Full record / Answer Freidman Management v City of Wyoming MTT 25-001698.pdf

Answer Freidman Management v City of Wyoming MTT 25-001698.pdf

Friedman Real Estate Management, Petitioner Vs. City Of Wyoming, Respondent · 25-001698-TT

← View full record

Text extracted from the reviewed PDF, organized by page. OCR and reading order may contain errors; confirm details in the PDF below.

Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

Friedman Real Estate Management, 

 Petitioner, 

 

v. 

 

City of Wyoming, 

 Respondent. 

_____________________________________/ 

 

 

MTT Docket No. 25-001698 

 

 

John-Paul Wolfe 

Friedman Real Estate 

Petitioner’s Representative 

34975 W. Twelve Mile Rd. 

Farmington Hills, MI 48331 

(248) 848-4154 

Jp.wolfe@freg.com 

____________________________________/ 

Ryan M. Shannon (P74535) 

Dickinson Wright PLLC 

Counsel for Respondent 

123 W. Allegan St., Suite 900 

Lansing, MI 48933 

(517) 371-1730 

rshannon@dickinsonwright.com 

 

ANSWER AND AFFIRMATIVE DEFENSES 

 

Respondent, the City of Wyoming, by and through its counsel, Dickinson 

Wright PLLC, hereby states by like-numbered paragraph its Answer to the Petition 

in the above-captioned matter, and states thereafter separately its Affirmative 

Defenses: 

1. 

No allegation of fact or law has been made to which a response is 

required. Parcel 41-18-19-426-011 will hereafter be referred to as the “Subject 

Property.” 

2. 

Admitted. 

3. 

No allegation of fact or law has been made to which a response is 

required.

Page 2

MTT Docket No. 25-001698 

Page 2 

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 to form a belief, and leaves Petitioner to its proofs. 

13. 

Respondent neither admits nor denies as it is without sufficient 

information to form a belief, 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.

Page 3

MTT Docket No. 25-001698 

Page 3 

17. 

Denied as untrue the allegation that the values for the Subject Property 

are or should be as set forth in this paragraph of the Petition. 

18. 

Admitted, based on Petitioner’s contention of value. 

19. 

Denied as untrue that the Petitioner is entitled to the requested relief. 

20. 

Denied as untrue. 

AFFIRMATIVE DEFENSES 

Respondent states as follows for its Affirmative Defenses: 

1. 

Petitioner has failed to state a claim upon which relief may be granted. 

2. 

Petitioner has failed to plead in conformity with the Tax Tribunal Rules. 

3. 

Petitioner has failed to plead the existence of facts to support standing to 

initiate this appeal. 

4. 

Petitioner lacks sufficient interests in the Subject Property to maintain 

standing. 

5. 

Any diminution in value is the result of Petitioner’s own actions or inactions 

and should not be the basis of an unequal tax burden for Petitioner’s neighbors. 

6. 

Respondent reserves the right to identify other and further affirmative 

defenses when and if they should become apparent during the course of this litigation. 

WHEREFORE, Respondent respectfully requests that the Tribunal deny 

Petitioner’s requested relief, dismiss the Petition, affirm the tax rolls, and grant to 

Respondent such other and further relief as the Tribunal deems to be within its 

powers to give.

Page 4

MTT Docket No. 25-001698 

Page 4 

 

Submitted Respectfully, 

Dickinson Wright PLLC 

/s/ Ryan M. Shannon 

Ryan M. Shannon (P74535) 

Counsel for Respondent 

 

Dated: 8/7/2025 

 

CERTIFICATE OF SERVICE 

The undersigned hereby certifies that on August 8, 2025, he caused the foregoing 

Answer and Affirmative Defenses to be served on representative for Petitioner at the 

following address by first class mail, postage prepaid: 

 

John-Paul Wolfe 

Friedman Real Estate 

34975 W. Twelve Mile Road 

Farmington Hills, MI 48331 

 

 

/s/ Ryan M. Shannon 

Ryan M. Shannon

PDF reading copy

← View full record