Tim Muflihi Answer 25-002045 Mack Ave.pdf
Tim Muflihi, Petitioner Vs. City Of Detroit, Respondent · 25-002045-TT
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1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS TIM MUFLIHI Petitioner, v CITY OF DETROIT, Docket No. 25- 002045- MTT Respondent. Parcel No. 21001277. ________________________________________________________________________________/ ANSWER TO PROPERTY TAX PETITION Now Comes Respondent, City of Detroit, by and through it undersigned counsel and in Answer to the Petition filed in this matter states the following : 1. Respondent, City of Detroit, neither admits nor denies as Respondent lacks sufficient knowledge or information to form a belief as to the truth of the allegation and leaves Petitioner to its proofs 2. Respondent, City of Detroit, neither admits nor denies as Respondent lacks sufficient knowledge or information to form a belief as to the truth of the allegation and leaves Petitioner to its proofs 3. Respondent, City of Detroit, neither admits nor denies as Respondent lacks sufficient knowledge or information to form a belief as to the truth of the allegation and leaves Petitioner to its proofs 4. Respondent, City of Detroit admits that the issue being appealed in the instant matter is the True Cash Value and Taxable Value, but denies that any such allegation has merit. 5. Respondent, City of Detroit, denies the allegations contained in the corresponding paragraph.
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2 6. Respondent, City of Detroit, admits as true the allegations contained in the corresponding paragraph. 7. Respondent, City of Detroit, neither admits nor denies as Respondent lacks sufficient knowledge or information to form a belief as to the truth of the allegation and leaves Petitioner to its proofs 8. Respondent, City of Detroit, neither admits nor denies as Respondent lacks sufficient knowledge or information to form a belief as to the truth of the allegation and leaves Petitioner to its proofs. 9. Respondent, City of Detroit, neither admits nor denies as Respondent lacks sufficient knowledge or information to form a belief as to the truth of the allegation and leaves Petitioner to its proofs. Wherefore, Respondent respectfully requests that this Honorable Tribunal dismiss the Petition in this matter and award attorney fees and costs to Respondent. Dated: 8/15/2025 /s/Mary Beth Cobbs By: Mary Beth Cobbs ( P40080) Kevin C. Richard ( P 43417) Attorneys for Respondent City of Detroit Law Department 2 Woodward Ave., Ste. 500 Detroit, MI 48226
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3 AFFIRMATIVE DEFENSES. NOW COMES Respondent, City of Detroit, and asserts the following Affirmative Defenses to the Petitioner’s claims: 1. Petitioner’s lacks standing and/or capacity to bring forth this Petition. 2. Petitioner’s claims may be barred by the applicable statute of limitations. 3. This Tribunal lacks subject matter jurisdiction. 4. Petitioner has failed to state a claim upon which relief can be granted. Wherefore, Respondent respectfully requests that this Honorable Tribunal dismiss the Petition in this matter and award attorney fees and costs to Respondent. Dated: 8/15/2025 /s/Mary Beth Cobbs By: Mary Beth Cobbs ( P40080) Kevin C. Richard ( P 43417) Attorneys for Respondent City of Detroit Law Department 2 Woodward Ave., Ste. 500 Detroit, MI 48226 313.237.3075 cobbm@detroitmi.gov
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4 PROOF OF SERVICE On 8/15/2025, I mailed by first class mail a copy of Respondent’s Answer and Affirmative Defenses to: Tim Muflihi 23676 Park St. Dearborn, MI 48124 I declare that the above statement is true to the best of my information, knowledge, and belief. Dated: August 15, 2025 /s/Mary Beth Cobbs Mary Beth Cobbs ( P40080) City of Detroit Law Department 2 Woodward Ave., Ste. 500 Detroit, MI 48226