Answer and Affirmative Defenses.pdf
Cr Oakland Square LLC Petitioner Vs. City Of Troy Respondent · 26-001379-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL CR OAKLAND SQUARE LLC Petitioner, MTT Docket: 26-001379 V Parcel IDs 88-20-36-301-005 & 88-20-36-301-006 CITY OF TROY, Respondent. / SARAH R. BELLOLI LORI GRIGG BLUHM (P46908) RYAN JULIE QUINLAN DUFRANE (P59000) Petitioner Representative TROY CITY ATTORNEY'S OFFICE 101 W. Big Beaver Road Attorneys for Respondent Suite 945 500 W. Big Beaver Road Troy, MI 48084 Troy, MI 48084 (313) 230-0104 (248) 524-3320 Sarah.Belloli@Ryan.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 admits the allegation. 2. As to Paragraph 2, Respondent admits the allegation. 3. As to Paragraph 3, Respondent admits the allegation.
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7. As to Paragraph 7, Respondent admits no board of review protest was submitted. 8. As to Paragraph 8, No answer is required. Sg. As to Paragraph 9, No answer is required. 10. As to Paragraph 10, Respondent admits the allegation. 11. As to Paragraph 11, Respondent admits the allegation. 12. As to Paragraph 12, Respondent neither admits nor denies the allegation, and leaves Petitioner to its proofs. 13. As to Paragraph 13, Respondent denies that Petitioner has any support for its challenge to the true cash, assessed and taxable values of the subject properties. 14. As to Paragraph 14, Respondent admits the allegation. 15. As to Paragraph 15, No answer is required. 18. As to Paragraph 16, Respondent admits the allegation. 17. As to Paragraph 17, Respondent denies that Petitioner has any support or basis for its contention of the true cash, assessed and taxable values for the subject properties. 18. As to Paragraph 18, Respondent does not contest the Petitioner's math calculations, but denies that Petitioner has any support or basis for its contention of the true cash, assessed and taxable values for the subject properties. 19. As to Paragraph 19, Respondent denies that Petitioner is entitled to its requested relief.
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WHEREFORE, Respondent, CITY OF TROY, requests the Tribunal dismiss the Petition, affirm or increase the assessed and taxable values of the subject properties, subject to county and state equalization, and award Respondent PD and attorney fees. Lori Grigg Bluhm (P46908) City of Troy Attorney's Office Attorney for Defendant 500 W. Big Beaver Road Troy, MI 48084 (248) 524-3320 BluhmLG@troymi.gov Dated: July 15, 2026
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AFFIRMATIVE DEFENSES For its further Answer to Petitioners’ Petition, Respondent relies on the following Affirmative Defenses: 1. 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 properties’ taxable values are improper, or failed to conform with the mode and method applied in the case of all properties in the City of Troy for 2026. Any decrease in the value of Petitioner's properties was a result of its own intentional acts and/or negligence and cannot be allowed to reduce Petitioner's otherwise equitable tax burden. Respondent has properly and lawfully assessed Petitioner's properties and established the assessed and taxable values in accordance with statutory and constitutional requirements. Respondent reserves the right to argue additional Affirmative Defenses during the
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affirmed or increased, that Petitioners’ Petition be dismissed with prejudice, and that Respondent be granted costs and attorney fees so wrongfully sustained. Led Lori Grigg Bluhm (P46908) City of Troy Attorney’s Office Attorney for Defendant 500 W. Big Beaver Road Troy, MI 48084 (248) 524-3320 BluhmLG@troymi.gov Dated: July 15, 2026 Certificate of Service | hereby certify that on July 15, 2026, | served a copy of this Answer and Affirmative Defenses via email to Petitioner's representative Sarah R. Belloli at Sarah.Belloli@Ryan.com and to the following via first class mail: Michigan Department of Treasury, State Treasurer, 430 W. Allegan, Lansing, MI 49822; Secretary of School Board, Lamphere Public Schools, 31201 Dorchester, Madison Heights, MI 48071; 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, Ml 4 341 7] DEAE Clara Reid ] Legal Administrative Coordinator City of Troy Attorney’s Office 500 W. Big Beaver Road Troy, MI 48084 Dated: July 15, 2026