Answer Freidman Management v City of Wyoming MTT 25-001698.pdf
Friedman Real Estate Management, Petitioner Vs. City Of Wyoming, Respondent · 25-001698-TT
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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.
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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.
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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.
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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