Flagstar Bank Answer to Petition and Affirmative Defenses and POS.pdf

Flagstar Bank, N.A., Petitioner Vs. City Of Jackson, Respondent · 25-001690-TT

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

FLAGSTAR BANK, FSB, 

Petitioner, 

-VS- 

CITY OF JACKSON, 

Respondent. 

MTT Docket No. 25-001690 

Parcel No. 4-0264.1000 

ANSWER TO PETITION AND 

AFFIRMATIVE DEFENSES 

LAW OFFICES OF AARON M. FALES, P.C. 

BY: Aaron M. Fales (P72864) 

Attorney for Petitioner 

330 Hamilton Row, Ste. 350 

Birmingham, MI 48009 

(248) 767-9840 

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 

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: 

I. 

Respondent admits the allegation contained in Paragraph 1 of Petitioner’s Petition. 

2. 

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

3. 

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

4. 

Respondent neither admits nor denies the allegation contained in Paragraph 4 of 

Petitioner’s Petition and leaves Petitioner to its proofs.

5. 

Respondent neither admits or denies the allegations made 

in Paragraph 

5 

of 

Petition’s Petition and leaves Petitioner to its proofs. 

6. 

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

7. 

Respondent denies the allegations of paragraph 7(a)-(d) inclusive, as untrue and 

further constitutes a legal conclusion. 

The property’s Assessed Value is 50% of the True Cash 

Value. 

WHEREFORE, 

Respondent 

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: October 22, 2025 

BY: 

City of Jackson, Michigan 

161 W. Michigan Ave. 

Jackson, MI 49201

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 property’s assessed, true cash and taxable values are levied in accordance with the 

Michigan General Property Tax Act and Michigan Constitution. 

2. 

The property is assessed in accordance with generally accepted assessing standards. 

3. 

The 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: October 22, 2025 

BY: 

y 

4 

4 

MATTHEW M. HAGERTY/(P66015) 

MARK M. PORTE 

(P57917) 

Office of the City Attorney 

City of Jackson, Michigan 

161 W. Michigan Ave. 

Jackson, MI 49201 

CERTIFICATE OF SERVICE 

STATE OF MICHIGAN 

) 

) ss 

COUNTY OF JACKSON 

) 

The undersigned certifies under penalty of perjury that on October 22, 2025 she 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: 

LAW OFFICES OF AARON M. FALES, P.C. 

Attorney for Petitioner 

330 Hamilton Row, Ste. 350 

Birmingham, MI 48009 

3

DATED: 

October 22, 2025 

Revit» fHrtdtetC 

ROBERTA HUBBELL

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