Respondent denies as untrue that the values for the Subject Property are or should be as set forth in this paragraph.
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MTT Docket No. 26-000949 Page 3 18. Respondent admits, based on Petitioner’s contentions, that the values in dispute are as set forth in this paragraph. 19. Respondent denies as untrue that Petitioner is entitled to the requested relief. 20. Denied as untrue AFFIRMATIVE DEFENSES For its Affirmative Defenses, Respondent states further as follows: 1. Petitioner has failed to state a claim upon which relief may be granted. 2. Petitioner has failed to invoke the Tribunal’s jurisdiction because it did not timely file a petition with respect to property in which it has an interest. 3. Petitioner has failed to state a claim because it has not complied with the Tribunal’s rules governing pleading. 4. Petitioner has failed to support the existence of a property interest supporting standing to bring an appeal of the property taxes. 5. Any reduction in value compared to the assessed value is the result of Petitioner’s own conduct or action such that it would be inequitable or improper to reduce its tax liability. 6. Granting the relief sought would result in dis-uniform assessment in violation of the Michigan Constitution. 7. Respondent reserves the right to add or identify further affirmative defenses as they become known through the course of this litigation.
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MTT Docket No. 26-000949 Page 4 WHEREFORE, Respondent respectfully requests that the Tribunal enter an order dismissing the appeal or in the alternative affirming the values on the rolls, and granting such other and further relief as are in its power to give. Submitted Respectfully, DICKINSON WRIGHT PLLC /s/ Ryan M. Shannon Ryan M. Shannon (P74535) Counsel for Respondent 123 W. Allegan St., Suite 900 Lansing, MI 48933 (517) 371-1730 rshannon@dickinsonwright.com Dated: September 4, 2026 CERTIFICATE OF SERVICE The undersigned hereby certifies that on September 4, 2026 he caused the foregoing Answer and Affirmative defenses to be served on representative for the Petitioners at the following address by first class mail, postage prepaid: Steve Johnson Michigan Tax Appeal Services 436 N. Center St. Northville, MI 48167 /s/ Ryan M. Shannon Ryan M. Shannon September 4, 2026