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Answer to Petition.pdf

Cmg Pcp Associates LLC, Petitioner Vs. Township Of Washington, Respondent · 25-001813-TT

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

CMG PCP ASSOCIATES, LLC, 

Petitioner, 

-Vs- 

MOAHR Docket No: 25-001813 

TOWNSHIP OF WASHINGTON, 

Respondent. 

/ 

AARON M. FALES (P72864) 

CHRISTINE D. ANDERSON (P45141) 

Attorney for Petitioner 

Attorney for Respondent 

330 Hamilton Row, Ste. 350 

SEIBERT AND DLOSKI, PLLC 

Birmingham, MI 

48009 

19500 Hall Road, Suite 101 

(248)767-9840 

Clinton Township, MI 48038 

afaleslaw@amail.com 

(586) 469-3800 

canderson@seibertanddloski.com 

RESPONDENT'S ANSWER TO PETITION 

The 

Charter Township 

of Washington 

(“Respondent”), 

by 

and 

through 

its 

attorneys, SEIBERT AND DLOSKI, PLLC, answers the Petition as follows: 

1. 

Respondent lacks sufficient knowledge to form a belief as to the truth of the 

allegations contained in Paragraph 1. 

2. 

Respondent admits the allegations contained in Paragraph 2. 

3. 

Respondent admits the allegations contained in Paragraph 3.

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5. 

Respondent lacks sufficient knowledge to form a belief as to the truth of the 

allegations contained in Paragraph 5. 

6. 

Respondent lacks sufficient knowledge to form a belief as to the truth of the 

allegations contained in Paragraph 6. 

7. 

Respondent denies the allegations contapined in Paragraph 7 as they are 

untrue and further denies Petitioner is entitled to the requested relief as the subject parcel 

was lawfully and uniformally assessed for the tax year at issue. 

WHEREFORE, 

the Respondent respectfully requests the Tax Tribunal 

dismiss the Petition and award the Respondent its costs and attorney fees. 

Respectfully submitted, 

os AND DLOSKI, PLLC 

Jay. 

By: Christine D. Anderson (P45141) 

Attorney for Roe 

SEIBERT AND DLOSKI, PLLC 

19500 Hall Road, Suite 101 

Clinton Township, MI 48038 

Dated: September 26, 2025 

(586) 469-3800

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