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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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.
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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
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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