Requests for Admission - Napior Adrian (26-000636)FINAL.pdf
Napior Leasing, LLC Petitioner Vs. City Of Adrian Respondent · 26-000636-TT
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76742601.1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Napior Leasing, LLC, Petitioner, v. City of Adrian, Respondent. MTT Docket No. 26-000636 Jackie J. Cook (P68781) Scott L. Damich (P74126) Honigman LLP Attorneys for Petitioner 2290 First National Building 660 Woodward Avenue Detroit, MI 48226-3506 (313) 465-7270 jcook@honigman.com sdamich@honigman.com Laura M. Hallahan (P42101) Seth A. O’Loughlin (P80251) Kelsea M. Melcher (P85821) Hallahan & Associates, P.C. Attorneys for Respondent 1750 S. Telegraph Rd., Suite 202 Bloomfield Hills, MI 48302 (248) 731-3089 lhallahan@hallahanlaw.com soloughlin@hallahanlaw.com kmelcher@hallahanlaw.com Petitioner Napior Leasing, LLC’s Requests for Admission to Respondent City of Adrian Petitioner, Napior Leasing, LLC, by and through its attorneys, Honigman LLP, requests that Respondent City of Adrian respond to these Requests for Admission within 28 days of service in accordance with TTR 201 and MCR 2.312. Definitions 1. “Any” or “all” means “any and all.” 2. “Buyer” refers to Petitioner, Napior Leasing, LLC. 3. “Seller” refers to Fluresh, LLC. 4. “Case” refers to the above-captioned Tax Tribunal matter assigned Docket No. 26- 000636.
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2 76742601.1 5. “Person” includes any individual, corporation, partnership, group, association, union, fraternity, company, sole proprietor, store, establishment, place, firm, co-partnership, joint venture, government, governmental department, governmental agency or any other organization or entity. 6. “Petitioner” refers to Napior Leasing, LLC. 7. “Subject property” refers to the real property and personal property reported under tax parcel no. XA0-109-1150-02, located in Adrian, Michigan. 8. “Respondent,” “City,” “you,” or “your” refers to the City of Adrian, including but not limited to, its assessor, any member of the assessing department, the City’s March Board of Review members, and the City’s March Board of Review. Instructions 1. Unless specified otherwise, each Request for Admission relates to tax year 2026. 2. Under MCR 2.312, the answers to the Request for Admissions are to be signed and verified by you. 3. Your public assessment records for the subject property indicate Grantor Fluresh, LLC, sold the subject property on September 19, 2025, for $3,837,537 to Grantee Napior Leasing, LLC, and reference the warranty deed filed a Liber/Page 2690:0467 with your Register of Deeds. Any references herein to the sale of the subject property and/or purchase of the subject property and/or subject transaction, refer to this sale on September 19, 2025. Requests for Admission 1. Admit that Green Life Business Group, Inc. has an established relationship with cannabis operators worldwide. ANSWER
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3 76742601.1 2. Admit that Green Life Business Group, Inc. is recognized as a premier authority in cannabis mergers and acquisitions. ANSWER 3. Admit that Green Life Business Group, Inc. has closed over 300 cannabis transactions nationwide. ANSWER 4. Admit that Green Life Business Group, Inc. listed the subject property for sale on its national platform on March 28, 2025. ANSWER 5. Admit that Green Life Business Group, Inc. initiated a nationwide email blast campaign targeting cannabis operators and investors. ANSWER 6. Admit that calls for offers for the subject property were due May 16, 2025. ANSWER 7. Admit that at least three offers were made for the purchase of the subject property. ANSWER 8. Admit that Buyer signed the purchase agreement for the subject property on May 31, 2025. ANSWER 9. Admit that Buyer purchased the subject property from Seller for $3,837,537 ANSWER 10. Admit that Buyer purchased the subject property and the personal property located at the subject property from Seller for $6,000,000.
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4 76742601.1 ANSWER 11. Admit that the Buyer purchased the subject property for less than the listing price. ANSWER 12. Admit that the sale of the subject property was not a private sale. ANSWER 13. Admit that the sale of the subject property was not conducted by public auction. ANSWER 14. Admit that the sale of the subject property was not a foreclosure sale. ANSWER 15. Admit that the sale of the subject property was not a sheriff’s sale. ANSWER 16. Admit that the sale of the subject property was not a tax foreclosure sale. ANSWER 17. Admit that sale of the subject property was not a bankruptcy sale. ANSWER 18. Admit that the sale of the subject property was not a liquidation sale. ANSWER 19. Admit that the sale of the subject property was not a forced sale. ANSWER 20. Admit that neither the Buyer nor the Seller was compelled by court order to consummate the sale. ANSWER 21. Admit that the Seller voluntarily offered the subject property for sale.
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5 76742601.1 ANSWER 22. Admit that the Seller voluntarily entered into the purchase agreement. ANSWER 23. Admit that the Buyer and the Seller in the subjection transaction were separate business entities. ANSWER 24. Admit that the Buyer and the Seller were not related entities at the time of the subject transaction. ANSWER 25. Admit that neither the Buyer nor the Seller owned any ownership interest in the other at the time of the subject transaction. ANSWER 26. Admit that the Buyer and the Seller were not under common ownership at the time of the subject transaction. ANSWER 27. Admit that the Buyer and the Seller were not parent, subsidiary, affiliate, or sister companies. ANSWER 28. Admit that no individual or entity held a controlling ownership interest in both the Buyer and the Seller at the time of the subject transaction. ANSWER 29. Admit that no officer, director, manager, member, partner, or shareholder of the Buyer held a controlling ownership interest in the Buyer.
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6 76742601.1 ANSWER 30. Admit that the Buyer and Seller dealt with each other as independent parties acting in their own economic self-interests. ANSWER 31. Admit that the purchase price was not influenced by any familial, ownership, affiliate, or other special relationship between the Buyer and Seller. ANSWER Respectfully submitted, Honigman LLP Dated: August 18, 2026 By: /s/ Jackie J. Cook Jackie J. Cook (P68781) Scott L. Damich (P74126) Attorneys for Petitioner 2290 First National Building 660 Woodward Avenue Detroit, MI 48226-3506 (313) 465-7270 jcook@honigman.com sdamich@honigman.com Proof of Service The undersigned states that she is employed by Honigman LLP and that on August 18, 2026 she served a copy of the foregoing on Respondent’s counsel of record, by way of electronic mail. /s/ Lisa Joseph Dated: August 18, 2026 Lisa Joseph