City of Taylor, TIFA lawsuit against Wayne County

8/12/2019 City of Taylor, TIFA lawsuit against Wayne County

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STATE OF MICHIGAN

IN THE CIRCUIT COURT FOR THE COUNTY OF WAYNE

TAX INCREMENT FINANCE AUTHORITYOF THE CITY OF TAYLOR,a public body corporate, and

THE CITY OF TAYLOR,a Michigan public body corporate

Plaintiffs, Case No. -CZHon.

v.

THE COUNTY OF WAYNE,a Michigan public body corporate

Defendant._____________________________________________________________________________/Gustaf R. Andreasen (P40956) David F. Greco (P53523)Michael F. Wais (P45482) Gasiorek Morgan Greco & McCauley PCHoward & Howard Attorneys PLLC Attorney for Plaintiff:Attorneys for Plaintiff: THE CITY OF TAYLORTAX INCREMENT FINANCE AUTHORITY 30500 Northwestern Hwy. Ste. 425OF THE CITY OF TAYLOR Farmington Hills, MI 48334450 West Fourth Street (248) 865-0001Royal Oak, Michigan 48067(248) 645-1483_____________________________________________________________________________/

There is no other civil action arising out of the same transaction oroccurrence as alleged in this Complaint pending in this court nor has any suchaction previously been filed and dismissed after having been assigned to a judge.

COMPLAINT

NOW COMES Plaintiffs, the TAX INCREMENT FINANCE AUTHORITY OF THE

CITY OF TAYLOR, and the CITY OF TAYLOR, all through their undersigned counsel, and for

their Complaint against Defendant, the COUNTY OF WAYNE, state as follows:

FILED IN MY OFFIC

WAYNE COUNTY CLE

6/3/2014 3:54:57

CATHY M. GARRE

14-007181-CZ

DB


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GENERAL OVERVIEW

In simple terms, The County of Wayne (the County) entered into an agreementwith

the City of Taylor (the City) which, to date, took over Forty-One Million Dollars

($41,000,000) of funds belonging to the Tax Increment Finance Authority of the City of Taylor

(the Authority)and gave those funds to the County. The agreement through which the County

obtained the money is known as the Northline Road Agreement entered into between the City

and the County on July 21, 1988 (the Northline Road Agreement or the Agreement).

Despite the fact that the Authoritys money was being taken under the Northline Road

Agreement, the Authority was not a party to the Agreement and did not agree to the terms of the

Northline Road Agreement. Further, the Northline Agreement is not an effective Interlocal

Agreement under Michigans Urban Cooperation Act. Frankly, there is no legal or other basis to

permit the County or the City to take the Authoritysmoney.

The fact that the City signed the Northline Road Agreement does not provide the County

with a basis to keep the Authoritys money as Michigan law does not allow the City to enter into

agreements on behalf of the Authority. To the contrary, Michigan law provides that the

Authority is a separate and distinct public body that makes and enters into its own contracts on

its own behalf and in its own name. See e.g. MCL 125.1802 and 125.1807 and the Bylaws of

the Authority, Article IV, Section 1.

Moreover, the Countys taking of the Authoritys money which comes from an attempt

in the Northline Road Agreement to exclude the Countys millage from capture by the Authority

- is likewise not permissible because Michigan law does not allow the County to opt out of

capture by the Authority. See e.g. MCL 125.1801 et seq. The Countys taking of the money is

also contrary to Michigan law because the Authority is legally required under Michigan law to


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expend its revenues only in accordance with its tax increment financing plan, which does not

authorize the County to take the Authoritys money. See e.g. MCL 125.1814. To the contrary,

the Authoritys funds must be used within its tax financing district (located within the City of

Taylor). See e.g. MCL 125.1814. However, with the Countys misappropriation of the

Authoritys funds, the over $41,000,000 that was legally required to be spent within the tax

financing district has been and continues to be spent by the County throughout Wayne County,

thereby taking funds belonging to the City of Taylor residents and using those funds throughout

the County instead of inside the City of Taylor as legally required.

Furthermore, Interlocal Agreements between public agencies (such as the Authority and

County) for sharing revenue derived from the levy of general ad valorem property taxes are

not effective unless these agreements meet the requirements set forth in the Michigan Urban

Cooperation Act (the UCA). See MCL 124.505a. The Northline Agreement does not meet

these requirements.

For instance, the UCA provides that a valid Interlocal Agreement must include a

provision stating that the agreement may be terminated or rescinded by a referendum of the

residents of a local governmental unit that is a party to the agreement not more than 45 days

after the approval of the agreement by the governing body of the local governmental unit. See

MCL 124.505a. The Northline Agreement does not contain such a provision. (See Exhibit A).

Next, the UCA provides that the legislative body of each local governmental unit

shall hold at least 1 public hearing before entering into an agreement under this section . See

MCL 125.505a. Upon information and belief, the parties never held a public hearing before

entering into the Northline Agreement.


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The UCA provides that [p]rior to its effectiveness, an interlocal agreement shall be filed

with the county clerk of each county where a party to the agreement is located and with the

secretary of state. See MCL 124.510. The Northline Agreement was never filed with the

Wayne County Clerk, nor with the Secretary of State of Michigan.

Finally,

[i]f funds of this state are to be allocated to carry out an interlocal agreement,prior to and as a condition precedent to its effectiveness, shall be submitted to thegovernor who shall determine whether the agreement is in proper form andcompatible with the laws of this state.

See MCL 124.510. To the extent that any State Funds were used in the Northline Road

construction, the Northline Agreement would also be ineffective under the UCA as, upon

information and belief, the Governor of the State of Michigan did not approve the Northline

Road Agreement.

Obviously, agreements such as the Northline Road Agreement that purport to take

someones money without their permission are not enforceable. Likewise, contracts such as the

Northline Road Agreement that are founded upon acts that are prohibited by statute or public

policy are void. Accordingly, for these and other reasons set forth in this Complaint, Plaintiffs

request that this Court declare the Northline Road Agreement void and/or not enforceable.

Even if the Northline Road Agreement had, at one time, been legally enforceable and it

was notthe County has nevertheless been unjustly enriched by taking over $41,000,000 from

the Authority.

In this regard, the Authority never had a contract with the County and never received

anything of benefit for the taking of more than $41,000,000 of its funds. Thus, at the very least,

the County must return the Authoritys money under an unjust enrichment claim.


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Furthermore, although irrelevant to the Plaintiffsunjust enrichment claims, the County

was also unjustly enriched as compared to the City. The County took the Authoritys money

under the Northline Road Agreement to repay the County for the money the County spent to

widen two miles of Northline Road between Allen Road and Telegraph Road. However, the

County has long ago been repaid this money it spent to widen Northline Road indeed, the over

$41,000,000 taken from the Authority has repaid the County approximately 6 times more than it

spent to widen the road.

Finally, upon information and belief, the County did not take any funds from any other

municipality to widen Northline Road, despite the fact that the road was widened with County

funds in other municipalities at or about the same time as it was widened in the City of Taylor.

By treating the City of Taylor detrimentally differently than other similarly situated

municipalities likewise resulted in an unjust enrichment to the County.

Despite the foregoing, the County has refused to terminate the Northline Road

Agreement and, incredibly, seeks to continue to collect the Authoritys funds through 2030

(which is the current date under which the Authority will continue to operate)! If allowed to

continue, the County could take at least another $30,000,000 from the Authority, further unjustly

enriching the County and further harming the City, the Authority, and the residents of the City of

Taylor whose TIF funds will continue to be spent throughout the County instead of where they

are legally required to be spentinside of the tax financing district for the City of Taylor.

PARTIES, JURISDICTION, AND VENUE

1. The Authority was incorporated by the City on or about April 12, 1983 and is apublic body corporate which may sue and be sued in any court of this state.


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2. The City is a Municipal Corporation created by the vote of the electors on the8th day of November, A.D., 1966, to be known as the "City of Taylor" [and] shall be a body

corporate and politic and shall have perpetual succession.

3. The County is abody corporate [that] possesses home rule power enabling it toprovide for any matter of County concern and all powers conferred by constitution or law upon

charter counties or upon general law counties, their officers, or agencies.

4. This Court has jurisdiction pursuant to MCR 2.605(A)(2) because there is anactual controversy within this Courts jurisdiction necessitating a declaration of legal rights

between the parties.

5. Further, the Court has jurisdiction pursuant toMCL 600.605because the amountin controversy exceeds twenty-five thousand dollars ($25,000.00), exclusive of interest and

costs.

6. Venue is proper with this Honorable Court pursuant to MCL 600.1615 becausethe parties hereto exercise and may exercise governmental authority in the County of Wayne

and/or the principal office of each party lies within the Count of Wayne.

BACKGROUND

7. On or about April 12, 1983, and pursuant to Michigans Tax Increment FinanceAct (the Act), the City of Taylor (the City) incorporated the Tax Increment Finance

Authority1of the City of Taylor (the Authority).

8. The City established the Authority to perform economic development activitieswithin the City such as rehabilitation, restoration, or reconstruction of public facilities, existing

buildings, and multi-family homes (Economic Development). To fulfill its objectives, the

1 There were originally 6 contiguous TIFA Development Areas; however, these were consolidated into a singleTIFA Development Area in 2000.
http://www.icle.org/Modules/Repositories/MCR/rule.aspx?lib=repositories&book=mcr&chap=02&rule=2.605http://www.legislature.mi.gov/mileg.aspx?page=getobject&objectname=mcl-600-605http://www.legislature.mi.gov/mileg.aspx?page=getobject&objectname=mcl-600-605http://www.icle.org/Modules/Repositories/MCR/rule.aspx?lib=repositories&book=mcr&chap=02&rule=2.605http://www.legislature.mi.gov/mileg.aspx?page=getobject&objectname=mcl-600-605http://www.icle.org/Modules/Repositories/MCR/rule.aspx?lib=repositories&book=mcr&chap=02&rule=2.605http://www.legislature.mi.gov/mileg.aspx?page=getobject&objectname=mcl-600-605http://www.icle.org/Modules/Repositories/MCR/rule.aspx?lib=repositories&book=mcr&chap=02&rule=2.605http://www.legislature.mi.gov/mileg.aspx?page=getobject&objectname=mcl-600-605http://www.icle.org/Modules/Repositories/MCR/rule.aspx?lib=repositories&book=mcr&chap=02&rule=2.605


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Authority created a Development Plan and a Financing Plan (collectively the Plans) (See

Exhibit C). The Plans describe Development Areas (Development Areas). The Authority uses

tax increment financing (TIF) to finance Economic Development within the Development

Areas. TIF permits the Authority to capture tax revenues attributable to increases in the value of

real and personal property located within the Development Areas. For instance, assume a

property in the Development Area initially pays taxes of $10,000. The Authority subsequently

rehabilitates and restores the surrounding area. Property values increase. As a result of

increased property values, the property now pays $12,000 in taxes. Under TIF, the Authority is

entitled to the additional $2,000. The Authority uses the TIF revenue for continued Economic

Development.

9. The Act mandates that taxing jurisdictions which overlap the Development Areas,such as the County of Wayne (the County), remit TIF revenues to the Authority. (See Exhibit

B). Taxing jurisdictions are not permitted to exclude their millage from capture by the

Authority. (See Exhibit B).

10. The County has recognized that the concept of tax increment financingauthorized by [the Act], is a valuable tool used by the City to provide public infrastructure

(See Exhibit A).

11. Nonetheless, the County determined, in direct contravention of the statute and ofpublic policy, that the concept of tax increment financing should be modified. (See Exhibit

A).

12. On July 21, 1988, based upon the Countys assertion that it is allowed to modifyMichigan law to better suit its own interests, the City and the County entered into an agreement

(the Northline Road Agreement) whereby the City agreed to exclude the Countys charter


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millage of 6.07, its extra voted millage of 1.00 mils and any additional voted millage from any

present or any subsequently created tax increment financing district under P.A. 450 of 1980 or

P.A. 281 of 1986 in exchange for the County temporarily assuming jurisdiction of that portion

of Northline Road between Allen Road and Inkster Road within the City and funding the

widening of Northline Road between Allen Road and Telegraph Roada span of approximately

two miles. (See Exhibit A).

13. The Northline Road Agreement does not contain a provision stating that theagreement may be terminated or rescinded by a referendum of the residents of a local

governmental unit that is a party to the agreement not more than 45 days after the approval of the

agreement by the governingbody of the local governmental unit. See MCL 124.505a.

14. Upon information and belief, a public hearing was not held before the County andCity entered into the Northline Agreement. See MCL 124.505a.

15. The Northline Agreement was not filed with the county clerk of [Wayne County]and with the secretary of state. See MCL 124.510.

16. Upon information and belief, the Northline Agreement was never submitted tothe governor [to] determine whether the agreement is in proper form and compatible with the

laws of this state. See MCL 124.510.

17. The funds to be excluded and taken by the County pursuant to the NorthlineRoad Agreement are TIF funds.

18. TIF funds are required to be given to the Authority and used only to fund projectswithin the Development Areas.

19. The Authority is a separate legal entity from the City.


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20. The Authority is legally required to enter into its own contracts on its own behalfand in its own name.

21. The Authority did not sign or enter into the Agreement.22. Upon information and belief, the Authority was not asked to sign or enter into the

Agreement.

23. Upon information and belief, the Authority did not authorize the City to enter intothe Agreement on behalf of the Authority.

24. The Authority did not agree to allow its funds to be given to the County.25.

But for the Agreement, the City would have paid the funds that have been taken

by the County to the Authority.

26. The Countys taking of the tax revenues under the Northline Road Agreement isequivalent to the County opting out of tax increment financing districts.

27. Michigan law does not permit the County to opt out of the tax incrementfinancing districts.

28. The Authority is legally required to expend its revenues only in accordance withthe tax increment financing plan.

29. The Plan requires the Authoritys revenues to be expended within theDevelopment Areas.

30. The Authoritys tax increment financing plan does not authorize the County to useTIF funds - and certainly does not authorize the County to use TIF funds outside of the

Development Areas.


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31. The Countys taking of the funds under the Northline Road Agreement resulted inthe County taking money from the City of Taylor and the Authority to use throughout the County

as opposed to being used solely within the Development Areas for economic development.

32. The County used TIF funds outside of the TIF districts.33. Upon information and belief, the Northline Road construction began in

approximately 1989 and was completed in approximately 1990.

34. Upon information and belief, the County expended approximately $7,000,000 towiden Northline Road in the City of Taylor.

35.

As a result of the Northline Road Agreement, the County has already excluded

$41,379,722.97 of its millage from capture by the Authority. (See Exhibit D).

36. If allowed to continue to capture funds under the Northline Agreement, theCounty could receive another $30,000,000 or more between the date hereof and 2030 when the

Authority is presently set to terminate.

37. The Authority did not receive a benefit from the County in exchange for theCountys taking of the TIF funds.

38. The County has more than been repaid under the Northline Road Agreement forthe funds it expended to widen Northline Road within the City of Taylor.

39. At or about the same time that the County widened Northline Road within theCity of Taylor, County funds were also used to widen Northline Road in Romulus and

Southgate.

40. Upon information and belief, the County did not collect funds from Romulus orSouthgate (or any other municipality or public entity) to pay for the widening of Northline Road

in Romulus and Southgate.


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41. As a result, upon information and belief, the County treated the residents of theCity of Taylor detrimentally different than the residents of the Cities of Romulus and Southgate

as the County only took funds from the City of Taylor and/or the Authority and not from these

other municipalities for the same project.

42. To compound the foregoing detrimentally different treatment, the County tookTIF funds that were to be used in the Development Areas and used the funds throughout the

County.

43. Despite the fact that it has been repaid for the widening of Northline Road manytimes over, and to add further insult to the injuries suffered by the Authority, the City, and the

residents of the City of Taylor, the County also required the City to, once again assume

the responsibility for the maintenance of Northline Road as herein described atits sole cost and expense, including by way of illustration, but not of limitation,grass maintenance, landscaping, gardening, sprinkler system maintenance,lighting, and any other special median facilities construction and/or installedtherein: and the County shall be relieved of all responsibility therefor.

(See Exhibit A). Should major reconstruction of the medianor curb be required at any time

after the completion of the [Northline Road widening], the costs thereof shall be the sole

responsibility of the City. (See Exhibit A).

44. Since the completion of construction on Northline Road in approximately 1990,the County has continued to unlawfully exclude its millage from capture by the Authority. (See

Exhibit D).

45. To date the County has unlawfully excluded more than $41,000,000 from captureby the Authority. (See Exhibit D).


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46. Furthermore, under the illicit terms of the Northline Road Agreement, the Countyexpects to continue to exclude its millage from capture by the Authority and LDFA until the

[Development Areas are] dissolved. (See Exhibit A).

47. All told, the County, pursuant to an illegal contract, traded a one time constructioncost of approximately $7,000,000 for a perpetual benefit already in excess of $41,000,000 and

counting.

COUNT I

DECLARATORY RELIEF IN FAVOR OF THE CITY OF TAYLOR

48.

Plaintiffs incorporates all prior allegations as if set forth herein in full.

49. The City of Taylor has repeatedly requested that the County terminate theNorthline Road Agreement as, inter alia, the contract is void, against public policy, and is

otherwise invalid for all of the reasons set forth above.

50. The County continues to refuse to terminate the Northline Road Agreement,continues to insist upon receiving the TIF funds that belong to the Authority and apparently

claims that the Northline Road Agreement is valid and enforceable.

51. The Northline Road Agreement is void, against public policy and otherwiseinvalid and unenforceable for the following reasons:

a. It takes money that belongs to the Authority without the Authoritys permission.b. It takes money that belongs to the Authority that it is prohibited from taking underMichigan law because the Act prohibits the County from exclude[ing] the Countys

Charter millage of 6.07, its extra voted millage of 1.00 mils and any additional voted

millage from any present or any subsequently created tax increment financing districts.


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c. The County cannot contractually agree to a course of action that is not permittedby statute.

d. The City did not, and does not, have the authority to contractually bind theAuthority.

e. Under the UCA, the Northline Agreement is not an effective InterlocalAgreement.

f. Michigan law does not allow the County to opt out of the capture of TIF fundsby the Authority. See e.g. MCL 125.1801 et. seq.

g.

The Countys taking of the Authoritys money is also contrary to Michigan law as

the Authority is legally required under Michigan law to expend its revenues only in

accordance with its Plan, which does not authorize the County to take the Authoritys

money. See e.g. MCL 125.1814. To the contrary, the Authoritysfunds must be used

within the Development Areas (located within the City of Taylor). See e.g. MCL

125.1814.

h. The Countys misappropriation of the Authoritys funds that were legallyrequired to be spent within the Development Areas have been and continue to be spent by

the County throughout Wayne County, thereby taking funds belonging to the City of

Taylor residents and using those funds throughout the County instead of inside the City

of Taylor as legally required.

i. The County is not permitted to treat the City of Taylor, its residents, or theAuthority detrimentally different than the other municipalities and residents of the

County, but by taking the TIF funds without taking funds from any other municipality

where Northline Road was widened with the usage of County funds, the County is


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treating the City of Taylor, its residents, and the Authority inequitably as compared to

other similarly situated municipalities and residents.

52. There is an actual controversy over whether or not the Northline Road Agreementis valid and, as such, the City of Taylor requests that this Court declare the rights and other legal

relations of the parties with respect to the Northline Road Agreement.

WHEREFORE, the City of Taylor requests a declaratory judgment providing the

following judicial declarations:

a. The Northline Road Agreement is illegal, void, and/or otherwise unenforceable.b.

The City is not bound by the Northline Road Agreement.

c. The TIF Funds that had been taken by the County, or which would otherwise betaken by the County, under the Northline Agreement are to be given to the Authority.

d. No further TIF Funds or other funds are to be taken by the County under theNorthline Road Agreement.

e. Enjoin the County from demanding, pursuing or receiving any further funds underthe Northline Road Agreement.

f. The County may not exclude its charter millage of 6.07, its extra voted millage of1.00 mils and any additional voted millage from any present or any subsequently created

tax increment financing districts.

g. Grant all other appropriate and equitable relief that the Court deems proper.COUNT II

DECLARATORY RELIEF IN FAVOR OF THE AUTHORITY

53. Plaintiffs incorporates all prior allegations as if set forth herein in full.


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54. The Authority has requested that the County terminate the Northline RoadAgreement as, inter alia, the contract is void, against public policy, and is otherwise invalid for

all of the reasons set forth above.

55. The County continues to refuse to terminate the Northline Road Agreement,continues to insist upon receiving the TIF funds that belong to the Authority, and apparently

claims that the Northline Road Agreement is valid and enforceable.

56. The Northline Road Agreement is void, against public policy and otherwiseinvalid and unenforceable for each of the following reasons:

a.

It takes the Authoritys money without the Authoritys permission.

b. It takes money that belongs to the Authority that it is prohibited from taking underMichigan law because the Act does not permit the County to exclude the Countys

Charter millage of 6.07, its extra voted millage of 1.00 mils and any additional voted

millage from [the Authority nor] any present or any subsequently created tax increment

financing districts within the Citys boundaries.

c. The County cannot contractually agree to a course of action that is not permittedby statute.

d. The City did not, and does not, have the authority to contractually bind theAuthority.

e. Under the UCA, the Northline Agreement is not an effective InterlocalAgreement.

f. Michigan law does not allow the County to opt out of the capture of tax revenueby the Authority. See e.g. MCL 125.1801 et. seq.


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g. The Countys taking of the Authoritys money is also contrary to Michigan lawbecause the Authority is legally required under Michigan law to expend its revenues only

in accordance with the tax increment financing plan which does not authorize the money

to be taken by the County. See e.g. MCL 125.1814. To the contrary, the Authoritys

funds must be used within the Development Areas (located within the City of Taylor).

See e.g. MCL 125.1814.

h. The Countys misappropriation ofthe Authoritys funds that were legally requiredto be spent within the Development Areas has been and is continuing to be spent by the

County throughout Wayne County, thereby taking funds belonging to the City of Taylor

residents and using those funds throughout the County instead of inside the City of

Taylor as legally required.

i. The County is not permitted to treat the City of Taylor, its residents or theAuthority detrimentally different than the other municipalities and residents of the

County, but by taking the TIF funds without taking funds from any other municipality

where Northline Road was widened with the usage of County funds, the County is

treating the City of Taylor, its residents and the Authority inequitably as compared to

other similarly situated municipalities and residents.

57. There is an actual controversy over whether or not the Northline Road Agreementis valid and, as such, the Authority requests that this Court declare the rights and other legal

relations of the parties with respect to the Northline Road Agreement.

WHEREFORE, the Authority requests a declaratory judgment providing the following

judicial declarations:

a. The Northline Road Agreement is illegal, void, and/or otherwise unenforceable.


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b. The Authority is not bound by the Northline Road Agreement.c. The TIF Funds that had been taken by the County, or which would otherwise betaken by the County, under the Northline Agreement are to be given to the Authority.

d. No further TIF Funds or other funds are to be taken by the County under theNorthline Road Agreement.

e. Enjoin the County from demanding, pursuing or receiving any further funds underthe Northline Road Agreement.

f. The County may not exclude its charter millage of 6.07, its extra voted millage of1.00 mils and any additional voted millage from any present or any subsequently created

tax increment financing districts.

g. Grant all other appropriate and equitable relief that the Court deems proper.COUNT III

UNJUST ENRICHMENT IN FAVOR OF THE AUTHORITY

58. Plaintiffs incorporates all prior allegations as if set forth herein in full.59. The Authority did not receive a benefit from the Countys taking of its funds.60. The County unjustly received a benefit of $41,379,722.97 to the detriment of the

Authority.

61. The County would continue to be unjustly enriched if it continued to receiveadditional funds pursuant to the Northline Road Agreement.

62. It would be inequitable for the County to retain these benefits.WHEREFORE, the Authority respectfully requests that this Court order the

County to pay the Authority all funds the County received under the Northline Road Agreement

(plus statutory interest), order that no further funds are to be paid to the County under the


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Northline Road Agreement and granting the Authority such further and other relief as it may

request and this Court may deem appropriate.

COUNT IV

UNJUST ENRICHMENT IN FAVOR OF THE CITY

63. Plaintiffs incorporates all prior allegations as if set forth herein in full.64. The City did not receive an equivalent benefit from the Countys taking of the

Authoritysfunds.

65. The County unjustly received a substantial benefit to the detriment of the City.66.

The County would continue to be unjustly enriched if it continued to receive

additional funds pursuant to the Northline Road Agreement.

67. It would be inequitable for the County to retain these benefits.WHEREFORE, the City respectfully requests that this Court order the County to pay the

City all funds the County received under the Northline Road Agreement (plus statutory interest),

order that no further funds are to be paid to the County under the Northline Road Agreement and

granting the City such further and other relief as it may request and this Court may deem

appropriate.

Respectfully submitted,

HOWARD & HOWARD ATTORNEYS PLLC

/s/ Gustaf R. AndreasenGustaf R. Andreasen (P40956)Michael F. Wais (P45482)Attorneys for Plaintiff:TAX INCREMENT FINANCE AUTHORITYOF THE CITY OF TAYLOR450 West Fourth StreetRoyal Oak, Michigan 48067(248) 645-1483


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GASIOREK MORGAN GRECCO & MCCAULEY PC

/s/ David F. Greco, with consent

David F. Greco (P53523)Attorneys for Plaintiff:THE CITY OF TAYLOR30500 Northwestern Hwy. Ste. 425Farmington Hills, MI 48334(248) 865-0001

Dated: June 3, 2014


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Exhibit A


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Exhibit B


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Exhibit C


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Exhibit D


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Documents

City of Taylor, TIFA lawsuit against Wayne County