Ans Aff Defs.pdf
Woodward Brown Ventures LLC Petitioner Vs. City Of Birmingham Respondent · 26-001315-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN ADMINISTRATIVE HEARING SYSTEM MICHIGAN TAX TRIBUNAL WOODWARD BROWN VENTURES LLC, Petitioner, vs. CITY OF BIRMINGHAM, Respondent. MTT Docket No. 26-001315 Parcel No. 08-19-36-202-019 _____________________________________________________________________________/ ANSWER TO PETITION Respondent City of Birmingham, through its attorneys, Beier Howlett, P.C., responds to the allegations made in the Petition as follows: 1. Admitted. 2. Not applicable. 3. Admitted. 4. Admitted. 5. Neither admit nor deny as Respondent is without sufficient information and therefore, Respondent leaves Petitioner to its proofs. 6. Neither admit nor deny as Respondent is without sufficient information and therefore, Respondent leaves Petitioner to its proofs. 7. Neither admit nor deny as Respondent is without sufficient information and therefore, Respondent leaves Petitioner to its proofs. 8. Admitted. 9. It is admitted that Petitioner seeks the values stated in this paragraph. Respondent denies that the requested values are appropriate or accurate.
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10. Respondent admits that the amounts recited reflect Petitioner’s position as to the values in dispute, but denies Petitioner’s value contentions and therefore denies those are appropriate or accurate. 11. Respondent denies all of the allegations in this paragraph. WHEREFORE, Respondent City of Birmingham requests that the Tribunal dismiss the Petition, affirm Respondent’s assessed and taxable values, subject to county and state equalization, and award Respondent its costs and attorney fees. Respectfully submitted, BEIER HOWLETT, P.C. /s/ Michael C. Gibbons Michael C. Gibbons (P51304) Attorneys for Respondent 3001 W. Big Beaver Rd., Ste. 600 Troy, MI 48084 Date: October 15, 2026 248-282-1069/ mgibbons@bhlaw.us.com
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AFFIRMATIVE DEFENSES Respondent, City of Birmingham, through its attorneys, Beier Howlett, P.C., submits the following Affirmative Defenses to the Petition: 1. Petitioner has failed to establish that it is entitled to the relief requested in the Petition, including any reduction in the property's true cash value, assessed value, state equalized value, or taxable value. 2. Petitioner bears the burden of establishing the true cash value of the subject property pursuant to MCL 205.737(3), and Respondent denies that the values alleged in the Petition accurately reflect the property's true cash value. 3. To the extent applicable, Petitioner's claims are barred, in whole or in part, by failure to comply with statutory jurisdictional prerequisites, including applicable filing deadlines, protest requirements, and requirements concerning standing. 4. To the extent applicable, Petitioner's claims are barred, in whole or in part, by waiver, estoppel, release, settlement, or other binding agreement. 5. Respondent reserves the right to seek leave to amend its Answer to assert additional defenses as may be warranted by discovery or further proceedings. Respectfully submitted, BEIER HOWLETT, P.C. /s/ Michael C. Gibbons Michael C. Gibbons (P51304) Attorneys for Respondent 3001 W. Big Beaver Rd., Ste. 600 Troy, MI 48084 Date: October 15, 2026 248-282-1069/ mgibbons@bhlaw.us.com
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STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN ADMINISTRATIVE HEARING SYSTEM MICHIGAN TAX TRIBUNAL WOODWARD BROWN VENTURES LLC, Petitioner, vs. CITY OF BIRMINGHAM, Respondent. MTT Docket No. 26-001315 Parcel No. 08-19-36-202-019 _____________________________________________________________________________/ PROOF OF SERVICE On the date below I sent a copy of this Answer to: LAURA M. HALLAHAN Hallahan & Associates, P.C. 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302 I declare that the statements above are true and to the best of my information, knowledge and belief. /s/ Erin Miller Erin Miller Dated: October 15, 2026