25-002128 Answer.pdf

Brays Investments LLC, Petitioner Vs. City Of Warren, Respondent · 25-002128-TT

← View full record

Text extracted from the reviewed PDF, organized by page. OCR and reading order may contain errors; confirm details in the PDF below.

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

BRAYS INVESTMENTS LLC 

MOAHR Docket No. 25-002128 

Petitioner, 

Parcel ID No. 12-13-35-326-015 

V. 

CITY OF WARREN, 

Respondent. 

BARRY STEINWAY 

Representative for Petitioner 

21001 Groesbeck Highway 

Warren, Michigan 48089 

(248) 563-2544 

basteinway@gmail.com 

MARY MICHAELS (P44601) 

JENNIFER PIERCE (P57078) 

CITY OF WARREN 

Attorneys for Respondent 

One City Square, Suite 400 

Warren, MI 48093 

(586) 574-4671 

Jpierce@cityofwarren.org 

/ 

RESPONSE TO PETITION 

Respondent, 

City 

of Warren, 

by 

its attorney, MARY MICHAELS, 

City Attorney and 

JENNIFER PIERCE, Assistant City Attorney, in response to the Petition states as follows: 

1. 

2. 

necessary. 

Respondent admits the allegations contained in paragraph 1. 

No allegations 

are 

set forth 

in paragraph 

two and therefore 

no response 

is

7. 

Respondent 

admits 

the 

allegations 

contained 

in 

paragraph 

7 

for assessing 

purposes. 

8. 

No allegations are set forth in paragraph 8 and therefore no response is necessary. 

9. 

No allegations are set forth in paragraph 9 and therefore no response is necessary. 

10. 

No 

allegations 

are 

set 

forth 

in paragraph 

10 

and 

therefore 

no response 

is 

necessary. 

11. 

Respondent admits the allegations in paragraph 11. 

12. 

Respondent admits the allegations contained in paragraph 12. 

13. 

In response 

to Paragraph 

13, 

Respondent 

is without knowledge 

or information 

sufficient to form a belief as to the truth of the allegations and therefore leaves Petitioner to its 

proofs. 

14. 

In response to Paragraph 

14, Respondent 

is without knowledge or information 

sufficient to form a belief as to the truth of the allegation and therefore leaves Petitioner to its 

proofs. 

15. 

Respondent admits the allegations contained in paragraph 15. 

16. 

Respondent admits that the Assessed value and Taxable values are $63,260, 

however further states that the true cash value is $126,516. 

17. 

In response to Paragraph 

17, Respondent 

is without knowledge or information 

sufficient to form a belief as to the truth of the allegation and therefore leaves Petitioner to its 

proofs. 

18. 

In response 

to Paragraph 

18, 

Respondent 

is without knowledge 

or information 

sufficient to form a belief as to the truth of the allegation and therefore leaves Petitioner to its

THEREFORE, Respondent City of Warren requests this Tribunal deny the requested 

relief, dismiss the Petition with prejudice, and award Respondent costs it incurred in the defense 

of this appeal. 

Respectfully submitted, 

By: 

[s/Jennifer Pierce 

JENNIFER PIERCE (P57078) 

Assistant City Attorney 

Attorneys for Respondent 

Dated: September 4, 2025 

JP/s Response to Petition, Affirmative Defenses and POS Brays Investments — ID 114340

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN OFFICE OF ADMINISTRATIVE HEARINGS AND RULES 

MICHIGAN TAX TRIBUNAL 

BRAYS INVESTMENTS LLC 

MOAHR Docket No. 25-002128 

Petitioner, 

Parcel ID No. 12-13-35-326-015 

V. 

CITY OF WARREN, 

Respondent. 

BARRY STEINWAY 

Representative for Petitioner 

21001 Groesbeck Highway 

Warren, Michigan 48089 

(248) 563-2544 

basteinway@gmail.com 

MARY MICHAELS (P44601) 

JENNIFER PIERCE (P57078) 

CITY OF WARREN 

Attorneys for Respondent 

One City Square, Suite 400 

Warren, MI 48093 

(586) 574-4671 

Jpierce@cityofwarren.org 

/ 

AFFIRMATIVE DEFENSES 

Respondent, 

City 

of Warren, 

by 

its attorney, MARY MICHAELS, 

City Attorney and 

JENNIFER PIERCE, Assistant City Attorney, 

in response to the Petition, submit the following 

Affirmative Defenses: 

1. 

Petitioner 

is 

not the 

listed owner on the tax 

roll. 

The 

listed owner 

is Jeniya 

Investments, LLC as of May 7, 2025.

Tribunal. 

4. 

Petitioner failed to allege specific and sufficient facts to establish fraud, error of 

law, discrimination, application of wrong principles, or illegality on the part of Respondent or its 

agents. 

5. 

Petitioner failed 

to allege that the mode and method of assessing the subject 

property fails to conform to the mode and method applied 

in the case of all other properties in 

Respondent's taxing unit for the year in question. 

6. 

Petitioner failed to show that any factor other than fifty percent (50%) was applied 

to the true cash value of Petitioner's property, as well as all others, to arrive at the respective 

assessments appearing on the roll, and also failed to allege specific and sufficient facts to support 

its allegations that the property's taxable value is improper. 

7. 

Petitioner failed to submit any evidence warranting relief from the assessments to 

the Board of Review. 

8. 

Petitioner, 

in essence, seeks by petition to challenge the process of county and 

state equalization as to which 

it has no legal standing and cannot maintain a cause of action. 

9. 

Respondent reserves the right to raise additional defenses as may become known 

to 

it during the course of these proceedings. 

Respectfully submitted, 

By: 

[s/Jennifer Pierce 

JENNIFER PIERCE (P57078) 

Assistant City Attorney 

Attorneys for Respondent 

Dated: September 4, 2025

← View full record