Answer to Petition and Proof of Service.pdf
Dev H23 LLC Petitioner Vs. Township Of Lincoln Respondent · 26-002338-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN ADMINISTRATIVE HEARING SYSTEM MICHIGAN TAX TRIBUNAL DEV H23, LLC, Petitioner, MTT Docket: 26-002338 LINCOLN CHARTER TOWNSHIP Respondent, PROOF OF SERVICE STATE OF MICHIGAN SS COUNTY OF BERRIEN } John Baumann, being first duly sworn, deposes and says that he is employed by Lincoln Charter Township, Representative for Respondent herein, and that on the 13th day of JULY, 2026 he served, via United States mail, deposited in a mail receptacle in the Lincoln Charter Township building, a copy of ANSWER TO PETITION. Haji M Tehrani Representative for Petitioner 16915 Cleveland Ave Granger, IN 46530 (574) 876-7788 haji@driveandshine.com John po dae Sworn and subscribed to before me This 13th day of July, 2026. JULIE A. AMICARELLI NOTARY PUBLIC ~ STATE OF MICHIGAN COUNTY OF BERRIEN My Commission Expires Fe bruary 2, 2031 Acting in the County of WOVAENR
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFIARS MICHIGAN ADMINISTRATIVE HEARING SYSTEM MICHIGAN TAX TRIBUNAL DEV H23, LLC, Petitioner, MTT Docket: 26-002338 v. Property ID # 11-12-0021-0004-44-0 LINCOLN CHARTER TOWNSHIP, Respondent. / Haji M Tehrani John Baumann, MMAO, CAE Representative for Petitioner Representative for Respondent 16915 Cleveland Ave 2055 W John Beers Rd. Granger, IN 46530 P.O. Box 279 (574) 876-7788 Stevensville, MI 49127 haji@driveandshine.com (269) 429-1589 x103 jbaumann@]ctberrien.org ANSWER TO PETITION Respondent Lincoln Charter Township, through its representative, John Baumann, responds to the allegations made in the Petition as follows: 1. Respondent admits the allegations in Paragraph 1 on information and belief. 2. Respondent admits the allegations in Paragraph 2 on information and belief. 3. Respondent neither admits nor denies the allegations in Paragraph 3, leaving Petitioner to its proofs. 4. Respondent neither admits nor denies the allegations in Paragraph 4, leaving Petitioner to its proofs.
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5. Respondent neither admits nor denies the allegations in Paragraph 5, leaving Petitioner to its proofs. 6. Respondent admits the allegations in Paragraph 6 on information and belief. 7. Respondent admits the allegations in Paragraph 7 on information and belief. 8. Respondent neither admits nor denies the allegations in Paragraph 8, leaving Petitioner to its proofs. 9. Respondent neither admits nor denies the allegations in Paragraph 9, leaving Petitioner to its proofs. 10. Respondent admits the allegations in Paragraph 10 on information and belief. 11. Respondent admits the allegations in Paragraph 11 on information and belief. 12. Respondent neither admits nor denies the allegations in Paragraph 12, leaving Petitioner to its proofs. 13. Respondent neither admits nor denies the allegations in Paragraph 13, leaving Petitioner to its proofs. 14. Respondent neither admits nor denies the allegations in Paragraph 14, leaving Petitioner to its proofs. 15. Respondent neither admits nor denies the allegations in Paragraph 15, leaving Petitioner to its proofs. 16. Respondent admits the allegations in Paragraph 16 on information and belief. 17. Respondent neither admits nor denies the allegations in Paragraph 17, leaving Petitioner to its proofs. 18. Respondent neither admits nor denies the allegations in Paragraph 18, leaving Petitioner to its proofs. 19. Respondent neither admits nor denies the allegations in Paragraph 19, leaving Petitioner to its proofs. 20. Respondent neither admits nor denies the allegations in Paragraph 20, leaving Petitioner to its proofs. WHEREFORE, Respondent respectfully requests that this Honorable Tribunal deny Petitioner’s Petition, affirm the Respondent’s assessment of the subject property, award
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Respondent its reasonable costs and attorney fees incurred in defending this Petition, and grant such further relief as this Tribunal deems just and proper. £ John Bit MAO! CAE Representative for Respondent 2055 W. John Beers Rd P.O. Box 279 Stevensville, MI 49127 jbaumann@]ctberrien.org (269) 429-1589 x103 Dated: July 13, 2026