Full record / Answer Gratiot Investment LLC.pdf

Answer Gratiot Investment LLC.pdf

Gratiot Investment, LLC Petitioner Vs. City Of Detroit Respondent · 26-001031-TT

← View full record

Text extracted from the reviewed PDF, organized by page. OCR and reading order may contain errors; confirm details in the PDF below.

Page 1

1 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

GRATIOT INVESTMENT LLC 

 

Petitioner, 

 

 

 

 

 

v 

CITY OF DETROIT, 

 

 

 

Docket No. 26- 001031 

 

Respondent 

 

 

 

 

Parcel No. 21028711-4 

____________________________________________________________________________/ 

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 neither admits nor denies as Respondent lacks specific knowledge, and 

therefore and therefore denies these allegations. 

3. Respondent admits as true. 

4. Respondent admits as true. 

5. Respondent admits as true. 

6. Respondent admits as true that this appeal involves issues of the property’s true cash 

and taxable values, but denies that these values as set by the Respondent are violative 

of the Michigan Constitution or the statues of the State of Michigan. 

7. Respondent admits as true.

Page 2

2 

 

8. Respondent neither admits nor denies as Respondent lacks specific knowledge, and 

therefore and therefore denies these allegations. 

9. Respondent admits as true as to the values established by Respondent’s Board of 

Review. 

10. Respondent neither admits nor denies as Respondent lacks specific knowledge, and 

therefore and therefore denies these allegations. 

11. Respondent admits. 

12. Respondent requests that this Honorable Tribunal deny Petitioner’s request for relief. 

13. Respondent denies as untrue. 

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: September 16, 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

Page 3

3 

 

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 16, 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

Page 4

4 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

GRATIOT INVESTMENT, LLC 

 

Petitioner, 

 

 

 

 

 

v 

CITY OF DETROIT, 

 

 

 

Docket No. 26- 001031 

 

Respondent 

 

 

 

 

Parcel No. 21028711-4 

____________________________________________________________________________/ 

 

PROOF OF SERVICE 

 

On September 16, 2026, I mailed by first class mail, a copy of Respondent’s Answer and 

Affirmative Defenses to: 

 

 

 

Law Office of Peter Ellenson, P.C. 

 

 

 

Peter Ellenson 

 

 

 

30500 Northwestern Highway, Suite 500 

Farmington Hills, MI 48334 

 

 

 

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

belief. 

 

Dated: September 16, 2026 

 

 

 

 

 

 /s/Mary Beth Cobbs 

 

 

 

 

 

 

Mary Beth Cobbs ( P40080) 

 

 

 

 

 

 

City of Detroit Law Department 

 

 

 

 

 

 

2 Woodward Ave., Ste. 500 

 

 

 

 

 

 

Detroit, MI 48226

PDF reading copy

← View full record