Answer John Ziraldo 26-001565.pdf
John Ziraldo, Monica Ziraldo Petitioners Vs. City Of Detroit Respondent · 26-001565-TT
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1 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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2 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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3 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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4 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