doc26001195TT ANSWER09903420260714141231.pdf

East Jordan Foundry LLC Petitioner Vs. Township Of Warner Respondent, Michigan Department Of Treasury Intervening Respondent · 26-001195-TT

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

EAST JORDAN FOUNDRY, LLC, 

Petitioner, 

MTT Docket No. 26-001195-TT 

v 

WARNER TOWNSHIP, 

Respondent. 

Edward U. Blanchard 

Robert E. Thall (P46421) 

Benjamin Buoscio 

Bauckham, Thall, Seeber, 

Deloitte Tax, LLP 

Kaufman & Koches, P.C. 

Representative for Petitioner 

Attorney for Respondent 

2200 Ross Ave., Ste. 1600 

470 W. Centre Ave., Suite A 

Dallas, TX 75201 

Portage, MI 49024-5362 

(313) 597-4765 

269-382-4500 

thall@michigantownshiplaw.com 

ANSWER TO PROPERTY TAX PETITION 

WITH AFFIRMATIVE DEFENSES 

Respondent, 

Warner Township, 

states 

the 

following 

in response 

to 

the 

respective 

paragraphs of the Petition filed in this matter: 

I. 

In answer to paragraph 

1 of the Petition, Respondent admits the allegation therein. 

2. 

In answer to paragraph 2 of the Petition, Respondent admits the allegation therein. 

3. 

In answer to paragraph 3 of the Petition, Respondent admits the allegation therein. 

4. 

In answer to paragraph 4 of the Petition, Respondent admits the allegation therein.

7. 

In answer 

to paragraph 

7 

of the Petition, Respondent admits the allegations 

therein, except it only levies its own taxes. 

8. 

In answer to paragraph 8 of the Petition, Respondent admits the allegation therein. 

9. 

In answer to paragraph 9 of the Petition, Respondent admits the allegation therein. 

10. 

In answer to paragraph 

10 of the Petition, Respondent admits the allegations 

therein. 

11. 

In answer to paragraph 

11 

of the Petition, Respondent admits the allegations 

therein. 

12. 

In answer to paragraph 

12 of the Petition, Respondent denies the contended 

valuations as untrue. 

13. 

In answer to paragraph 

13 

of the Petition, Respondent admits the allegations 

therein. 

14. 

In answer 

to paragraph 

14 

of the Petition, Respondent denies the allegation 

therein as untrue. 

15. 

Paragraph 15 is the Petitioner’s prayer for relief and does not require an answer. 

WHEREFORE, Respondent respectfully request that the Tribunal enter an Order denying 

the relief requested by Petitioner and uphold and affirm the valuations as established by the 

Respondent and require Petitioner to pay Respondent’s costs and attorney fees. 

AFFIRMATIVE DEFENSES 

Please take notice that Respondent may rely on one or more of the following affirmative

3. 

The service of process was insufficient. 

4. 

The subject property is under assessed and/or the taxable value and/or state equalized 

value of the subject property 

is too low, and should therefore be appropriately increased to 

comply with the mandate of the applicable provisions of law. 

5. 

Respondent reserves the right to file such additional affirmative defenses as may become 

apparent pursuant to discovery procedures during the pendency of this matter. 

WHEREFORE Respondent requests that the Tribunal enter a determination of no cause 

in its favor, and such other and further relief as is appropriate including costs and attorney fees. 

Respectfully submitted, 

BAUCKHAM, THALL, SEEBER, 

KAUFMAN, nh 

SP.C. 

Date: July 

4 

,2026 

AHL 

y: 

7) 

Vv 

/ 

Hover E. Thall 

Attorney for Respondent

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