Answer to 2026 Entire Tribunal Property Petition.pdf
Maniko LLC Petitioner Vs. Township Of Monitor Respondent · 26-001626-TT
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1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL MANIKO LLC, Petitioner, MTT Docket No. 26-001626 -vs- BAY CITY (MONITOR TOWNSHIP) Respondent, JOSHUA T. SHILLAIR, ESQ. (P72674) COLLIERS INTERNATIONAL Tax Appeal Representative for Petitioner 400 W. 4th Street, Suite 350 Royal Oak, MI 48067 (248) 226-1632 / (248) 226-1633 fax Joshua.Shillair@Colliers.com Karen.Cameron@Colliers.com THOMAS D. LANDA (P78201) THOMAS J. McGRAW (P48817) NICHOLAS R. SCHNEIDER (P88238) MCGRAW MORRIS MASUD, P.C. Attorneys for Respondent 2075 West Big Beaver Road, Ste 750 Troy, MI 48084 (248) 502-4000 tlanda@mcgrawmorris.com nschneider@mcgrawmorris.com RESPONDENT’S ANSWER TO 2026 ENTIRE TRIBUNAL PROPERTY TAX PETITION Respondent, Monitor Township (“Respondent”), through its attorneys, McGraw Morris Masud P.C., states as follows for its answer to Maniko, LLC’s (“Petitioner”) Petition: 1. Respondent neither admits nor denies the allegations in paragraph 1 for the reason that it lacks sufficient knowledge or information to form a belief as to the truth thereof and therefore leaves Petitioner to its proofs. 2. Admitted. 3. Admitted.
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2 4. Respondent neither admits nor denies the allegations in paragraph 4 for the reason that it lacks sufficient knowledge or information to form a belief as to the truth thereof and therefore leaves Petitioner to its proofs. 5. Respondent neither admits nor denies the allegations in paragraph 5 for the reason that it lacks sufficient knowledge or information to form a belief as to the truth thereof and therefore leaves Petitioner to its proofs. 6. Admitted. 7. Respondent neither admits nor denies the allegations in paragraph 7 for the reason that it lacks sufficient knowledge or information to form a belief as to the truth thereof and therefore leaves Petitioner to its proofs. 8. Admitted. 9. Admitted. 10. Denied as untrue, including all subparagraphs. 11. Denied as untrue. 12. Respondent neither admits nor denies the allegations in paragraph 12 for the reason that it lacks sufficient knowledge or information to form a belief as to the truth thereof and therefore leaves Petitioner to its proofs. 13. Denied as untrue. WHEREFORE, Respondent Monitor Township requests that the Tribunal deny any and all relief sought by Petitioner and grant Respondent any other relief it deems just and equitable.
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3 MCGRAW MORRIS MASUD, P.C. By: /s/ Thomas D. Landa THOMAS D. LANDA (P78201) THOMAS J. McGRAW (P48817) NICHOLAS R. SCHNEIDER (P88238) Attorneys for Respondent 2075 W. Big Beaver Rd., Ste., 750 Troy, MI 48084 (248) 502-4000 Dated: September 9, 2026
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4 AFFIRMATIVE DEFENSES TO PETITION 1. Respondent used the proper means and method to establish the assessment and made a proper assessment according to Michigan Law. 2. Respondent reserves the right to add, amend, or delete any and all Affirmative Defenses up to and including trial. MCGRAW MORRIS MASUD, P.C. By: /s/ Thomas D. Landa THOMAS D. LANDA (P78201) THOMAS J. McGRAW (P48817) NICHOLAS R. SCHNEIDER (P88238) Attorneys for Respondent 2075 W. Big Beaver Rd., Ste., 750 Troy, MI 48084 (248) 502-4000 Dated: September 9, 2026 PROOF OF SERVICE The undersigned certifies that a copy of the foregoing Respondent’s Answer To 2026 Entire Tribunal Property Tax Petition was served upon all attorney(s) of record of all party(ies) to the above cause at the respective addresses disclosed in the pleadings on September 9, 2026 by: ☐U.S. Mail ☐Fax ☐Hand Delivery ☐Overnight Courier ☒E-Mail ☐E-File/E-Serve ☐Other: _____________________ I declare under the penalty of perjury that the statement above is true to the best of my information, knowledge and belief. /s/ April M. Leve April M. Leve