City's Response to Petition - EPR2 LLC - 26-001496.1.pdf
Epr2 LLC Petitioner Vs. City Of Ann Arbor Respondent · 26-001496-TT
Text extracted from the reviewed PDF, organized by page. OCR and reading order may contain errors; confirm details in the PDF below.
Page 1
STATE OF MCHIGAN MICHIGAN TAX TRIBUNAL EPR2 LLC, Petitioner, V City of Ann Arbor, Respondent. MTT Docket No. 26-001496 Aaron M. Fales (P72864) LAW OFFICE OF AARON M. FALES, P.C. Attorney for Petitioner 330 Hamilton Row, Suite 350 Brimingham, Michigan 48009 (248) 767-9840 aaron@afaleslaw.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) 794-6170 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 EPR2 LLC (“Petitioner”) as follows: 1. Respondent leaves Petitioner to its proofs. 2. Admit. 3. Admit. 4. Respondent leaves Petitioner to its proofs. 5. Respondent leaves Petitioner to its proofs as to (a) through (d). 6. Respondent leaves Petitioner to its proofs.
Page 2
2 7. Respondent leaves Petitioner to its proofs and denies subparagraphs (a) through (d) as untrue. For the reasons stated above, Respondent requests that the Tribunal deny Petitioner’s request and affirm its 2026 assessed and taxable values. Dated: October 13, 2026 Respectfully submitted, OFFICE OF THE CITY ATTORNEY By: /s/ John W. Reiser John W. Reiser (P45050) Attorney for Respondent 301 E. Huron Street, 3rd Floor Ann Arbor, Michigan 48104-1908 (734) 794-6170 jreiser@a2gov.org 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 EPR2 LLC (“Petitioner”), states the following: 1. Respondent reserves the right to raise affirmative defenses as the same become apparent in the court of this litigation. Dated: October 13, 2026 Respectfully submitted, OFFICE OF THE CITY ATTORNEY By: /s/ John W. Reiser John W. Reiser (P45050) Attorney for Respondent 301 E. Huron Street, 3rd Floor Ann Arbor, Michigan 48104-1908 (734) 794-6170 jreiser@a2gov.org
Page 3
3 PROOF OF SERVICE I hereby certify that on October 13, 2026, I emailed a true and correct copy of the foregoing Response to Petition and Affirmative Defenses to the above-named attorney for petitioner at the address listed above. /s/ Dawn M. Bagozzi Legal Assistant