Respondent City of Jackson - Answer and Affirmative Defenses w POS.pdf

Jackson Properties LLC Petitioner Vs. City Of Jackson Respondent · 26-000695-TT

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

______________________________________________________________________________ 

 

Jackson Properties, LLC, 

 

 

 

 

Petitioner, 

 

 

MTT Docket No. 26-000695 

 

 

 

 

 

 

 

Parcel No. 2-1742.0100 

 

 

 

 

 

 

 

 

 2-1737.5000 

 

 

-vs- 

 

 

 

 

 

ANSWER TO PETITION AND 

 

 

 

 

 

 

 

AFFIRMATIVE DEFENSES 

City of Jackson, 

 

 

 

 

 

 

 

 

 

 

 

Respondent. 

 

 

_____________________________________________________________________________/ 

WILLIAMS, WILLIAMS, RATTNER 

& PLUNKETT, PC 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

Attorneys for Petitioner 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI. 48009 

(248)642-0333 

 

JACKSON CITY ATTORNEY’S OFFICE 

By: Matthew M. Hagerty (P66015) 

Mark M. Porterfield (P57917) 

Attorneys for Respondent 

161 W. Michigan Avenue 

Jackson, MI 49201 

(517) 788-4050 

mhagerty@cityofjackson.org 

mporterfield@cityofjackson.org 

____________________________________________________________________________/ 

 

RESPONDENT CITY OF JACKSON’S 

ANSWER TO PETITION 

 

NOW COMES Respondent, City of Jackson, by and through its attorneys, the City 

Attorney’s Office, and for its Answer to Petitioner’s Petition, states as follows: 

1. Respondent neither admits nor denies the allegation contained in Paragraph 1 of 

Petitioner’s Petition and leaves Petitioner to its strict proofs. 

2. Respondent admits the allegation contained in Paragraph 2 of Petitioner’s Petition. 

3. Respondent admits the allegations contained in Paragraph 3 of Petitioner’s Petition. 

4. Respondent admits the allegations contained in Paragraph 4 of Petitioner’s Petition.

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5. Respondent admits the allegations contained in Paragraph 5 of Petitioner’s Petition. 

6. Respondent admits the allegations contained in Paragraph 6 of Petitioner’s Petition. 

7. Respondent admits the allegations contained in Paragraph 7 of Petitioner’s Petition. 

8. Respondent neither admits nor denies the allegation contained in Paragraph 8 of 

Petitioner’s Petition and leaves Petitioner to its strict proofs. 

9. Respondent neither admits nor denies the allegation contained in Paragraph 9 of 

Petitioner’s Petition and leaves Petitioner to its strict proofs. 

10. Respondent neither admits nor denies the allegation contained in Paragraph 10 of 

Petitioner’s Petition and leaves Petitioner to its strict proofs. 

11. Respondent denies the allegations contained in Paragraph 11 of Petitioner’s Petition as 

untrue. 

12. Respondent neither admits nor denies the allegation contained in Paragraph 12 of 

Petitioner’s Petition and leaves Petitioner to its strict proofs. 

WHEREFORE, Respondent requests this Honorable Tribunal dismiss Petitioner’s 

Petition in its entirety, that it assess actual costs and attorney fees against Petitioner for costs 

incurred in responding to the Petition, and further requests all other relief the Tribunal deems to 

be just and equitable. 

 

 

Respectfully submitted, 

 

 

 

 

 

 

 

DATED: June 26, 2026 

 

 

BY: ______________________________ 

 

 

 

 

 

 

 

MATTHEW M. HAGERTY (P66015) 

 

 

 

 

 

 

 

MARK M. PORTERFIELD (P57917) 

 

 

 

 

 

 

 

Office of the City Attorney 

 

 

 

 

 

 

 

City of Jackson, Michigan 

161 W. Michigan Ave. 

Jackson, MI 49201

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 AFFIRMATIVE DEFENSES 

NOW COMES Respondent, City of Jackson, by and through its attorneys, the City 

Attorney’s Office, and states the following Affirmative Defenses alternatively and consecutively: 

1. 

The subject property’s assessed, true cash, and taxable values are levied in 

accordance with the Michigan General Property Tax Act and Michigan Constitution. 

2. 

The subject property is assessed in accordance with generally accepted assessing 

standards. 

3. 

The subject property is assessed at no more than 50% of its true cash value. 

4. 

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

5. 

Respondent reserves the right to amend its affirmative defenses through the 

conclusion of discovery. 

Respectfully submitted, 

 

 

 

DATED: June 26, 2026 

 

 

BY: ______________________________ 

 

 

 

 

 

 

 

MATTHEW M. HAGERTY (P66015) 

 

 

 

 

 

 

 

MARK M. PORTERFIELD (P57917) 

 

 

 

 

 

 

 

Office of the City Attorney 

 

 

 

 

 

 

 

City of Jackson, Michigan 

161 W. Michigan Ave. 

Jackson, MI 49201

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CERTIFICATE OF SERVICE 

 

STATE OF MICHIGAN 

 

) 

) ss 

COUNTY OF JACKSON 

 

) 

 

The undersigned certifies under penalty of perjury that on June 26, 2026 he served copies of 

Respondent City of Jackson’s Answer to Petition and Affirmative Defenses upon the 

Petitioner by first class mail with postage fully prepaid to the following address: 

 

 

Jerome P. Pesick (P29039) 

Jason C. Long (P59244) 

Attorneys for Petitioner 

380 N. Old Woodward Ave., Ste. 300 

Birmingham, MI. 48009 

(248)642-0333 

 

 

 

 

 

 

 

 

 

 

 

 

 

DATED: June 26, 2026 

 

 

 

________________________________ 

 

Matthew M. Hagerty (P66015) 

 

Office of the City Attorney

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