Full record / Respondent's Answer to Petition and Affirmative Defenses with PoS - 8-18-26 (1).pdf

Respondent's Answer to Petition and Affirmative Defenses with PoS - 8-18-26 (1).pdf

Align Realty LLC Petitioner Vs. Township Of Allendale Respondent · 26-001486-TT

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND 

REGULATORY AFFAIRS 

ALIGN REALTY LLC, 

Petitioner, 

Docket No. 26-001486 

Parcel No. 70-09-25-200-070 

v. 

TOWNSHIP OF ALLENDALE, 

Respondent. 

Colliers International 

By: Joshua T. Shillair, Esq. (P72674) 

Representative for Petitioner 

400 W. 4" Street, Suite 350 

Royal Oak, Michigan 48067 

Bradley J. Fisher (P64608) 

SCHOLTEN FANT 

Attorneys for Respondent 

100 N. Third St. PO BOX 454 

Phone: (248) 226-1632 

Joshua shillair@colliers.com 

Karen.cameron@colliers.com 

Grand Haven, MI 49417 

Phone: (616) 842-3030 

bfisher@scholtenfant.com 

RESPONDENT’S ANSWER 

TO PETITIONER’S ENTIRE TRIBUNAL PROPERTY TAX PETITION 

NOW COMES the Respondent, ALLENDALE CHARTER TOWNSHIP, by and 

through its attorneys, SCHOLTEN FANT, and for its Answer to Petitioner’s Entire Tribunal 

Property Tax Petition states as follows: 

Admitted upon information and belief. 

Admitted upon information and belief. 

Admitted upon information and belief. 

Admitted upon information and belief. 

Admitted upon information and belief. 

Admitted upon information and belief. 

AE 

Neither admitted nor denied for lack of sufficient knowledge or information as to 

form a belief, and therefore leaves the Petitioner to its proofs. 

8. 

Admitted upon information and belief.

Page 2

9. 

Admitted upon information and belief. 

10. 

Denied as untrue, including all individual subparts. 

11. 

Neither admitted nor denied for lack of sufficient knowledge or information as to 

form a belief, and therefore leaves the Petitioner to its proofs. 

12. 

Neither admitted nor denied for lack of sufficient knowledge or information as to 

form a belief, and therefore leaves the Petitioner to its proofs. 

13. 

Neither admitted nor denied for lack of sufficient knowledge or information as to 

form a belief, and therefore leaves the Petitioner to its proofs. 

WHEREFORE, Respondent respectfully requests that 

the Tribunal deny Petitioners 

requested relief, affirm the assessments made by Respondent’s Assessor, award Respondent its 

costs and attorney’s fees in responding to this action and award such further relief that it deems 

appropriate under the circumstances. 

Respectfully submitted, 

HOLTEN 

FANT 

Dated: August 18, 2026 

By: 

BradleyNl. Fisher (P64608) 

Attorneys for 

Respondent, Allendale Twp. 

AFFIRMATIVE DEFENSES TO PETITIONER’S PETITION 

NOW COMES the Respondent, TOWNSHIP OF ALLENDALE, by and through its 

attorneys, SCHOLTEN FANT, and states that it may rely on one or all of the following affirmative 

defenses: 

8 

The appropriate methods of assessing the Subject Property were used and those 

methods conform to the methods used to assess similarly situated property in the State. 

2. 

Petitioner has failed to state a claim upon which relief can be granted. 

3 

Petitioner may not be a proper party-in-interest. 

4. 

Petitioner may not have standing to appeal. 

5 

The Tribunal may lack subject matter jurisdiction over this appeal.

Page 3

6. 

Petitioner may have failed to comply with state property tax law by, inter alia, 

failing to report or failing to report completely its assessable property such that its property taxes 

were delinquent or underpaid, such that Petitioner is precluded from appealing its property values, 

and, such that Respondent should be awarded damages. 

7. 

Respondent reserves the right to add additional affirmative defenses as they become 

known to it through discovery in this matter. 

WHEREFORE, Respondent requests that the Tribunal affirm the 2025 assessed and 

taxable values as determined by Respondent, to dismiss the Petition, and award Respondent costs, 

attorney fees and any other relief that the Tribunal determines is fair, just and equitable. 

Res 

submitted, 

SCGHOLTEN 

FANT 

BradlkyJ. Fisher (P64608) 

Attorneys for 

t, Allendale Twp. 

Dated: August 18, 2026 

By:

Page 4

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND 

REGULATORY AFFAIRS 

ALIGN REALTY LLC, 

Petitioner, 

Docket No. 26-001486 

Parcel No. 70-09-25-200-070 

v. 

TOWNSHIP OF ALLENDALE, 

Respondent. 

Colliers International 

By: Joshua T. Shillair, Esq. (P72674) 

Bradley J. Fisher (P64608) 

Representative for Petitioner 

SCHOLTEN FANT 

400 W. 4 Street, Suite 350 

Attorneys for Respondent 

Royal Oak, Michigan 48067 

100 N. Third St. PO BOX 454 

Phone: (248) 226-1632 

Grand Haven, MI 49417 

Joshua.shillair@colliers.com 

Phone: (616) 842-3030 

Karen.cameron@colliers.com 

bfisher@scholtenfant.com 

PROOF OF SERVICE 

The undersigned certifies that a copy of the Appearance and Respondent's Answer to 

Property Tax Petition and Affirmative Defenses to Petitioner's Property Tax Petition was e-filed 

with the Michigan Tax Tribunal and served upon all parties and/or attorneys of record to this action 

to their addresses as disclosed by the pleadings, on August 18, 2026, via email and U.S. Mail First 

Class, from Grand Haven, Michigan, with postage thereon fully prepaid. 

Dated: August 18, 2026 

befly Tapp 

Legal Assistant to Bradley J. Fisher

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