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26-000752.pdf

Trinity Place Investments LLC Petitioner Vs. Township Of Flint Respondent · 26-000752-TT

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Page 1

RECEIVED 

JUL 07 ozs 

CLUSTER TOWN SHIP OF FLINT 

MICHIGAN Tax 

ssessment Division 

IBUNAL 

William Fowler, 

14905, Dye Road 

ho pert 

MMAO, PPE 

Flint, Michigan 48532 

assessingdept@flinttownship.org 

Assessor 

July 1, 2026 

Office of the Chief Clerk 

Michigan Tax Tribunal 

P.O. Box 30232 

Lansing, MI 48909 

RE: 

MTT Docket No.: 26-000752 

Trinity Place Investments LLC v Township of Flint 

Parcels: 07-25-300-054, 07-25-553-001, 07-25-300-002, 07-25-300-003, 07-25- 

553-004, and 07-25-553-005 

Dear Honorable Michigan Tax Tribunal: 

Enclosed for filing, please find Respondent’s Reply to Petitioner’s Petition (in the Entire 

Tribunal) and Respondent’s Proof of Service. 

Respectfully submitted, 

NYA 

=a 

Paula Dotson 

Deputy Assessor 

Charter Township of Flint

Page 2

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Trinity Place Investments LLC 

Petitioner 

v 

Flint Township, Genesee County 

Respondent 

MTT Docket No.: 26-000752 

Parcels: 

07-25-300-054 

07-25-553-001 th 07-25-553-005 

Brian Etzel 

Williams, Williams, Rattner & Plunkett 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI 48009 

Paula Dotson 

Deputy Assessor, Charter Township of Flint 

1490 S. Dye Road 

Flint, MI 48532 

248.642.0333 

810.600.3227 

RESPONDENT’S REPLY TO PETITIONER’S APPEAL TO CONTEST THE 2026 

ASSESSED AND TAXBLE VALUATION (IN ENTIRE TRIBUNAL) 

Respondent, the Charter Township of Flint, through its Assessor, William Fowler, and its Deputy 

Assessor, Paula Dotson, hereby submits its response to Petitioner’s Petition as follows: 

1. 

Respondent neither admits nor denies the statements and or allegations 

set forth 

in 

paragraph 

1 of Petitioner’s Petition as it does not have sufficient information to form a 

belief as to the truth of the allegations. 

Respondent admits the statements and or allegations set forth in paragraph 2 of Petitioner’s 

Petition. 

Respondent admits the statements and or allegations set forth in paragraph 3 of Petitioner’s 

Petition.

Page 3

10. 

11. 

12. 

MTT Docket No. 26-000752 

Respondent admits the statements and or allegations set forth in paragraph 6 of Petitioner’s 

Petition. 

Respondent admits the statements and or allegations set forth in paragraph 7 of Petitioner’s 

Petition. 

Respondent neither admits nor denies the statements and or allegations set forth in paragraph 

8 of Petitioner’s Petition as said paragraph is merely the opportunity for Petitioner to set 

forth its opinion of value. 

Respondent neither admits nor denies the statements and or allegations set forth in paragraph 

9 of Petitioner’s Petition said paragraph is merely the mathematical calculation of the 

difference between Respondent’s valuations and Petitioner’s contention of value. 

Respondent neither admits nor denies the statements and or allegations set forth in paragraph 

10 of Petitioner’s as said paragraph does not have sufficient information to form a belief as 

to the truth of the allegations. 

Respondent denies the statements or allegations set forth in paragraph 11 of Petitioner’s 

Petition for the reason they are not true. 

Respondent acknowledges the statements or allegations set forth in paragraph 12 of 

Petitioner’s Petition. 

Wherefore Respondent requests the relief and actions requested by Petitioner be denied. 

Respondent leaves Petitioner to meeting its required burden of proof. 

Respondent’s Response submitted on this date, 

July 1, 2026, by: 

Paula Dotson 

Deputy Assessor 

Charter Township of Flint

Page 4

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

Trinity Place Investments LLC 

Petitioner 

v 

Flint Township, Genesee County 

Respondent 

MTT DOCKET NO.: 26-000752 

PROOF OF SERVICE 

STATE OF MICHIGAN 

) 

GENESEE COUNTY) 

THE UNDERSIGNED, Paula Dotson, being first duly sworn, deposes and says that on 

July 1, 2026, she caused to be served upon: 

Brian Etzel 

Michigan Tax Tribunal 

Williams, Williams, Rattner & Plunkett 

PO Box 30232 

380 N. Old Woodward Ave., Ste. 300 

Lansing, Michigan 48909 

Birmingham, MI 48009 

by enclosing the same in an envelope, plainly addressed to said party at the above address, with 

lawful United States first class postage affixed thereon and by placing same in the United States 

mail. 

July 

1, 2026 

Date 

Paula Dotson 

Deputy Assessor

Page 5

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