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Answer Carlton Acquision.pdf

Carlton Acquisition LLC Petitioner Vs. City Of Detroit Respondent · 26-000749-TT

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 CARLTON ACQUISITION, LLC 

 

Petitioner, 

 

 

 

 

 

v 

CITY OF DETROIT, 

 

 

 

Docket No. 26-000749 

 

Respondent 

 

 

 

 

Parcel No. 05003477-8 

____________________________________________________________________________/ 

ANSWER TO AMENDED PETITION and 

AFFIRMATIVE DEFENSES 

Now Comes Respondent, City of Detroit, by and through it undersigned counsel and in Answer 

to the Amended Petition filed in this matter states the following: 

The Parties 

 

1. Respondent, City of Detroit, neither admits nor denies and leaves Petitioner to its 

proofs. 

2. Respondent admits as true. 

The Subject Property 

3. Respondent admits as true. 

4. Respondent admits as true. 

5. Respondent admits as true. 

 The 2026 Assessment 

6. Respondent admits as true. 

7. Respondent admits as true.

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8. Respondent neither admits nor denies and leaves Petitioner to its proofs. 

9. Respondent admits as true. 

10. Respondent admits that this appeal contains issues of valuation for assessment 

purposes of the subject property, although Petitioner does not believe that this appeal 

involves issues of “additions” or “losses, but reserves the right to assert said issues. 

Respondent reserves the right to property respond, should Petitioner raise said issues. 

11. Respondent denies that the 2026 assessment is violative of the Michigan Constitution, 

the GPTA and other Michigan law. Respondent also denies the other allegations 

contained in the corresponding paragraph. 

12. Petitioner denies the allegations in the corresponding paragraph. 

 

 

CONCLUSION and REQUEST FOR RELIEF 

Wherefore, Respondent respectfully requests that this Honorable Tribunal dismiss the 

Petition in this matter and award attorney fees and costs to Respondent. 

Dated: July 7, 2026 

 

 

 

 

 

 

/s/Mary Beth Cobbs 

 

 

 

 

 

 

By: Mary Beth Cobbs ( P40080) 

 

 

 

 

 

 

Kevin C. Richard ( P 43417) 

 

 

 

 

 

 

Attorneys for Respondent 

 

 

 

 

 

 

City of Detroit Law Department 

 

 

 

 

 

 

2 Woodward Ave., Ste. 500 

 

 

 

 

 

 

Detroit, MI 48226

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AFFIRMATIVE DEFENSES 

 

NOW COMES Respondent, City of Detroit, and asserts the following Affirmative 

Defenses to the Petitioner’s claims: 

1. 

Petitioner’s lacks standing and/or capacity to bring forth this Petition. 

2. 

Petitioner’s claims may be barred by the applicable statute of limitations. 

3. 

This Tribunal lacks subject matter jurisdiction. 

 

4. 

Petitioner has failed to state a claim upon which relief can be granted. 

Wherefore, Respondent respectfully requests that this Honorable Tribunal dismiss the 

Petition in this matter and award attorney fees and costs to Respondent. 

Dated: 

July 7, 2026 

 

 

/s/Mary Beth Cobbs 

 

 

 

 

 

 

By: Mary Beth Cobbs ( P40080) 

 

 

 

 

 

 

Kevin C. Richard ( P 43417) 

 

 

 

 

 

 

Attorneys for Respondent 

 

 

 

 

 

 

City of Detroit Law Department 

 

 

 

 

 

 

2 Woodward Ave., Ste. 500 

 

 

 

 

 

 

Detroit, MI 48226 

 

 

 

 

 

 

313.237.3075 

 

 

 

 

 

 

cobbm@detroitmi.gov

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PROOF OF SERVICE 

 

On July 7, 2026, I mailed by first class mail a copy of Respondent’s Answer and Affirmative 

Defenses to: 

 

 

 

 

 

Brian E. Etzel, Esq. 

 

 

WILLIAMS, WILLIAMS, RATTNER & PLUNKETT, PC 

 

 

380 N. Old Woodward Ave, Ste. 300 

 

 

Birmingham, MI 48009 

 

 

 

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

belief. 

 

Dated: July 7,2026 

 

 

 

 

 

 /s/Mary Beth Cobbs 

 

 

 

 

 

 

Mary Beth Cobbs ( P40080) 

 

 

 

 

 

 

City of Detroit Law Department 

 

 

 

 

 

 

2 Woodward Ave., Ste. 500 

 

 

 

 

 

 

Detroit, MI 48226

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