03. City's Response to Petition - LMP Ann Arbor Property Owner LLC - 26-001001.pdf
Lmp Ann Arbor Property Owner LLC Petitioner Vs. City Of Ann Arbor Respondent · 26-001001-TT
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STATE OF MICHIGAN MICHIGAN TAX TRIBUNAL LMP ANN ARBOR PROPERTY OWNER, LLC, Petitioner, v. CITY OF ANNY ARBOR, Respondent. MTT Docket No. 26-001001 Jerome P. Pesick (P29039) Jason C. Long (P59244) WILLIAM, WILLIAMS, RATTNER & PLUNKETT, PC Attorneys for Petition 380 N. Old Woodward Avenue, Suite 300 Birmingham, Michigan48009 (248) 642-0333 John W. Reiser (P45050) OFFICE OF THE CITY ATTORNEY Attorney for Respondent 301 E. Huron Street, 3rd Floor Ann Arbor, MI 48104-1908 (734) 794-6170 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 LMP Ann Arbor Property Owner, LLC (“Petitioner”), and states as follows: 1. Respondent leaves Petitioner to its proofs. 2. Admit. 3. Respondent leaves Petitioner to its proofs. 4. Admit. 5. Admit. 6. Admit. 7. Admit.
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2 8. Respondent leaves Petitioner to its proofs. 9. Respondent leaves Petitioner to its proofs. 10. Respondent leaves Petitioner to its proofs. 11. Respondent leaves Petitioner to its proofs as to subparagraphs (a) through (d). 12. Respondent leaves Petitioner to its proofs. For the reasons stated above, Respondent asks the Tribunal to deny Petitioner’s request and affirm 2026 assessed and taxable values. Dated: July 29, 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, MI 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 LMP Ann Arbor Property Owner, 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: July 29, 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, MI 48104-1908 (734) 794-6170 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 petitioner’s attorneys at the address listed above this July 29, 2026. /s/ Dawn Bagozzi Legal Assistant