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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1 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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2 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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3 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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4 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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5 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