2515 Riopelle Answer.pdf
2515 Riopelle, LLC Petitioner Vs. City Of Detroit Respondent · 26-001559-TT
Text extracted from the reviewed PDF, organized by page. OCR and reading order may contain errors; confirm details in the PDF below.
Page 1
1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL 2515 RIOPELLE, LLC A Michigan limited liability company Petitioner, v CITY OF DETROIT, Docket No. 26-001559-MTT a municipal corporation Parcel No. 07000823.004 Respondent. ________________________________________________________________________________/ ANSWER TO PROPERTY TAX PETITION Respondent, City of Detroit, by and through it undersigned counsel and for its Answer to this Petition 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 admits as true. 3. Respondent admits as true. 4. Respondent denies Petitioner’s contentions of value are correct or accurate. 5. Based solely upon Petitioner’s unsubstantiated contentions of value, Respondent admits. 6. Respondent admits as true. 7. Respondent admits that this is a proper recitation of MCL 205.735a(6).
Page 2
2 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. Respondent reserves the right to assert additional responses if Petitioner subsequently raises issues of “additions” or “losses”. 9. Respondent admits this appeal involves issues of true cash and taxable values imposed upon the Subject Property, but states that these allegations lack merit. 10. 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: 10/6/2026 /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 AFFIRMATIVE DEFENSES. NOW COMES Respondent, City of Detroit, and asserts the following Affirmative Defenses to the Petitioner’s claims: 1. Petitioner lacks standing and/or capacity to bring forth this Petition. 2. Petitioner’s claims may be barred by the applicable statute of limitations.
Page 3
3 3. This Tribunal lacks subject matter jurisdiction. 4. Petitioner has failed to state a claim upon which relief can be granted. 5. Petitioner has failed to allege that the mode and method of appraising its property failed to conform with the mode and method of appraising its property failed to conform with the mode and method applied in the case of all other properties in the community for the year in question. Wherefore, Respondent respectfully requests that this Honorable Tribunal dismiss the Petition in this matter and award attorney fees and costs to Respondent. Dated: 10/6/2025 /s/Mary Beth Cobbs By: Mary Beth Cobbs ( P40080) Kevin C. Richard ( P43417) Attorneys for Respondent City of Detroit Law Department 2 Woodward Ave., Ste. 500 Detroit, MI 48226 313.237.3075 cobbm@detroitmi.gov
Page 4
4 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL 2515 RIOPELLE, LLC A Michigan limited liability company Petitioner, v CITY OF DETROIT, Docket No. 26-001559-MTT a municipal corporation Parcel No. 07000823.004 Respondent. _______________________________________________________________________ PROOF OF SERVICE On 10/6/202, I mailed by first class mail a copy of Respondent’s Answer and Affirmative Defenses to: DAWDA PLC Christopher R. Martella Adam J. Salomon 39533 Woodward Avenue, Suite 200 Bloomfield Hill, MI 48304-5103 I declare that the above statement is true to the best of my information, knowledge, and belief. Dated: October 6, 2026 /s/Mary Beth Cobbs Mary Beth Cobbs ( P40080) City of Detroit Law Department 2 Woodward Ave., Ste. 500 Detroit, MI 48226