25002453 FINAL Grand Haven Answer to Petition - Prep LLC.pdf
Prep LLC, Petitioner Vs. City Of Grand Haven, Respondent · 25-002453-TT
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CLARKHILL\09999\09998-5325\283563131.v1-9/8/25 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL ________________________________________________ Docket No. 25-002453 Parcel No. 70-03-21-326-043 PREP LLC, Petitioner, v CITY OF GRAND HAVEN, Respondent. / Stephen Polter (P72591) POLTER LAW GROUP PC Attorney for Petitioner 2600 W Big Beaver, Suite L100 Troy, MI 48084 (248) 213-6800 spolter@polterlaw.com Elizabeth White McDonnell (P62561) Sean P. Fitzgerald (P60654) CLARK HILL PLC Attorneys for Respondent 200 Ottawa NW, Suite 500 Grand Rapids, MI 49503 (616) 608-1131 ewhitemcdonnell@clarkhill.com sfitzgerald@clarkhill.com / ANSWER TO PETITION Respondent, City of Grand Haven, by and through its attorneys, Clark Hill PLC, answers the Petition filed by Prep LLC, Petitioner, and states as follows: 1. Respondent admits the allegations in paragraph 1 of the Petition. 2. Respondent admits the allegations in paragraph 2 of the Petition. 3. Respondent lacks the knowledge or information to form a belief as to the truth of the allegations contained in paragraph 3 of the Petition. 4. Respondent lacks the knowledge or information to form a belief as to the truth of the allegations contained in paragraph 4 of the Petition. 5. Respondent lacks the knowledge or information to form a belief as to the truth of the allegations contained in paragraph 5 of the Petition.
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2 CLARKHILL\09999\09998-5325\283563131.v1-9/8/25 6. Respondent admits the allegations in paragraph 6 of the Petition. 7. Respondent lacks the knowledge or information to form a belief as to the truth of the allegations contained in paragraph 7 of the Petition. 8. Respondent lacks the knowledge or information to form a belief as to the truth of the allegations contained in paragraph 8 of the Petition. 9. Respondent lacks the knowledge or information to form a belief as to the truth of the allegations contained in paragraph 9 of the Petition. 10. Respondent admits the allegations in paragraph 10 of the Petition. 11. Respondent admits the allegations in paragraph 11 of the Petition. 12. Respondent lacks the knowledge or information to form a belief as to the truth of the allegations contained in paragraph 12 of the Petition. 13. Respondent lacks the knowledge or information to form a belief as to the truth of the allegations contained in paragraph 13 of the Petition. 14. Respondent lacks the knowledge or information to form a belief as to the truth of the allegations contained in paragraph 14 of the Petition. 15. Respondent lacks the knowledge or information to form a belief as to the truth of the allegations contained in paragraph 15 of the Petition. 16. Respondent admits the allegations in paragraph 16 of the Petition. 17. Respondent lacks the knowledge or information to form a belief as to the truth of the allegations contained in paragraph 17 of the Petition. 18. Respondent denies the allegations in paragraph 18 of the Petition as untrue. 19. Respondent denies the allegations in paragraph 19 of the Petition as untrue 20. Respondent denies the allegations in paragraph 20 of the Petition as untrue
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3 CLARKHILL\09999\09998-5325\283563131.v1-9/8/25 WHEREFORE, Respondent respectfully requests that the Tax Tribunal dismiss the Petition, sustain the assessed, taxable and true cash values with respect to the property as established by Respondent, award the costs and fees, including attorneys’ fees, incurred by Respondent in the defense of this matter, and grant such other and further relief as the Tribunal deems just and proper. Dated: September 8, 2025 Respectfully submitted, CLARK HILL PLC By: Elizabeth White McDonnell (P62561) Sean P. Fitzgerald (P60654) Attorneys for Respondent
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4 CLARKHILL\09999\09998-5325\283563131.v1-9/8/25 AFFIRMATIVE DEFENSES TO PETITIONER’S PETITION NOW COMES Respondent, City of Grand Haven, by and through its attorneys, Clark Hill PLC, and hereby offers the following Affirmative Defenses to Petitioner’s Petition as follows: 1. Petitioner fails to allege specific and sufficient facts to set forth a cause of action against Respondent and to support its claim of relief. 2. Respondent has properly and lawfully classified Petitioner’s property and established its taxable and assessed value in accordance with local ordinances, state regulations, statutory and constitutional requirements. 3. Respondent reserves the right to add other affirmative defenses as they become known. Dated: September 8, 2025 Respectfully submitted, CLARK HILL PLC By: Elizabeth White McDonnell (P62561) Sean P. Fitzgerald (P60654) Attorneys for Respondent
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL ________________________________________________ Docket No. 25-002453 Parcel No. 70-03-21-326-043 PREP LLC, Petitioner, v CITY OF GRAND HAVEN, Respondent. / Stephen Polter (P72591) POLTER LAW GROUP PC Attorney for Petitioner 2600 W Big Beaver, Suite L100 Troy, MI 48084 (248) 213-6800 spolter@polterlaw.com Elizabeth White McDonnell (P62561) Sean P. Fitzgerald (P60654) CLARK HILL PLC Attorneys for Respondent 200 Ottawa NW, Suite 500 Grand Rapids, MI 49503 (616) 608-1131 ewhitemcdonnell@clarkhill.com sfitzgerald@clarkhill.com / PROOF OF SERVICE The undersigned certifies that on the date below, a copy of Respondent’s Answer was served via electronic mail, upon: Stephen Polter spolter@polterlaw.com Date: September 8, 2025 /s/ Bailey Dettloff Bailey Dettloff