Answer.pdf
Coho Drive Mfd LLC, Petitioner Vs. Township Of East Bay, Respondent · 26-000687-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL COHO DRIVE MFD LLC, Petitioner, MTT Docket No. 26-000687 V EAST BAY CHARTER TOWNSHIP, Respondent. Scott Knowlton Robert E. Thall (P46421) Representative for Petitioner Bauckham, Thall, Seeber COHO DRIVE MFD, LLC Kaufman & Koches, P.C. 1435 Fulton St., Ste. C Attorney for Respondent Grand Haven, MI 49417 470 W. Centre Ave., Suite A 616-607-2532 Portage, MI 49024-5362 scott@westwind.build 269-382-4500 thall@michigantownshiplaw.com ANSWER TO PETITION WITH AFFIRMATIVE DEFENSES Respondent, East Bay Charter Township, states the following in response to the respective paragraphs of the Petition filed in this matter: 1. 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, one only parcel is under appeal. 4. In answer to paragraph 4 of the Petition, the parcel under appeal is real. 5. In answer to paragraph 5 of the Petition, no response is required. 6. In answer to paragraph 6 of the Petition, Respondent admits the allegation therein. 7. In answer to paragraph 7 of the Petition, Respondent admits the allegation therein. 8. In answer to paragraph 8 of the Petition, no response is required.
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9. In answer to paragraph 9 of the Petition, no response is required. 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 allegation therein. 12. In answer to paragraph 12 of the Petition, Respondent admits the allegation therein. 13. In answer to paragraph 13 of the Petition, Respondent admits that the Petitioner has raised the issues identified therein. 14. In answer to paragraph 14 of the Petition, Respondent admits the allegation therein. 15. In answer to paragraph 15 of the Petition, no response is required. 16. In answer to paragraph 16 of the Petition, Respondent admits the allegations therein. 17. In answer to paragraph 17 of the Petition and, Respondent denies the Petitioners values for the property as untrue. 18. In answer to paragraph 18 of the Petition, Respondent admits the values in dispute. 19. Paragraph 19 of the Petition does not require an answer as it is the Petitioner’s prayer for relief. 20. In answer to paragraph 20 of the Petition, Respondent lacks knowledge or information to form a belief about the truth of the matters asserted, except Respondent denies as untrue assertions as to the value of the property.
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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 defenses: 1. Petitioner has failed to state a claim upon which relief may be granted. 2. The Tribunal lacks jurisdiction over Petitioner and/or the subject property. 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, SPARKS, THALL, SEEBER & KAUFMAN, P.C. Date: June 29, 2026 By: /s/ Robert E. Thall Robert E. Thall Attorney for Respondent