Full record / Answer John Ziraldo 26-001565.pdf

Answer John Ziraldo 26-001565.pdf

John Ziraldo, Monica Ziraldo Petitioners Vs. City Of Detroit Respondent · 26-001565-TT

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 STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 JOHN ZIRALDO and MONICA ZIRALDO 

 

 

Petitioner, 

 

 

 

 

 

v 

CITY OF DETROIT, 

 

 

 

Docket No. 26-001565 

 

Respondent 

 

 

 

 

Parcel No. 06000002.050 and 

 

 

 

 

 

 

 

 06000002.053 

____________________________________________________________________________/ 

ANSWER TO PETITION and 

AFFIRMATIVE DEFENSES 

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

to the Petition filed in this matter states the following: 

1. Respondent, City of Detroit, admits as true. 

2. Respondent admits as true. 

3. Respondent admits as true. 

4. Respondent neither admits nor denies the allegations in the corresponding paragraph 

and leaves Petitioner to their proofs. 

5. No response is required. 

6. Respondent admits as true 

7. Respondent admits as true. 

8. Respondent admits that a formal protest was made to Respondent’s Board of review 

and Petitioner has attached to this petition correspondence from the Board of Review.

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9. No response is required to this paragraph. 

10. Respondent admits as true. 

11. Respondent admits as true. 

12. Respondent lacks knowledge or information sufficient to form a belief as to the truth 

of the allegations contained in this paragraph, and therefore denies these allegations. 

13. Respondent that this appeal contains issues of (a) valuation (b) assessment and (c) 

taxable value as it relates to the subject property, but further states that these 

allegations lack merit. 

14. Respondent admits as true. 

15. No response is required 

16. Respondent admits as true. 

17. Respondent neither admits nor denies as Respondent lacks specific knowledge 

regarding Petitioner claims of value, and therefore and therefore denies these 

allegations. 

18. Respondent admits as true. 

19. Respondent neither admits nor denies as Respondent lacks specific knowledge 

regarding any improper uncapping event, and therefore and therefore denies these 

allegations. 

20. Respondent admits that Petitioner has attached to their petition specific facts 

supporting the relief requested in this appeal. 

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.

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Dated: September 30, 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 

 

 

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: 

September 30, 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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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

JOHN ZIRALDO and MONICA ZIRALDO 

Petitioner, 

 

 

 

 

 

v 

CITY OF DETROIT, 

 

 

 

Docket No. 26-001565 

 

Respondent 

 

 

 

 

Parcel No. 06000002.050 and 

 

 

 

 

 

 

 

06000002.053 

____________________________________________________________________________/ 

 

PROOF OF SERVICE 

 

On September 30, 2026, I mailed by first class mail, a copy of Respondent’s Answer and 

Affirmative Defenses to: 

 

 

 

 

 

Joseph A. Peterson 

 

38505 Woodward Ave., Ste. 100 

 

Bloomfield Hills, MI 48304 

 

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

belief. 

 

Dated: September 30, 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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