Answer final 631 Orleans 26-001035.pdf
631 Orleans LLC Petitioner Vs. City Of Detroit Respondent · 26-001035-TT
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1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL 631 ORLEANS LLC Petitioner, v CITY OF DETROIT, Docket No. 26- 001035 Respondent Parcel No. 07001962 ____________________________________________________________________________/ ANSWER TO PETITION and AFFIRMATIVE DEFENSES 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 and leaves Petitioner to its proofs. 2. Respondent admits as true. 3. Respondent admits as true. 4. Respondent admits as true. 5. Respondent admits that this appeal contains issues of (a) valuation (b) assessment (c) taxable value and (d) uniformity as it relates to the subject property, but further states that these allegations lack merit. 6. Respondent neither admits nor denies as Respondent lacks specific knowledge regarding any value of a loss, and therefore and therefore denies these allegations. 7. Respondent denies as untrue, including sub-paragraphs a-d.
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2 CONCLUSION and REQUEST FOR RELIEF Wherefore, Respondent respectfully requests that this Honorable Tribunal dismiss the Petition in this matter and award attorney fees and costs to Respondent. Dated: September 18, 2026 /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 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: September 18, 2026 /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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3 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL 631 ORLEANS, LLC Petitioner, v CITY OF DETROIT, Docket No. 26- 001035 Respondent Parcel No. 07001962 ___________________________________________________________________________/ PROOF OF SERVICE On September 18, 2026, I mailed by first class mail, a copy of Respondent’s Answer and Affirmative Defenses to: Aaron M. Fales, Esq. 330 Hamilton Row, Ste. 350 Birmingham, MI 48009 I declare that the above statement is true to the best of my information, knowledge, and belief. Dated: September 18, 2026 /s/Mary Beth Cobbs Mary Beth Cobbs ( P40080) City of Detroit Law Department 2 Woodward Ave., Ste. 500 Detroit, MI 48226