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