Full record / 03. City's Answer to Petition - The Kroger Co. of Michigan - 25-002024.pdf

03. City's Answer to Petition - The Kroger Co. of Michigan - 25-002024.pdf

The Kroger Co Of Michigan, Petitioner Vs. City Of Ann Arbor, Respondent · 25-002024-TT

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Page 1

STATE OF MICHIGAN 

MICHIGAN TAX TRIBUNAL 

THE KROGER CO. OF MICHIGAN, 

 

Petitioner, 

v. 

CITY OF ANN ARBOR, 

 

Respondent. 

Docket No. 25-002024 

Michelle M. Silvey (P69494) 

Alex Morse 

DuCHARME, McMILLEN & ASSOCIATES, INC. 

Representatives for Petitioner 

9229 Delegates Row, Suite 375 

Indianapolis, Indiana 46240 

(371) 689-6467 

msilvey@dmainc.com 

amorse@dmainc.com 

John W. Reiser (P45050) 

OFFICE OF THE CITY ATTORNEY 

Attorney for Respondent 

301 E. Huron Street, 3rd Floor 

Ann Arbor, Michigan 48104 

(734) 794-6184 

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 The Kroger Co. of Michigan, (“Petitioner”) and 

states as follows: 

1. 

Admit. 

2. 

Admit. 

3. 

Admit. 

4. 

Respondent leaves Petitioner to its proofs. 

5. 

Admit. 

6. 

Admit. 

7. 

Admit.

Page 2

2 

8. 

Admit. 

9. 

Admit. 

10. 

Respondent leaves Petitioner to its proofs. 

11. 

Respondent leaves Petitioner to its proofs. 

12. 

Admit. 

13. 

Admit. 

14. 

Respondent leaves Petitioner to its proofs. 

15. 

Respondent leaves Petitioner to its proofs. 

16. 

Respondent denies subparagraphs (a) through (d) as untrue and further leaves 

Petitioner to its proofs. 

For the reasons stated above, Respondent requests that the Tribunal deny Petitioner’s 

request and affirm 2025 assessed and taxable values. 

Dated: October 17, 2025 

Respectfully submitted, 

OFFICE OF THE CITY ATTORNEY 

By: 

/s/ John W. Reiser 

 

 

 

 

John W. Reiser (P45050) 

 

Attorney for City of Ann Arbor 

 

301 E. Huron Street, 3rd Floor 

 

Ann Arbor, Michigan 48104 

 

(734) 794-6170 

 

jreiser@a2gov.org

Page 3

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 The Kroger Co. of Michigan, 

(“Petitioner”) states as follows: 

1. 

Respondent reserves the right to raise affirmative defenses as the same becomes 

apparent in the course of this litigation. 

Dated: October 17, 2025 

Respectfully submitted, 

OFFICE OF THE CITY ATTORNEY 

By: 

/s/ John W. Reiser 

 

 

 

 

John W. Reiser (P45050) 

 

Attorney for City of Ann Arbor 

 

301 E. Huron Street, 3rd Floor 

 

Ann Arbor, Michigan 48104 

 

(734) 794-6184 

 

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 representatives at the email addresses 

listed above this October 17, 2025. 

 /s/ Dawn Bagozzi 

 

 

 Legal Assistant

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