26000675 Pontiac Answer - Centerpoint Associates LLC.pdf
Centerpoint Associates LLC Petitioner Vs. City Of Pontiac Respondent · 26-000675-TT
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ClarkHill\18836\1032869\288883717.v1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL MTT Docket No. 26-000675 Parcel No. 64-19-03-426-016 CENTERPOINT ASSOCIATES LLC, Petitioner, v CITY OF PONTIAC, Respondent. / Laura M. Hallahan (P42101) HALLAHAN & ASSOCIATES, P.C. Representative for Petitioner 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302-0179 (248) 731-3090 lhallahan@hallahanlaw.com Elizabeth White McDonnell (P62561) Sean P. Fitzgerald (P60654) CLARK HILL PLC Attorneys for Respondent 200 Ottawa Avenue NW, Suite 500 Grand Rapids, MI 49503 (616) 608-1131 ewhitemcdonnell@clarkhill.com sfitzgerald@clarkhill.com / RESPONDENT’S ANSWER TO PETITION Respondent, City of Pontiac, by and through its attorneys, Clark Hill PLC, hereby answers the Petition filed by Petitioner, Centerpoint Associates LLC, and states as follows: 1. Respondent admits the allegations in paragraph 1 of the Petition. 2. Respondent lacks the knowledge or information to form a belief as to the truth of the allegations contained in paragraph 2 of the Petition. 3. Respondent admits the allegations in paragraph 3 of the Petition. 4. Respondent lacks the knowledge or information to form a belief as to the truth of the allegations contained in paragraph 4 of the Petition. 5. Respondent lacks the knowledge or information to form a belief as to the truth of the allegations contained in paragraph 5 of the Petition.
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2 ClarkHill\18836\1032869\288883717.v1 6. Respondent lacks the knowledge or information to form a belief as to the truth of the allegations contained in paragraph 6 of the Petition. 7. Respondent admits the allegations in paragraph 7 of the Petition. 8. Respondent admits that the values set by Respondent’s Board of Review are: TCV AV TV 492,360 246,180 50,930 9. Respondent denies the allegations in paragraph 9 of the Petition as untrue. 10. Respondent denies the allegations in paragraph 10 of the Petition as untrue. 11. Respondent denies the allegations in paragraph 11 of the Petition as untrue. WHEREFORE, Respondent respectfully requests that the Tribunal dismiss the Petition, sustain the assessed, taxable and true cash values with respect to the property as established by Respondent, award the costs and fees, including attorneys’ fees, incurred by Respondents in the defense of this matter, and grant such other and further relief as the Tribunal deems just and proper. Dated: August 31, 2026 Respectfully submitted, CLARK HILL PLC By: Elizabeth White McDonnell (P62561) Sean P. Fitzgerald (P60654) Attorneys for Respondent
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3 ClarkHill\18836\1032869\288883717.v1 AFFIRMATIVE DEFENSES TO PETITIONER’S PETITION NOW COMES Respondent, City of Pontiac, by and through its attorneys, Clark Hill PLC, and hereby offers the following Affirmative Defenses to Petitioner’s Petition as follows: 1. Petitioner fails to allege specific and sufficient facts to set forth a cause of action against Respondent and to support its claim of relief. 2. Respondent has properly and lawfully classified Petitioner’s property and established its taxable and assessed value in accordance with local ordinances, state regulations, statutory and constitutional requirements. 3. Respondent reserves the right to add other affirmative defenses as they become known. Dated: August 31, 2026 Respectfully submitted, CLARK HILL PLC By: Elizabeth White McDonnell (P62561) Sean P. Fitzgerald (P60654) Attorneys for Respondent