Respondent Answer and Affirmative Defenses.pdf
Continental Plaza Venture LLC Petitioner Vs. City Of Troy Respondent · 26-000862-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL CONTINENTAL PLAZA VENTURE LLC, Petitioner, MTT Docket: 26-000862 \Y, Parcel ID 88-20-28-101-048 CITY OF TROY, Respondent. / JOSHUA T. SHILLAIR (P72674) LORI GRIGG BLUHM (P46908) Vice President/ Tax Appeal JULIE QUINLAN DUFRANE (P59000) COLLIERS INTERNATIONAL TROY CITY ATTORNEY'S OFFICE Attorney for Petitioner Attorneys for Respondent 400 W. 4th Street, Suite 350 500 W. Big Beaver Road Royal Oak, MI 48067 Troy, MI 48084 (248) 226-1632 (248) 524-3320 Joshua.Shillair@Colliers.com BLUHMLG@TROYMI.gov / RESPONDENT’S ANSWER TO PETITION AND AFFIRMATIVE DEFENSES NOW COMES, Respondent, CITY OF TROY, by and through its attorney, Lori Grigg Bluhm, and for its Answer to Petitioner's Petition, states as follows: 1. As to Paragraph 1, Respondent neither admits nor denies the allegation, lacking knowledge or information sufficient to form a belief as to the truth of the allegations and therefore and leaves Petitioners to the proofs. 2. As to Paragraph 2, Respondent admits the allegation.
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denies the allegation, lacking knowledge or information sufficient to form a belief as to the truth of the allegations and therefore and leaves Petitioners to the proofs. 5. As to Paragraph 5, Respondent admits that there was no board of review protest filed. 6. As to Paragraph 6, Respondent admits. 7. As to Paragraph 7, Respondent denies that there are any issues concerning the valuation, assessment, taxable value, and/or uniformity. 8. As to paragraph 8, Respondent admits. 9. As to Paragraph 9, Respondent admits. 10. As to Paragraph 10, Respondent denies the allegation in its entirety, as it is untrue. 11. As to Paragraph 11, Respondent denies that the Petitioner's alleged values for the subject parcels are correct or supported by any basis. 12. As to Paragraph 12, Respondent admits that Petitioner has correctly calculated the difference between Petitioner's claimed assessed values for the subject property and the Respondent's assessed value determination. Respondent denies that the Petitioner's assessed values are correct. 13. As to Paragraph 13, Respondent denies that Petitioner has correctly determined the values of the subject property, and also denies that Respondent has erred in its determination of the values of the property, since these assertions are untrue.
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Dated: July 14, 2026 CITY OF TROY LORI GRIGG BLUHM (P46908) Attorney for Respondent 500 W. Big Beaver Road Troy, MI 48084 (248) 524-3320 BluhmLG@troymi.gov AFFIRMATIVE DEFENSES For its further Answer to Petitioners’ Petition, Respondent relies on the following Affirmative Defenses: (8 Petitioners fail to allege specific and sufficient facts to set forth a cause of action against Respondent and to support its claim for relief. Petitioners fail to allege specific and sufficient facts to establish fraud, error of law, discrimination, application of wrong principles or illegality on the part of the Respondent or its agents. Petitioners fail to allege specific and sufficient facts to establish the true cash value, assessed value, and taxable value of its property. Petitioners fail to allege specific and sufficient facts to support its allegations that the property's taxable value is improper, or failed to conform with the mode and method applied in the case of all properties in the City of Troy for 2023. Any decrease in the value of Petitioner's property was a result of its own intentional
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6. Respondent has properly and lawfully assessed Petitioner's property and established its assessed and taxable value in accordance with statutory and constitutional requirements. 7. Respondent reserves the right to argue additional Affirmative Defenses during the pendency of this action. WHEREFORE, Respondent, CITY OF TROY denies that Petitioner is entitled to its requested relief, and requests that the subject property's assessment and taxable value be affirmed or increased, that Petitioners’ Petition be dismissed with prejudice, and that Respondent be granted costs and attorney fees so wrongfully sustained. Dated: July 14, 2026 CITY OF TROY LORI GRIGG BLUHM (P46908) Attorneys for Respondent 500 W. Big Beaver Road Troy, MI 48084 (248) 524-3320 BluhmLG@troymi.gov
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Certificate of Service | hereby certify that on July 14, 2026, | served a copy of this Answer and Affirmative Defenses via email to Petitioner's representative Joshua Shillair at Joshua. Shillair@Colliers.com and to the following via first class mail: Chief Clerk, Michigan Tax Tribunal; P.O. Box 30232, Lansing, MI 48909; Michigan Department of Treasury, State Treasurer, 430 W. Allegan, Lansing, MI 490822; Secretary of School Board, Troy Public Schools, 4400 Livernois Road, Troy, MI 48098; Director of Equalization; Oakland Pointe Office Building, 250 Elizabeth Lake Road Suite 1000; Pontiac, MI 48341; and Clerk, Oakland County; 1200 N. Telegraph, Building 12 East, Pontiac, MI 48341. Dated: July 14, 2026 CITY OF TROY ClaraReid 3 Legal Administrative Coordinator 500 W. Big Beaver Road Troy, MI 48084 (248) 524-3320