City's Response to Petition - FHVM Green Road LLC - 26-001000.pdf
Fhvm Green Road, LLC Petitioner Vs. City Of Ann Arbor Respondent · 26-001000-TT
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STATE OF MCHIGAN MICHIGAN TAX TRIBUNAL FHVM Green Road LLC, Petitioner, V City of Ann Arbor, Respondent. MTT Docket No. 26-001000 Jerome P. Pesick (P29039) Jason C. Long (P59244) WILLIAMS, WILLIAMS, RATTNER & PLUNKETT, PC Attorneys for Petitioner 380 N. Old Woodward Avenue, Suite 300 Birmingham, Michigan 48009 (248) 642-0333 jpesick@wwrplaw.com jlong@wwrplaw.com John W. Reiser (P45050) OFFICE OF THE CITY ATTORNEY Attorney for Respondent 301 E. Huron Street, 3rd Floor Ann Arbor, Michigan 48104-1908 (734) 794-6170 jreiser@a2gov.org RESPONDENT CITY OF ANN ARBOR’S RESPONSE TO PETITION Respondent City of Ann Arbor (“Respondent”), through the Ann Arbor City Attorney’s Office, responds in opposition to the Petition of FHVM Green Road LLC (“Petitioner”) as follows: 1. Respondent leaves Petitioner to its proofs. 2. Admit. 3. Respondent leaves Petitioner to its proofs. 4. Admit. 5. Admit. 6. Admit.
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2 7. Admit. 8. Respondent leaves Petitioner to its proofs. 9. Respondent leaves Petitioner to its proofs. 10. Respondent leaves Petitioner to its proofs. 11. Respondent leaves Petitioner to its proofs as to (a) through (d). 12. Respondent leaves Petitioner to its proofs. For the reasons stated above, Respondent requests that the Tribunal deny Petitioner’s request and affirm its 2026 assessed and taxable values. Dated: August 21, 2026 Respectfully submitted, OFFICE OF THE CITY ATTORNEY By: /s/ John W. Reiser John W. Reiser (P45050) Attorney for Respondent 301 E. Huron Street, 3rd Floor Ann Arbor, Michigan 48104-1908 (734) 794-6170 jreiser@a2gov.org
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3 AFFIRMATIVE DEFENSES Respondent City of Ann Arbor (“Respondent”), through the Ann Arbor City Attorney’s Office, and for its Affirmative Defenses to the Petition of FHVM Green Road LLC (“Petitioner”), states the following: 1. Respondent reserves the right to raise affirmative defenses as the same become apparent in the court of this litigation. Dated: August 21, 2026 Respectfully submitted, OFFICE OF THE CITY ATTORNEY By: /s/ John W. Reiser John W. Reiser (P45050) Attorney for Respondent 301 E. Huron Street, 3rd Floor Ann Arbor, Michigan 48104-1908 (734) 794-6170 jreiser@a2gov.org PROOF OF SERVICE I hereby certify that on August 21, 2026, I emailed a true and correct copy of the foregoing Response to Petition and Affirmative Defenses to the above-named attorneys for petitioner at the address listed above. /s/ Dawn M. Bagozzi Legal Assistant