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City's Response to Petition - Mall at Briarwood LLC - MTT 26-000490.pdf

Mall At Briarwood LLC Petitioner Vs. City Of Ann Arbor Respondent · 26-000490-TT

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Page 1

5TATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

Mall at Briarwood, LLC, 

 

Petitioner, 

v. 

City of Ann Arbor, 

 

Respondent. 

MTT Docket No. 26-000490 

Eva T. Cantarella (P51917) 

Hertz Schram PC 

Attorney for Petitioner 

1760 S. Telegraph Road 

Bloomfield Hills, MI 48302-0183 

(248) 335-5000 

Ecantarella@Hertzschram.com 

John W. Reiser (P45050) 

OFFICE OF THE CITY ATTORNEY 

Attorney for Respondent 

301 E. Huron Street, 3rd Floor 

Ann Arbor, MI 48104-1908 

(734) 794-6184 

Jreiser@a2gov.org 

David Suess 

Brent Auberry 

Benjamin Blair 

Faegre Drinker Biddle & Reath LLP 

Attorneys for Petitioner 

300 N. Meridian Street, Ste 2500 

Indianapolis, IN 46204 

(317) 684-5112 

david.suess@faegredrinker.com 

brent.auberry@faegredrinker.com 

benjamin.blair@faegredrinker.com 

 

RESPONDENT CITY OF ANN ARBOR’S 

RESPONSE TO PETITION 

Respondent City of Ann Arbor (“Respondent”), through the Ann Arbor City 

Attorney’s Office, responds in opposition to the Petition of Mall at Briarwood, 

LLC (“Petitioner”) and states as follows: 

1. 

Respondent leaves Petitioner to its proofs. 

2. 

Admit.

Page 2

2 

3. 

Respondent leaves Petitioner to its proofs. 

4. 

Respondent leaves Petitioner to its proofs. 

5. 

Admit. 

6. 

Admit. 

7. 

Admit. 

8. 

Respondent leaves Petitioner to its proofs as to (a) through (c). 

9. 

Admit. 

10. 

Admit. 

11. 

Admit. 

12. 

Respondent leaves Petitioner to its proofs. 

13. 

Respondent leaves Petitioner to its proofs. 

14. 

Respondent leaves Petitioner to its proofs. 

15. 

Respondent leaves Petitioner to its proofs. 

16. 

Respondent leaves Petitioner to its proofs. 

17. 

Respondent leaves Petitioner to its proofs. 

18. 

Respondent leaves Petitioner to its proofs. 

19. 

Respondent leaves Petitioner to its proofs. 

20. 

Respondent leaves Petitioner to its proofs as to its contention that the 

Assessed State Equalized Value and Taxable Value are invalid, and leaves 

Petitioner to its proofs as to subparagraphs (a) through (c). 

21. 

Respondent leaves Petitioner to its proofs. 

22. 

Respondent leaves Petitioner to its proofs.

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23. 

Respondent leaves Petitioner to its proofs. 

24. 

Respondent leaves Petitioner to its proofs. 

25. 

Respondent requests the Tribunal deny this request. 

For the reasons stated above, Respondent asks the Tribunal to deny 

Petitioner’s request that the Tribunal affirm its 2026 market value and deny 

Petitioner’s request. 

Dated: June 8, 2026 

Respectfully submitted, 

OFFICE OF THE CITY ATTORNEY 

By: 

/s/ John W. Reiser 

 

 

 

John W. Reiser (P45050) 

 

Attorney for City of Ann Arbor 

 

301 E. Huron Street, 3rd Floor 

 

Ann Arbor, MI 48104-1908 

 

(734) 794-6184

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AFFIRMATIVE DEFENSES 

Respondent City of Ann Arbor (“Respondent”), through the Ann Arbor City 

Attorney’s Office, and for its Affirmative Defenses to the Petition of Mall at 

Briarwood, LLC (“Petitioner”) states as follows: 

1. 

Respondent reserves the right to raise affirmative defenses as the 

same become apparent in the course of this litigation. 

Dated: June 8, 2026 

Respectfully submitted, 

OFFICE OF THE CITY ATTORNEY 

By: 

/s/ John W. Reiser 

 

 

 

John W. Reiser (P45050) 

 

Attorney for City of Ann Arbor 

 

301 E. Huron Street, 3rd Floor 

 

Ann Arbor, MI 48104-1908 

 

(734) 794-6184 

PROOF OF SERVICE 

I hereby certify that I emailed a true and correct copy of the foregoing 

Response to Petition and Affirmative Defenses to Petitioner’s attorneys at the 

address listed above this June 8, 2026. 

 /s/ Dawn Bagozzi 

 

 

 Legal Assistant

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