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25-001881 - ET - 2025 Answer - Signed.pdf

588 Northwestern LLC, Petitioner Vs. City Of Southfield, Respondent · 25-001881-TT

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Page 1

MTT Docket No. 25-001881 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

588 NORTHWESTERN LLC, 

Petitioner, 

V. 

MTT Docket No.: 25-001881 

| 

Parcel No(s): 76-24-18-226-039 

CITY OF SOUTHFIELD, 

Respondent 

/ 

Stewart Mandell (P33781) 

Justin E. Prybylski, MMAO(4) 

Attorney 

for Petitioner 

City Assessor 

Honigman LLP 

City of Southfield 

39400 Woodward Avenue, Suite 101 

26000 Evergreen Rd. 

Bloomfield Hills, MI 

48304 

Southfield, MI 

48076 

slmandell@honigman.com 

jprybylski@cityofsouthfield.com 

jcook@honigman.com 

(248) 

796-5230 

(313) 

465-7420 

RESPONDENT’S ANSWER TO PETITIONER’S 

ENTIRE TRIBUNAL PROPERTY TAX PETITION 

NOW COMES Respondent, CITY OF SOUTHFIELD, by and through its Representative, and for 

its Answer to Petitioner’s Petition, states as follows: 

I. 

As to the allegations contained in Paragraph 1, Respondent can neither admit, nor 

deny the same as true, for the reason that it’s without sufficient knowledge or information, upon 

which to form a belief as to the truth thereof and leaves Petitioner to its strict proofs. 

2. 

As to the allegations contained in Paragraph 2, Respondent admits the same as true;

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MTT Docket No. 25-001881 

4. 

As to the allegations contained in Paragraph 4, Respondent admits the same as true; 

the property(s) identified herein are classified commercial real property and used for commercial 

purposes. 

5: 

As to the allegations contained in Paragraph 5, Respondent can neither admit, nor 

deny the same as true, for the reason it’s without sufficient knowledge, or information, upon which 

to form a belief as to the truth thereof and leaves Petitioner to its strict proofs. 

6. 

As to the allegations contained in Paragraph 6, Respondent can neither admit, nor 

deny the same as true, for the reason it’s without sufficient knowledge, or information, upon which 

to form a belief as to the truth thereof and leaves Petitioner to its strict proofs. 

7. 

As to the allegations contained in Paragraph 7, Respondent admits the same as true; 

the property(s) identified herein were not required to appeal to the March Board of Review, as 

required under MCL 205.735a(3). 

8. 

As to the allegations contained 

in Paragraph 8, Respondent denies Petitioner’s 

allegations as untrue and leaves Petitioner to its strict proofs. 

WHEREFORE, Respondent, CITY OF SOUTHFIELD, respectfully requests that this 

Honorable Tribunal affirm Respondent’s assessment and taxable value of the subject property, that 

Petitioner’s Petition be dismissed with prejudice and that Respondent be granted costs and attorney 

fees so wrongfully sustained. 

Respectfully submitted, 

Tg 

Dated: July 24, 2025

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MTT Docket No. 25-001881 

AFFIRMATIVE DEFENSES 

For its further Answer to Petitioner's Petition and by way of its Affirmative Defenses, 

Respondent respectfully requests unto this Honorable Tribunal as follows: 

I. 

Petitioner fails to allege specific and sufficient facts to set forth a cause of action 

against Respondent and to support its claim for relief. 

| 

| 

2. 

Petitioner fails to allege specific and sufficient facts to establish fraud, error of law, 

discrimination, the application of wrong principles or illegality on the part of the Respondent. 

3. 

Petitioner fails to allege that the mode and method of appraising its property failed 

to conform to the mode and method applied in the case of all of the properties in the Respondent’s 

taxing unit for the year in question. 

4. 

Petitioner fails to allege specific and sufficient facts to establish the true cash value, 

assessed value and taxable value of its property. 

5. 

Petitioner fails to allege specific and sufficient facts to support its allegation that 

the assessed value of its property, as equalized, is at a factor other than 50% and also fails to allege 

specific and sufficient facts to support its allegations that the property’s taxable value is improper. 

6. 

Petitioner fails to show that any rate other than 50% after equalization was applied 

to the true cash value of its property, as well as to the properties of all others to arrive at the 

respective equalized assessments. 

7. 

Petitioner, 

in 

essence, 

asks 

that 

this Honorable Tribunal 

grant 

it 

an 

illegal 

preference 

by application 

of a method of assessment different from 

that employed 

in 

the

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MTT Docket No. 25-001881 

9. 

Any decrease in the value of Petitioner’s property was a result of its own intentional 

acts and/or negligence and cannot be allowed to reduce Petitioner’s otherwise equitable tax burden. 

10. 

Respondent 

has 

properly 

and 

lawfully 

assessed 

Petitioner’s 

property 

and 

established its taxable value in accordance with statutory and constitutional requirements. 

11. 

Respondent reserves the right to add to these Affirmative Defenses any new 

Affirmative Defenses that discovery reveals. 

WHEREFORE, Respondent, CITY OF SOUTHFIELD, denies that Petitioner is entitled to 

the relief it seeks and respectfully requests that the Respondent’s assessment and taxable value of 

the subject property be affirmed, and that Petitioner’s Petition be dismissed with prejudice and that 

Respondent be granted costs and attorney fees so wrongfully sustained. 

Dated: July 24, 2025 

Respectfully submitted, 

- 

Justin E. Prybylski, MMAO(4) 

Assessor 

|| City of Southfield 

26000 Evergreen Rd 

Southfield, MI 48076 

0: (248) 796-5230 

iprybylski@cityofsouthfield.com

Page 5

MTT Docket No. 25-001881 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

588 NORTHWESTERN LLC, 

Petitioner, 

V. 

MTT Docket No.: 25-001881 

Parcel No(s): 76-24-18-226-039 

CITY OF SOUTHFIELD, 

Respondent 

Proof of Service 

Justin E. Prybylski, MMAO(4), Assessor for the City of Southfield, certifies that on Thursday, 

July 24, 2025, copies of Respondent’s Answer to Petitioner’s Petition were served to: 

Stewart Mandell, Attorney for Petitioner 

Honigman LLP 

39400 Woodward Avenue, Suite 101 

Bloomfield Hills, MI 

48304 

By certified mail and 

Southfield School District 

Oakland County Equalization Division 

Administrative Offices 

Oakland Pointe Office Building 

24661 Lahser Road 

250 Elizabeth Lake Rd., Suite 1000W 

Southfield, MI 

48033 

Pontiac, MI 

48341-0431 

Oakland County Clerk 

Chief Clerk, Michigan Tax Tribunal 

1200 N Telegraph, Building #12E 

P.O. Box 30232 

Pontiac, MI 

48341 

Lansing, MI 48909 

Michigan State Treasury 

P.O. Box 30471 

Lansing, MI 48909 

By first class mail by placing said document in envelopes addressed to the above parties with 

postage fully prepaid, and by depositing said envelopes in a receptacle for United States Mail.

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