Response Division Storage Signed. 8.20.26.pdf
Division Ave Self Storage LLC Petitioner Vs. City Of Wyoming Respondent · 26-001141-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN ADMINISTRATIVE HEARING SYSTEM MICHIGAN TAX TRIBUNAL Division Ave Self Storage, LLG, Petitioner, MTT Docket No. 26-001141 v Parcel No. 41-17-36-476-031 41-17-36-476-043 City of Wyoming, 41-17-36-476-007 Respondent. Brian E. Etzel (P54805) Gregory T. Stremers (P45006) Williams, Williams, Rattner Wyoming City Attorney & Plunkett, PC Respondent's Representative Attorneys for Petitioner 2650 DeHoop Ave SW 380 N. Old Woodward Ave, Ste 300 Wyoming, MI 49509-0805 Birmingham, M! 48009 (616) 530-3194 (248) 642-0333 Greg. Stremers@wyomingmi.gov bee@wwrplaw.com RESPONDENT'S RESPONSE TO PETITION Respondent, the City of Wyoming, states its Response to the Petition and is affirmative defenses: 1. ® No or oR WN Admitted. Admitted. Admitted. Admitted. Admitted. Admitted. Admitted. Denied as untrue, the values for the Subject Properties are as assessed and leaves Petitioner to its proofs.
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9. Admitted. 10. Respondent neither admits nor denies as it is without sufficient information, and leaves Petitioner to its proofs. 11. Denied as untrue, as the values for the Subject Properties are as stated and leaves Petitioner to its proofs. 12. Denied as untrue as to uniformity, and in any event, the values for the Subject Properties are as assessed and leaves Petitioner to its proofs. AFFIRMATIVE DEFENSES Pending discovery and presentment of valuation by Petitioner, the City of Wyoming preliminary affirmative defense states: 1. Petitioner has failed to state a claim upon which relief may be granted. 2. 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 Petitioner's tax liability. 3. Granting the relief sought would result in dis-uniform assessment in violation of the Michigan Constitution. 4. Respondent reserves the right to add or identify further affirmative defenses as they become known through the course of this litigation. WHEREFORE, Respondent respectfully requests that the tribunal issue an order denying Petitioner's request for Relief, affirming the tax rolls as they currently exist, and granting the Respondent such other and further relief as the Tribunal deems to be appropriate. Date: August 11, 2026 Co ~ GreoonT Stremers (P45008) ming City Nomar Respondent's Representative 2650 DeHoop Ave SW Wyoming, MI 49509-0905 (616) 530-3194 Greg. Stremers@wyomingmi.gov