Full record / Southeast Group LLC MTT# 26-002662 answer.pdf

Southeast Group LLC MTT# 26-002662 answer.pdf

Southeast Group LLC Petitioner Vs. City Of Detroit Respondent · 26-002662-TT

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

SOUTHEAST GROUP, LLC, 

 

Petitioner, 

v. 

 

 

 

 

 

 

 

Docket No. 26-002662 

 

CITY OF DETROIT, 

 

 

 

 

 

 

 

Respondent. 

________________________________/ 

 

ANSWER 

 

 

RESPONDENT, CITY OF DETROIT, for its Answer to the Petition filed in this matter 

states as follows: 

1. Respondent admits. 

2. Respondent admits. 

3. Respondent admits. 

4. Respondent admits as to Respondent’s Board of Review values, however, neither 

admits nor denies Petitioner’s value contentions as Respondent lacks sufficient 

knowledge or information to form a belief as to the truth of the allegation. 

5. Respondent admits. 

6. Respondent admits. 

7. Respondent admits only that Petitioner’s instant Tax Tribunal appeal alleges issues 

involving valuation, assessment, taxable value, and uniformity, however, Respondent 

denies that any such allegations have merit. 

8. Respondent neither admits nor denies as Respondent lacks sufficient knowledge or 

information to form a belief as to the truth of the allegation.

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9. Respondent admits. 

10. Respondent denies as untrue. 

AFFIRMATIVE DEFENSES 

Respondent further asserts that Petitioner’s claims are barred, in whole or in part, by: 

1. Petitioner’s claims are barred by the applicable statute of limitations. 

2. Petitioner has failed to state a claim for which relief may be granted. 

3. This Tribunal lacks subject matter jurisdiction. 

WHEREFORE, Respondent City of Detroit respectfully requests that this Honorable 

Tribunal dismiss the petition in this matter and award costs and attorney fees. 

 

 

 

 

Respectfully Submitted, 

 

 

 

 

 

/s/ Kevin C. Richard 

 

 

 

 

 

Kevin C. Richard (P43417) 

 

 

 

 

 

City of Detroit Law Department 

 

 

 

 

 

Coleman A. Young Municipal Center 

 

 

 

 

 

2 Woodward Avenue, Suite 500 

 

 

 

 

 

Detroit, Michigan 48226 

 

 

 

 

 

(313) 237-3061 

Dated: August 18, 2026

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

SOUTHEAST GROUP, LLC, 

 

Petitioner, 

v. 

 

 

 

 

 

 

 

Docket No. 26-002662 

 

CITY OF DETROIT, 

 

Respondent. 

________________________________/ 

 

PROOF OF SERVICE 

 

On August 18, 2026, I sent by first class mail and email a copy of Respondent’s Answer 

w/Affirmative Defenses in the instant matter to: 

 

Stewart L. Mandell 

Daniel L. Stanley 

Honigman LLP 

2290 First National Building 

660 Woodward Avenue 

Detroit, Michigan 48226 

slmandell@honigman.com 

dstanley@honigman.com 

 

I declare that the statement above is true to the best of my information, knowledge, and belief. 

 

 

 

 

 

 

 

 

/s/ Kevin C. Richard 

 

 

 

 

 

 

Kevin C. Richard (P43417) 

 

 

 

 

 

 

Senior Assistant Corporation Counsel 

 

 

 

 

 

 

City of Detroit Law Department 

 

 

 

 

 

 

Coleman A. Young Municipal Center 

 

 

 

 

 

 

2 Woodward Avenue, Suite 500 

Dated: August 18, 2026 

 

 

Detroit, Michigan 48226

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