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Answer to Petition.pdf

Romeo Acquisition LLC Petitioner Vs. Township Of Washington Respondent · 26-001042-TT

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

ROMEO ACQUISITION, LLC 

Petitioner, 

-VS- 

MTT Docket No. 26-001042 

CHARTER TOWNSHIP OF WASHINGTON, 

Respondent. 

MICHELLE (MIKKI) M. SILVEY (P69494) 

CHRISTINE D. ANDERSON (P45141) 

ALEX MORSE 

SEIBERT AND DLOSKI, PLLC 

CAMERON BEKCNER 

Attorney for Respondent 

Ducharme, McMillen & Associates, Inc. 

19500 Hall Road, Suite 101 

Representatives for Petitioner 

Clinton Township, MI 48038 

9229 Delegates Row, Suite 375 

(586) 469-3800 

Indianapolis, IN 

46240 

canderson@seibertanddloski.com 

(317)596-3260 

msilvev@dmainc.com 

amorse@dmainc.corn 

cbeckner@dmainc.com 

CHARTER TOWNSHIP OF WASHINGTON’S 

ANSWER TO PETITIONER’S ENTIRE TRIBUNAL PETITION 

The 

Charter Township 

of Washington 

(“Respondent”), 

by 

and 

through 

its 

attorneys, SEIBERT AND DLOSKI, PLLC, for its answer to Petitioner's Entire Tribunal 

Property Tax Petition states as follows: 

1. 

Respondent admits the allegations contained in Paragraph 1. 

2. 

Respondent admits the allegations contained in Paragraph 2.

Page 2

5. 

Respondent admits the allegations contained in Paragraph 5. 

6. 

Respondent admits the allegations contained in Paragraph 6. 

7. 

Respondent admits the allegations contained in Paragraph 7. 

8. 

Respondent admits the allegations contained in Paragraph 8. 

9. 

Respondent admits the allegations contained in Paragraph 9. 

10. 

Respondent 

neither 

admits 

nor 

denies 

the 

allegations 

contained 

in 

Paragraph 

10 as 

it lacks sufficient knowledge to form 

a belief as to the truth of the 

allegations contained therein. 

11. 

Respondent 

neither 

admits 

nor 

denies 

the 

allegations 

contained 

in 

Paragraph 

11 

as 

it lacks sufficient knowledge to form 

a belief as to the truth of the 

allegations contained therein. 

12. 

Respondent admits the allegations contained in Paragraph 12. 

13. 

Respondent admits the allegations contained in Paragraph 13. 

14. 

Respondent 

neither 

admits 

nor 

denies 

the 

allegations 

contained 

in 

Paragraph 

14 as 

it lacks sufficient knowledge to form 

a belief as to the truth of the 

allegations contained therein. 

15. 

Respondent 

neither 

admits 

nor 

denies 

the 

allegations 

contained 

in 

Paragraph 15 as 

it lacks sufficient knowledge to form 

a belief as to the truth of the 

allegations contained therein.

Page 3

WHEREFORE, the Respondent respectfully requests the Tax Tribunal dismiss the 

Petition and award the Respondent its costs and attorney fees. 

Respectfully submitted, 

v 

n 

\ 

- 

| 

|! 41 

> 

By: Christine D. Anderson (P45141) 

Attorney for Respondent 

SEIBERT AND DLOSKI, PLLC 

19500 Hall Road, Suite 101 

Clinton Township, MI 48038 

Dated: 

July 17, 2026 

(586) 469-3800

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