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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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.
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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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3 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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4 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