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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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Page 1

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.

Page 2

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

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