Response to Petition, Multi-Parcel Petition, Affirmative Defenses & POS â Warren Manor Equities (ID 113854).pdf
Warren Manor Equities LLC, Petitioner Vs. City Of Warren, Respondent · 25-002540-TT
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V. STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL CITY OF WARREN, WARREN MANOR EQUITIES LLC, MTT Docket No. 25-002540 Parcel ID Nos. 12-13-31-301-013, Petitioner, 12-13-31-301-012 Respondent. STEPHEN POLTER POLTER LAW GROUP Representative for Petitioner 2600 W. Big Beaver Rd., Ste. L100 Troy, MI 48084 (248) 213-6800 spolter@polterlaw.com MARY MICHAELS (P44601) CANDICE M. MAYER (P85421) WARREN CITY ATTORNEY'S OFFICE Attorneys for Respondent One City Square, Suite 400 Warren, Michigan 48093 (586) 574-4671 cmayer@cityofwarren.org RESPONSE TO PETITION NOW COMES Respondent, CITY OF WARREN, by and through its attorneys, MARY MICHAELS, Acting City Attorney, and LAURA SULLIVAN, Assistant City Attorney, and for its Response to the Petition states as follows: 1. 2. Paragraph 1 is not contested. Paragraph 2 is not contested.
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7. Paragraph 7 is not applicable, as it does not state anything. 8. Paragraph 8 is not applicable, as it does not state anything. 9. Paragraph 9 is not applicable, as it does not state anything. 10. Paragraph 10 is not contested. 11. Paragraph 11 is not contested. 12. In response to Paragraph 12, Respondent is without knowledge or information sufficient to form a belief as to Paragraph 12, and leaves Petitioner to its proofs. 13. In response to Paragraph 13, Respondent is without knowledge or information sufficient to form a belief as to Paragraph 13, and leaves Petitioner to its proofs. 14. Paragraph 14 is not contested. 15. In response to Paragraph 15 is not applicable, as it does not state anything. 16. Paragraph 16 is not contested, except that the True Cash Values on the Subject Property Tax Records are $13,634,481 and $5,719,274, respectively. 17. Paragraph 17 is not applicable, as it does not state anything except for “2025.” 18. Paragraph 18 is not applicable, as it does not state anything except for “2025.” 19. In response to Paragraph 19, Respondent denies that the Respondent's figures are not accurate and leaves Plaintiff's to its proofs. 20. Paragraph 20 is not applicable, as it does not state anything. WHEREFORE, Respondent, CITY OF WARREN, requests the Tribunal deny the requested relief and dismiss the Petition with prejudice. Respectfully submitted,
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL WARREN MANOR EQUITIES LLC, MTT Docket No. 25-002540 Parcel ID Nos. 12-13-31-301-013, Petitioner, 12-13-31-301-012 V. CITY OF WARREN, Respondent. STEPHEN POLTER POLTER LAW GROUP Representative for Petitioner 2600 W. Big Beaver Rd., Ste. L100 Troy, MI 48084 (248) 213-6800 spolter@polterlaw.com MARY MICHAELS (P44601) CANDICE M. MAYER (P85421) WARREN CITY ATTORNEY'S OFFICE Attorneys for Respondent One City Square, Suite 400 Warren, Michigan 48093 (586) 574-4671 cmayer@cityofwarren.org RESPONSE TO MULTIPLE PARCEL PETITION NOW COMES Respondent, CITY OF WARREN, by and through its attorneys, MARY MICHAELS, Acting City Attorney, and LAURA SULLIVAN, Assistant City Attorney, and for its Response to the Multiple Parcel Petition states as follows: 1. Paragraph 1 is not contested. 2. Paragraph 2 is not contested, except that the True Cash Values on the Subject
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4, In response to Paragraph 4 Respondent is without knowledge or information sufficient to form a belief as to the remainder of Paragraph 4, and leaves Petitioner to its proofs. WHEREFORE, Respondent, CITY OF WARREN, requests the Tribunal deny the requested relief and dismiss the Petition with prejudice. Respectfully submitted, [s/Laura Sullivan LAURA SULLIVAN (P42021) Assistant City Attorney Ill One City Square, Suite 400 Warren, Michigan 48093 (586) 574-4671 Dated: July 18, 2025 Isullivan@cityofwarren.org ID 113726
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL WARREN MANOR EQUITIES LLC, MTT Docket No. 25-002540 Parcel ID Nos. 12-13-31-301-013, Petitioner, 12-13-31-301-012 V. CITY OF WARREN, Respondent. STEPHEN POLTER POLTER LAW GROUP Representative for Petitioner 2600 W. Big Beaver Rd., Ste. L100 Troy, MI 48084 (248) 213-6800 spolter@polterlaw.com MARY MICHAELS (P44601) CANDICE M. MAYER (P85421) WARREN CITY ATTORNEY'S OFFICE Attorneys for Respondent One City Square, Suite 400 Warren, Michigan 48093 (586) 574-4671 cmayer@cityofwarren.org AFFIRMATIVE DEFENSES NOW COMES Respondent, CITY OF WARREN, by and through its attorneys, MARY MICHAELS, Acting City Attorney, and LAURA SULLIVAN, Assistant City Attorney, and for its Affirmative Defenses states as follows: 1. Petitioner failed to allege specific and sufficient facts to set forth a cause of action.
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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, /s/Laura Sullivan LAURA SULLIVAN (P42021) Assistant City Attorney Il One City Square, Suite 400 Warren, Michigan 48093 (586) 574-4671 Isullivan@cityofwarren.org
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL WARREN MANOR EQUITIES LLC, MTT Docket No. 25-002540 Parcel ID Nos. 12-13-31-301-013, Petitioner, 12-13-31-301-012 V. CITY OF WARREN, Respondent. STEPHEN POLTER POLTER LAW GROUP Representative for Petitioner 2600 W. Big Beaver Rd., Ste. L100 Troy, MI 48084 (248) 213-6800 spolter@polterlaw.com MARY MICHAELS (P44601) CANDICE M. MAYER (P85421) WARREN CITY ATTORNEY'S OFFICE Attorneys for Respondent One City Square, Suite 400 Warren, Michigan 48093 (586) 574-4671 cmayer@cityofwarren.org PROOF OF SERVICE STATE OF MICHIGAN ) ) ss. COUNTY OF MACOMB ) On the date below, | sent via email a copy of Respondent, City of Warren's Response to Petition, Response to Multiple Parcel Petition, Affirmative Defenses and Proof of Service to Representative for Petitioner Stephen Polter at spolter@polterlaw.com. | declare that the statements above are true to the best of my information, knowledge, and belief.