Answer and AD.pdf
Reign Co2 Propco LLC Petitioner Vs. City Of Sterling Heights Respondent · 26-000483-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Reign CO2 Propco, LLC (by AT&T Services Inc., Tenant), Petitioner, v Docket No. 26-000483 Parcel No. 10-10-34-101-132 CITY OF STERLING HEIGHTS, Respondent. TED KUCH Kroll, LLC Representative for Petitioner 285 Fulton St., 31st Floor New York, NY 10007 (212) 833-3211 Ted.kuch@kroll.com MARC D. KASZUBSKI (P60333) O’Reilly Rancilio P.C. Attorney for Respondent 12900 Hall Road, Suite 350 Sterling Heights, MI 48313-1151 (586) 726-1000 mkaszubski@orlaw.com ANSWER TO PETITION Respondent, CITY OF STERLING HEIGHTS (“Respondent”), submits the following as its Answer to the Petition in this matter: 1. Admit. 2. Admit. 3. Admit. 4. Admit. 5. No response required. 6. Admit. 7. No response required. 8. No response required. 9. No response required.
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2 10. Admit. 11. Admit. 12. Neither admit nor deny as Respondent is without sufficient information upon which to form a belief as to the truth of the matter asserted. 13. Admit. 14. Admit. 15. No response required. 16. No response required. 17. Denied as untrue. 18. Denied as untrue. 19. Respondent requests the Michigan Tax Tribunal deny Petitioner’s request. 20. Denied as untrue. O’REILLY RANCILIO P.C. By: /s/ Marc D. Kaszubski Marc D. Kaszubski (P60333) Attorney for Respondent Dated: August 28, 2026
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3 RESPONDENT’S AFFIRMATIVE DEFENSES NOW COMES, Respondent, CITY OF STERLING HEIGHTS, by and through its attorneys, O’REILLY RANCILIO P.C. and states for its Affirmative Defenses as follows: 1. Petitioner lacks an interest in the property or standing to bring this action. 2. Lack of jurisdiction. 3. Res Judicata and Collateral Estoppel. 4. Petitioner fails to allege specific and sufficient facts to support a cause of action against Respondent. 5. The Petition is improper because it asks this Tribunal to grant a preference by application of a self-chosen method of assessment contrary to the laws of the State of Michigan. 6. The Petition is improper because its effect would be to shift the burden of the city, school and county taxes to other property owners within the City of Sterling Heights. 7. Petitioner has failed to join any and all claims arising out of the same transaction or occurrence subject to this action. 8. Respondent reserves the right to raise any additional affirmative defenses as they arise during the pendency of this matter. WHEREFORE, Respondent respectfully requests this Honorable Tribunal dismiss the Petition with prejudice and on the merits and further award Respondent any and all other relief in its favor as is deemed just and appropriate under the circumstances.
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4 O’REILLY RANCILIO P.C. By: /s/ Marc D. Kaszubski Marc D. Kaszubski (P60333) Attorney for Respondent Dated: August 28, 2026 PROOF OF SERVICE I served Respondent’s Answer to Petition and Affirmative Defenses upon the attorneys of record and/or parties in this case on August 28, 2026. I declare the foregoing statement to be true to the best of my information, knowledge and belief. U.S. Mail Fax Hand Delivered Messenger Express Mail Private Other /s/ Teresa A. Walsh Teresa A. Walsh