Answer Signed.pdf
Zen Troy LLC, Petitioner Vs. City Of Troy, Respondent · 25-001938-TT
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STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL Zen Troy, LLC Petitioner, MTT Docket: 25-001938 \ Parcel ID 88-20-21-352-016 CITY OF TROY, Respondent. / SARAH R. BELLOLI LORI GRIGG BLUHM (P46908) RYAN TROY CITY ATTORNEY'S OFFICE Petitioner Representative Attorney for Respondent 101 W. Big Beaver Road 500 W. Big Beaver Road Suite 945 Troy, MI 48084 Troy, MI 48084 (248) 524-3320 (313) 230-0104 BluhmLG@TroyMi.gov Sarah.Belloli@Ryan.com RESPONDENT'S ANSWER TO PETITION NOW COMES, Respondent, CITY OF TROY, by and through its attorney, Lori Grigg Bluhm, and for its Answer to 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, No answer is required. 4. As to Paragraph 4, No answer is required.
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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. 9. 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 subject property's true cash and taxable values. 14. As to Paragraph 14, Respondent admits the allegation. 15. As to Paragraph 15, No answer is required. 16. 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, SEV, and taxable values for the subject property. 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, SEV, and taxable values for the subject property. 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 subject properties assessed and taxable values, subject to county and state equalization, and award Respondent its costs and attorney fees. Dated: July 2, 2025 Kt LL 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
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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 Respandent 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 property’s taxable value is improper, or failed to conform with the mode and method applied in the case of all properties in the City of Troy for 2025. . 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 property and established its 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. Dated: July 2, 2025 Sq =a Lori Grigg Bluhm (P46908) City of Troy pri Ss es Attorney for Defendant 500 W. Big Beaver Road Troy, MI 48084 (248) 524-3320 BluhmLG@troymi.gov Certificate of Service | hereby certify that on July 2, 2025, | 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, Troy Public Schools, 4400 Livernois Road, Troy MI 48098; 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, MI 48341 Dated: July 2, 2025 Led Zackary'R Trezona City of Troy Attorney’s Office 500 W. Big Beaver Road Troy, Ml 48084