MTT 26-000752 ET Response w-Proof of Service.Paula.Amended.pdf
Trinity Place Investments LLC Petitioner Vs. Township Of Flint Respondent · 26-000752-TT
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August 24, 2026 Office of the Chief Clerk Michigan Tax Tribunal P.O. Box 30232 Lansing, MI 48909 RE: MTT Docket No.: 26-000752 Trinity Place Investments LLC v Township of Flint Parcels: 07-25-300-054, 07-25-553-001, 07-25-553-002, 07-25-553-003, 07-25- 553-004, and 07-25-553-005 Dear Honorable Michigan Tax Tribunal: Enclosed for filing, please find Respondent’s Amended Reply to Petitioner’s Petition (in the Entire Tribunal) and Respondent’s Proof of Service. Respectfully submitted, Paula Dotson Deputy Assessor Charter Township of Flint
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Trinity Place Investments LLC Petitioner v Flint Township, Genesee County Respondent MTT DOCKET NO.: 26-000752 PROOF OF SERVICE STATE OF MICHIGAN ) GENESEE COUNTY ) THE UNDERSIGNED, Paula Dotson, being first duly sworn, deposes and says that on August 24, 2026, she caused to be served upon: Brian Etzel Williams, Williams, Rattner & Plunkett 380 N. Old Woodward Ave., Ste. 300 Birmingham, MI 48009 Michigan Tax Tribunal PO Box 30232 Lansing, Michigan 48909 by enclosing the same in an envelope, plainly addressed to said party at the above address, with lawful United States first class postage affixed thereon and by placing same in the United States mail. August 24, 2026 /s/ Paula Dotson Date Paula Dotson Deputy Assessor Flint Township
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Trinity Place Investments LLC MTT Docket No.: 26-000752 Petitioner Parcels: 07-25-300-054 07-25-553-001 07-25-553-002 07-25-553-003 07-25-553-004 07-25-553-005 v Flint Township, Genesee County Respondent Brian Etzel Williams, Williams, Rattner & Plunkett 380 N. Old Woodward Ave., Ste. 300 Birmingham, MI 48009 248.642.0333 Paula Dotson Deputy Assessor, Charter Township of Flint 1490 S. Dye Road Flint, MI 48532 810.600.3227 RESPONDENT’S REPLY TO PETITIONER’S APPEAL TO CONTEST THE 2026 ASSESSED AND TAXBLE VALUATION (IN ENTIRE TRIBUNAL) Respondent, the Charter Township of Flint, through its Assessor, William Fowler, and its Deputy Assessor, Paula Dotson, hereby submits its response to Petitioner’s Petition as follows: 1. Respondent neither admits nor denies the statements and or allegations set forth in paragraph 1 of Petitioner’s Petition as it does not have sufficient information to form a belief as to the truth of the allegations. 2. Respondent admits the statements and or allegations set forth in paragraph 2 of Petitioner’s Petition. 3. Respondent admits the statements and or allegations set forth in paragraph 3 of Petitioner’s Petition. 4. Respondent denies the statements and or allegations set forth in paragraph 4 of Petitioner’s Petition because they are untrue. The subject properties are in Carman-Ainsworth School District. 5. Respondent admits the statements and or allegations set forth in paragraph 5 of Petitioner’s Petition.
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MTT Docket No. 26-000752 6. Respondent admits the statements and or allegations set forth in paragraph 6 of Petitioner’s Petition. 7. Respondent admits the statements and or allegations set forth in paragraph 7 of Petitioner’s Petition. 8. Respondent neither admits nor denies the statements and or allegations set forth in paragraph 8 of Petitioner’s Petition as said paragraph is merely the opportunity for Petitioner to set forth its opinion of value. 9. Respondent neither admits nor denies the statements and or allegations set forth in paragraph 9 of Petitioner’s Petition said paragraph is merely the mathematical calculation of the difference between Respondent’s valuations and Petitioner’s contention of value. 10. Respondent neither admits nor denies the statements and or allegations set forth in paragraph 10 of Petitioner’s as said paragraph does not have sufficient information to form a belief as to the truth of the allegations. 11. Respondent denies the statements or allegations set forth in paragraph 11 of Petitioner’s Petition for the reason they are not true. 12. Respondent acknowledges the statements or allegations set forth in paragraph 12 of Petitioner’s Petition. Wherefore Respondent requests the relief and actions requested by Petitioner be denied. Respondent leaves Petitioner to meeting its required burden of proof. Respondent’s Response submitted on this date, August 24, 2026, by: /s/ Paula Dotson Paula Dotson Deputy Assessor Charter Township of Flint