Full record / City of Manistee - Divine Mercy - MTT 25-003340 - Request for Property Inspection (12.5.25).pdf

City of Manistee - Divine Mercy - MTT 25-003340 - Request for Property Inspection (12.5.25).pdf

Divine Mercy Of Manistee Diocese Of Gaylord, Petitioner Vs. City Of Manistee, Respondent · 25-003340-TT

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

DIVINE MERCY OF MANISTEE / 

DIOCESE OF GAYLORD, 

 

 

Petitioner, 

 

v 

 

CITY OF MANISTEE, 

 

 

Respondent. 

 

MTT Docket No. 25-003340 

 

 

PPN: 51-51-713-125-04 

 

____________________________/ 

 

 

 

Erica J. Sarver (P80106) 

BODMAN PLC 

Attorney for Petitioner 

1901 St. Antoine Street 

6th Floor at Ford Field 

Detroit, Michigan 48226 

(313) 259-7777 

esarver@bodmanlaw.com 

Toby Koenig (P72367) 

BLOOM SLUGGETT, PC 

Attorney for Respondent 

161 Ottawa Avenue NW, Suite 400 

Grand Rapids, Michigan 49503 

(616) 965-9340 

toby@bloomsluggett.com 

___________________________/ 

 

 

RESPONDENT’S REQUEST FOR ENTRY UPON AND INSPECTION 

OF PROPERTY UNDER APPEAL 

 

 

NOW COMES, Respondent, City of Manistee, by and through its attorneys, Bloom 

Sluggett, PC, and for its request for entry upon and inspection of the property under appeal to 

Petitioner, states as follows: 

REQUEST FOR ENTRY UPON LAND AND INSPECTION 

1. Pursuant to Michigan Tax Tribunal Rule 247(2), Respondent formally requests and 

demands an opportunity to enter upon Petitioner’s property that is under appeal in this 

matter for the purposes of inspecting the same, as is permitted by the Tax Tribunal and 

Court Rules identified herein.

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2 

 

4925-5345-2671, v. 1 

2. Accordingly, Respondent requests that Petitioner provide proposed dates and times (within 

28 days of the service of this request) for the Respondent’s representatives to enter upon 

the property under appeal to inspect the same. 

 

 

 

 

 

 

Dated: December 5, 2025 

Respectfully submitted, 

 

BLOOM SLUGGETT, PC 

 

/s/ Toby Koenig 

 

 

 

Toby Koenig (P72367) 

Attorney for Respondent 

161 Ottawa Ave. NW, Suite 400 

Grand Rapids, MI 49503 

(616) 965-9340 

 

 

PROOF OF SERVICE 

Tonya Voakes, being duly sworn, deposes and says that she is employed by Bloom Sluggett, 

PC, and that on December 5, 2025, she served a copy of Respondent’s Request for Entry Upon and 

Inspection of Property Under Appeal by First Class Mail, postage paid, and by electronic mail 

upon: 

 

Erica J. Sarver 

BODMAN PLC 

1901 St. Antoine Street 

6th Floor at Ford Field 

Detroit, Michigan 48226 

esarver@bodmanlaw.com 

/s/ Tonya Voakes 

 

 

 

 

 

 

 

 

 

 

 Tonya Voakes

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