25-002023 Amended Answer.pdf
Gedr Landmark LLC, Petitioner Vs. City Of Ann Arbor, Respondent · 25-002023-TT
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STATE OF MICHIGAN MICHIGAN TAX TRIBUNAL GEDR LANDMARK, LLC, Petitioner, v. CITY OF ANN ARBOR, Respondent. MTT Docket No. 25-002023 Sarah R. Belloli RYAN, LLC Representative for Petitioner 101 West Big Beaver, Suite 945 Troy, Michigan 48084 (313) 230-0104 sarah.belloli@ryan.com John W. Reiser (P45050) OFFICE OF THE CITY ATTORNEY Attorney for Respondent 301 E. Huron Street, 3rd Floor Ann Arbor, Michigan 48104-1908 (734) 794-6184 Jreiser@a2gov.org 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 GEDR LANDMARK, LLC (“Petitioner”) and states as follows: 1. Admit. 2. Admit. 3. No response required. 4. No response required. 5. No response required. 6. Admit. 7. No response required. 8. No response required. 9. No response required.
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2 10. Admit. 11. Admit. 12. Respondent leaves Petitioner to its proofs. 13. Respondent leaves Petitioner to its proofs. 14. Admit. 15. No response required. 16. Admit. 17. Respondent leaves Petitioner to its proofs. 18. Respondent leaves Petitioner to its proofs. 19. Respondent requests the Tribunal deny Petitioner’s request and sustain Respondent’s values. 20. Respondent leaves Petitioner to its proofs and further denies a. and b. as untrue. For the reasons stated above, Respondent asks the Tribunal to deny Petitioner’s request and affirm 2025 assessed and taxable values. Dated: September 22, 2025 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, Michigan 48104-1908 (734) 794-6170 jreiser@a2gov.org
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3 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 GEDR LANDMARK, 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: September 22, 2025 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, Michigan 48104-1908 (734) 794-6184 jreiser@a2gov.org PROOF OF SERVICE I hereby certify that I emailed a true and correct copy of the foregoing Response to Petition and Affirmative Defenses to the above-named representative for petitioner at the address listed above this July 29, 2025 and upon refiling, September 11, 2025 and September 22, 2025. /s/ Dawn Bagozzi Legal Assistant