Respondent City of Jackson - Answer and Affirmative Defenses w POS 5.28.26.pdf

310 S Mechanic Limited Dividend Housing Association Limited Partnership Petitioner Vs. City Of Jackson Respondent · 26-000941-TT

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

______________________________________________________________________________ 

 

310 S. Mechanic Lofts Limited Dividend 

Housing Association Limited Partnership, 

 

 

 

 

Petitioner, 

 

 

MTT Docket No. 26-000941 

 

 

 

 

 

 

 

Parcel No. 4-007400000 

 

 

-vs- 

 

 

 

 

 

ANSWER TO PETITION AND 

 

 

 

 

 

 

 

AFFIRMATIVE DEFENSES 

City of Jackson, 

 

 

 

 

 

 

 

 

 

 

 

Respondent. 

 

 

_____________________________________________________________________________/ 

Honigman LLP 

By: Jackie J. Cook (P68781) 

Attorney for Petitioner 

2290 First National Bldg. 

660 Woodward Ave. 

Detroit, MI 48226 

(313)465-7270 

jcook@honigman.com 

JACKSON CITY ATTORNEY’S OFFICE 

By: Matthew M. Hagerty (P66015) 

Mark M. Porterfield (P57917) 

Attorneys for Respondent 

161 W. Michigan Avenue 

Jackson, MI 49201 

(517) 788-4050 

mhagerty@cityofjackson.org 

mporterfield@cityofjackson.org 

____________________________________________________________________________/ 

 

RESPONDENT CITY OF JACKSON’S 

ANSWER TO PETITION 

 

NOW COMES Respondent, City of Jackson, by and through its attorneys, the City 

Attorney’s Office, and for its Answer to Petitioner’s Petition, states as follows: 

1. Respondent neither admits nor denies the allegation contained in Paragraph 1 of 

Petitioner’s Petition and leaves Petitioner to its strict proofs. 

2. Respondent admits the allegation contained in Paragraph 2 of Petitioner’s Petition. 

3. Respondent admits the allegations contained in Paragraph 3 of Petitioner’s Petition. 

4. Respondent admits the allegations contained in Paragraph 4 of Petitioner’s Petition.

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5. Respondent admits the allegations contained in Paragraph 5 of Petitioner’s Petition. 

6. Respondent admits the allegations contained in Paragraph 6 of Petitioner’s Petition. 

7. Respondent admits the allegations contained in Paragraph 7 of Petitioner’s Petition. 

8. Respondent neither admits nor denies the allegation contained in Paragraph 8 of 

Petitioner’s Petition and leaves Petitioner to its strict proofs. 

9. Respondent neither admits nor denies the allegation contained in Paragraph 9 of 

Petitioner’s Petition and leaves Petitioner to its strict proofs. 

10. Respondent neither admits nor denies the allegation contained in Paragraph 10 of 

Petitioner’s Petition and leaves Petitioner to its strict proofs. 

11. Respondent neither admits nor denies the allegation contained in Paragraph 11 of 

Petitioner’s Petition and leaves Petitioner to its strict proofs. 

12. Respondent denies the allegations contained in Paragraph 12(a) through (d) of 

Petitioner’s Petition as untrue. 

WHEREFORE, Respondent City of Jackson requests this Honorable Tribunal dismiss 

Petitioner’s Petition in its entirety, that it assess actual costs and attorney fees against Petitioner 

for costs incurred in responding to the Petition, and further requests all other relief the Tribunal 

deems to be just and equitable. 

 

 

 

 

Respectfully submitted, 

 

 

 

 

 

 

 

DATED: May 28, 2026 

 

 

BY: ______________________________ 

 

 

 

 

 

 

 

MATTHEW M. HAGERTY (P66015) 

 

 

 

 

 

 

 

MARK M. PORTERFIELD (P57917) 

 

 

 

 

 

 

 

Office of the City Attorney 

 

 

 

 

 

 

 

City of Jackson, Michigan 

161 W. Michigan Ave. 

Jackson, MI 49201

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 AFFIRMATIVE DEFENSES 

NOW COMES Respondent, City of Jackson, by and through its attorneys, the City 

Attorney’s Office, and states the following Affirmative Defenses alternatively and consecutively: 

1. 

The subject property’s assessed, true cash, and taxable values are levied in 

accordance with the Michigan General Property Tax Act and Michigan Constitution. 

2. 

The subject property is assessed in accordance with generally accepted assessing 

standards. 

3. 

The subject property is assessed at no more than 50% of its true cash value. 

4. 

Petitioner has failed to state a claim upon which relief can be granted. 

5. 

Respondent reserves the right to amend its affirmative defenses through the 

conclusion of discovery. 

Respectfully submitted, 

 

 

 

DATED: May 28, 2026 

 

 

BY: ______________________________ 

 

 

 

 

 

 

 

MATTHEW M. HAGERTY (P66015) 

 

 

 

 

 

 

 

MARK M. PORTERFIELD (P57917) 

 

 

 

 

 

 

 

Office of the City Attorney 

 

 

 

 

 

 

 

City of Jackson, Michigan 

161 W. Michigan Ave. 

Jackson, MI 49201

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CERTIFICATE OF SERVICE 

 

STATE OF MICHIGAN 

 

) 

) ss 

COUNTY OF JACKSON 

 

) 

 

The undersigned certifies under penalty of perjury that on May 28, 2026 he served copies of 

Respondent City of Jackson’s Answer to Petition and Affirmative Defenses upon the 

Petitioner by first class mail with postage fully prepaid to the following address: 

 

 Jackie J. Cook (P68781) 

 Attorney for Petitioner 

 2290 First National Bldg. 

660 Woodward Ave. 

Detroit, MI 48226 

 

 

 

 

 

 

 

 

 

 

 

 

DATED: May 28, 2026 

 

 

 

________________________________ 

 

Matthew M. Hagerty (P66015) 

 

Office of the City Attorney

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