03. City's Response to Petition - Briarwood Hospitality LLC - 26-000669.pdf
Briarwood Hospitality, LLC Petitioner Vs. City Of Ann Arbor Respondent · 26-000669-TT
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STATE OF MICHIGAN MICHIGAN TAX TRIBUNAL Briarwood Hospitality, LLC, Petitioner, v` City of Ann Arbor, Respondent. MTT Docket No. 26-000669 Laura M. Hallahan (P42101) HALLAHAN & ASSOCIATES, P.C. Attorney for Petitioner 1750 S. Telegraph Road, Suite 202 Bloomfield, Michigan 48302-0179 (248) 731-3089 lhallahan@hallahanlaw.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 Briarwood Hospitality, LLC (“Petitioner”) as follows: 1. Admit. 2. Admit. 3. Admit. 4. Respondent leaves Petitioner to its proofs. 5. Respondent leaves Petitioner to its proofs. 6. Respondent leaves Petitioner to its proofs. 7. Admit. 8. Admit.
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2 9. Respondent leaves Petitioner to its proofs. 10. Respondent leaves Petitioner to its proofs. 11. 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: July 29, 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 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 Briarwood Hospitality, 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: July 29, 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 PROOF OF SERVICE I hereby certify that on July 29, 2026, I emailed a true and correct copy of the foregoing Response to Petition and Affirmative Defenses to the above-named petitioner’s attorney at the address listed above. /s/ Dawn M. Bagozzi Legal Assistant