Full record / Cedar Springs - Friedman Real Estate 25-001652-TT - Respondent's Appearance Answer & ADs with POS 7-31-25.pdf

Cedar Springs - Friedman Real Estate 25-001652-TT - Respondent's Appearance Answer & ADs with POS 7-31-25.pdf

Friedman Real Estate Management Company, Petitioner Vs. City Of Cedar Springs, Respondent · 25-001652-TT

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4907-5570-6712, v. 1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

FRIEDMAN REAL ESTATE 

MANAGEMENT, 

 

 

Petitioner, 

 

v 

 

CITY OF CEDAR SPRINGS, 

 

 

Respondent. 

 

MTT Docket No. 25-001652-TT 

 

Parcel No. 41-02-36-100-072 

 

 

 

 

 

 

 

/ 

 

 

 

 

John-Paul Wolfe 

FRIEDMAN REAL ESTATE 

Petitioner’s Representative 

34975 W. Twelve Mile Road 

Farmington Hills, MI 48331 

(248) 848-4154 

jp.wolfe@freg.com 

 

Toby Koenig (P72367) 

BLOOM SLUGGETT, PC 

Attorneys for Respondent 

161 Ottawa Ave NW, Suite 400 

Grand Rapids, MI 49503 

(616) 965-9340 

toby@bloomsluggett.com 

 

 

 

 

 

 

 

 

/ 

 

 

 

 

APPEARANCE 

 

NOW COMES attorney Toby Koenig, of the law firm of Bloom Sluggett, PC and hereby 

enters his appearance on behalf of Respondent in this matter. 

 

 

 

 

 

Dated: July 31, 2025 

Respectfully submitted, 

 

BLOOM SLUGGETT, PC 

 

/s/ Toby Koenig 

 

 

 

Toby Koenig (P72367) 

Attorney for Respondent 

161 Ottawa Ave. NW, Suite 400 

Grand Rapids, MI 49503 

(616) 965-9340

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4907-5570-6712, v. 1 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

FRIEDMAN REAL ESTATE 

MANAGEMENT, 

 

 

Petitioner, 

 

v 

 

CITY OF CEDAR SPRINGS, 

 

 

Respondent. 

 

MTT Docket No. 25-001652-TT 

 

Parcel No. 41-02-36-100-072 

 

 

 

 

 

 

 

/ 

 

 

 

 

John-Paul Wolfe 

FRIEDMAN REAL ESTATE 

Petitioner’s Representative 

34975 W. Twelve Mile Road 

Farmington Hills, MI 48331 

(248) 848-4154 

jp.wolfe@freg.com 

 

Toby Koenig (P72367) 

BLOOM SLUGGETT, PC 

Attorneys for Respondent 

161 Ottawa Ave NW, Suite 400 

Grand Rapids, MI 49503 

(616) 965-9340 

toby@bloomsluggett.com 

 

 

 

 

 

 

 

 

/ 

 

 

 

 

RESPONDENT’S ANSWER TO PETITION AND AFFIRMATIVE DEFENSES 

NOW COMES Respondent through its attorneys Bloom Sluggett, PC, and hereby submits 

its Answer to Petition and Affirmative Defenses as follows: 

1. Petitioner’s allegation as to the property parcel number at issue is merely a statement 

of the claim that requires no response 

 

2. Admitted. 

 

3. There are no allegations in Paragraph 3 of Petitioner’s petition, and Respondent 

otherwise leaves Petitioner to its proofs. 

 

4. There are no allegations in Paragraph 4 of Petitioner’s petition, and Respondent 

otherwise leaves Petitioner to its proofs. 

 

5. There are no allegations in Paragraph 5 of Petitioner’s petition, and Respondent 

otherwise leaves Petitioner to its proofs. 

 

6. Admitted.

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4907-5570-6712, v. 1 

7. There are no allegations in Paragraph 7 of Petitioner’s petition, and Respondent 

otherwise leaves Petitioner to its proofs. 

 

8. There are no allegations in Paragraph 8 of Petitioner’s petition, and Respondent 

otherwise leaves Petitioner to its proofs. 

 

9. There are no allegations in Paragraph 9 of Petitioner’s petition, and Respondent 

otherwise leaves Petitioner to its proofs. 

 

10. Admitted. 

 

11. Admitted. 

 

12. Respondent lacks sufficient knowledge or information to form a belief as to the 

truthfulness of the allegations in paragraph 12 of Petitioner’s petition, and Respondent 

otherwise leaves Petitioner to its proofs. 

 

13. The paragraph contains a restatement of Petitioner’s claim to which no response is 

required. To the extent a response is required, Respondent admits that Petitioner alleges 

issues relating to the subject property’s true cash and taxable values and the uniformity 

of the assessment, but Respondent denies that the subject property is improperly 

assessed and denies that Petitioner is entitled to any relief. 

 

14. Admitted. 

 

15. There are no allegations in paragraph 15 of Petitioner’s petition, and Respondent 

otherwise leaves Petitioner to its proofs. 

 

16. Admitted that the values alleged by Petitioner in paragraph 16 of Petitioner’s petition 

accurately reflect the Taxable Value, Assessed Value, and True Cash Value established 

by Respondent’s Board of Review for the 2025 tax year. 

 

17. Respondent denies as untrue the values alleged by Petitioner in paragraph 17 of 

Petitioner’s petition. 

 

18. Respondent admits that Petitioner alleges the values in dispute in paragraph 18 of 

Petitioner’s petition, but Respondent denies that the subject property is inaccurately 

assessed or that Petitioner is entitled to any relief. 

 

19. Paragraph 19 of Petitioner’s petition contains a request for relief to which no response 

is required; Respondent otherwise denies that Petitioner is entitled to any relief. 

 

20. Paragraph 20 contains allegations and statements allegedly supporting Petitioner’s 

request for relief to which no response is required; Respondent otherwise denies that 

the subject property is inaccurately assessed and denies that Petitioner is entitled to any 

relief.

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4907-5570-6712, v. 1 

WHEREFORE, Respondent requests that the Tribunal dismiss Petitioner’s appeal with 

prejudice and award Respondent its costs, attorney fees, and all such further and additional relief 

as this Tribunal may deem appropriate. 

 

AFFIRMATIVE DEFENSES 

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

2. Petitioner’s claims against Respondent are barred because the valuation methods used 

by Respondent comply with the Constitution, state law, and prevailing State Tax Commission 

procedures. 

 

3. Respondent’s assessment reflects 50% of the subject property’s true cash value, and 

the values on the roll, including the taxable value, comply with the General Property Tax Act. 

 

4. Petitioner has failed to allege facts to support standing to bring this appeal or that it is 

a proper party-in-interest. 

 

5. Petitioner has failed to allege facts to support its allegation that the taxable value of the 

subject property is improper. 

 

6. Respondent reserves the right to identify further affirmative defenses as may become 

known through discovery. 

 

 

 

 

 

 

Dated: July 31, 2025 

Respectfully submitted, 

 

BLOOM SLUGGETT, PC 

 

/s/ Toby Koenig 

 

 

 

Toby Koenig (P72367) 

Attorney for Respondent

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4907-5570-6712, v. 1 

PROOF OF SERVICE 

Tonya Voakes, being duly sworn, deposes and says that she is employed by Bloom 

Sluggett, PC, and that on July 31, 2025, she served a copy of Respondent’s Appearance and 

Respondent’s Answer to Petition with Affirmative Defenses by First Class and electronic mail 

upon: 

 

John-Paul Wolfe 

FRIEDMAN REAL ESTATE 

34975 W. Twelve Mile Road 

Farmington Hills, MI 48331 

(248) 848-4154 

jp.wolfe@freg.com 

/s/ Tonya Voakes 

 

 

 

 

 

 

 

 

 

 

 Tonya Voakes

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