Full record / 26000714 Pontiac Answer - VAB Senior Limited Dividend Housing Association.pdf

26000714 Pontiac Answer - VAB Senior Limited Dividend Housing Association.pdf

Vab Senior Ltd Dividend Housing Assn Petitioner Vs. City Of Pontiac Respondent · 26-000714-TT

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Page 1

CLARKHILL\18836\1032826\288855282.v1-8/7/26 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

 

MTT Docket No. 26-000714 

 

 

Parcel No. 64-19-05-102-010 

 

VAB SENIOR LTD DIVIDEND HOUSING 

ASSOCIATION, 

 

Petitioner, 

v 

 

CITY OF PONTIAC, 

 

Respondent.

 

 

 

 

 

 

 

 

 

/

 

Laura M. Hallahan (P42101) 

HALLAHAN & ASSOCIATES, P.C. 

Representative for Petitioner 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302-0179 

(248) 731-3090 

lhallahan@hallahanlaw.com 

 

 

Elizabeth White McDonnell (P62561) 

Sean P. Fitzgerald (P60654) 

CLARK HILL PLC 

Attorneys for Respondent 

200 Ottawa Avenue NW, Suite 500 

Grand Rapids, MI 49503 

(616) 608-1131 

ewhitemcdonnell@clarkhill.com 

sfitzgerald@clarkhill.com

 

/

 

RESPONDENT’S ANSWER TO PETITION 

Respondent, City of Pontiac, by and through its attorneys, Clark Hill PLC, hereby answers 

the Petition filed by Petitioner, VAB Senior Limited Dividend Housing Association, and states as 

follows: 

1. 

Respondent admits the allegations in paragraph 1 of the Petition, as to Parcel 

Number, Address, Classification, County and School District. As to use of the property, 

Respondent lacks the knowledge or information to form a belief as to the truth of that allegation. 

2. 

Respondent lacks the knowledge or information to form a belief as to the truth of 

the allegations contained in paragraph 2 of the Petition. 

3. 

Respondent admits the allegations in paragraph 3 of the Petition.

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CLARKHILL\18836\1032826\288855282.v1-8/7/26 

4. 

Respondent lacks the knowledge or information to form a belief as to the truth of 

the allegations contained in paragraph 4 of the Petition. 

5. 

Respondent lacks the knowledge or information to form a belief as to the truth of 

the allegations contained in paragraph 5 of the Petition. 

6. 

Respondent lacks the knowledge or information to form a belief as to the truth of 

the allegations contained in paragraph 6 of the Petition. 

7. 

Respondent admits the allegations in paragraph 7 of the Petition. 

8. 

Respondent admits that the values set by Respondent’s Board of Review are: 

TCV 

AV 

TV 

14,555,360 

7,277,680 

7,115,440 

 

9. 

Respondent denies the allegations in paragraph 9 of the Petition as untrue. 

10. 

Respondent denies the allegations in paragraph 10 of the Petition as untrue. 

11. 

Respondent denies the allegations in paragraph 11 of the Petition as untrue. 

WHEREFORE, Respondent respectfully requests that the Tribunal dismiss the Petition, 

sustain the assessed, taxable and true cash values with respect to the property as established by 

Respondent, award the costs and fees, including attorneys’ fees, incurred by Respondents in the 

defense of this matter, and grant such other and further relief as the Tribunal deems just and proper. 

 

 

 

 

 

 

Dated: August 7, 2026 

Respectfully submitted, 

 

CLARK HILL PLC 

 

 

By: 

 

 

 

 

 

 

 

Elizabeth White McDonnell (P62561) 

 

Sean P. Fitzgerald (P60654) 

Attorneys for Respondent

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CLARKHILL\18836\1032826\288855282.v1-8/7/26 

AFFIRMATIVE DEFENSES TO PETITIONER’S PETITION 

NOW COMES Respondent, City of Pontiac, by and through its attorneys, Clark Hill PLC, 

and hereby offers the following Affirmative Defenses to Petitioner’s Petition as follows: 

1. 

Petitioner fails to allege specific and sufficient facts to set forth a cause of action 

against Respondent and to support its claim of relief. 

2. 

Respondent has properly and lawfully classified Petitioner’s property and 

established its taxable and assessed value in accordance with local ordinances, state regulations, 

statutory and constitutional requirements. 

3. 

Respondent reserves the right to add other affirmative defenses as they become 

known. 

 

 

 

 

 

 

 

Dated: August 7, 2026 

Respectfully submitted, 

 

CLARK HILL PLC 

 

 

By: 

 

 

 

 

 

 

 

Elizabeth White McDonnell (P62561) 

 

Sean P. Fitzgerald (P60654) 

Attorneys for Respondent

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CLARKHILL\18836\1032826\288855281.v1-8/7/26 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

________________________________________________ 

 

 

 

MTT Docket No. 26-000714 

 

 

Parcel No. 64-19-05-102-010 

 

VAB SENIOR LTD DIVIDEND HOUSING 

ASSOCIATION, 

 

Petitioner, 

v 

 

CITY OF PONTIAC, 

 

Respondent.

 

 

 

 

 

 

 

 

 

/

 

Laura M. Hallahan (P42101) 

HALLAHAN & ASSOCIATES, P.C. 

Representative for Petitioner 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302-0179 

(248) 731-3090 

lhallahan@hallahanlaw.com 

 

Elizabeth White McDonnell (P62561) 

Sean P. Fitzgerald (P60654) 

CLARK HILL PLC 

Attorneys for Respondent 

200 Ottawa Avenue NW, Suite 500 

Grand Rapids, MI 49503 

(616) 608-1131 

ewhitemcdonnell@clarkhill.com 

sfitzgerald@clarkhill.com

 

/

 

APPEARANCE 

Clark Hill PLC hereby enters its Appearance on behalf of Respondent, City of Pontiac. 

 

 

 

 

 

 

 

Dated: August 7, 2026 

Respectfully submitted, 

 

CLARK HILL PLC 

 

 

By: 

 

 

 

 

 

 

 

Elizabeth White McDonnell (P62561) 

 

Sean P. Fitzgerald (P60654) 

Attorneys for Respondent

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CLARKHILL\18836\1032826\288973945.v1-8/7/26 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

________________________________________________ 

 

 

 

MTT Docket No. 26-000714 

 

 

Parcel No. 64-19-05-102-010 

 

VAB SENIOR LTD DIVIDEND HOUSING 

ASSOCIATION, 

 

Petitioner, 

v 

 

CITY OF PONTIAC, 

 

Respondent.

 

 

 

 

 

 

 

 

 

/

 

Laura M. Hallahan (P42101) 

HALLAHAN & ASSOCIATES, P.C. 

Representative for Petitioner 

1750 S. Telegraph Road, Suite 202 

Bloomfield Hills, MI 48302-0179 

(248) 731-3090 

lhallahan@hallahanlaw.com 

 

Elizabeth White McDonnell (P62561) 

Sean P. Fitzgerald (P60654) 

CLARK HILL PLC 

Attorneys for Respondent 

200 Ottawa Avenue NW, Suite 500 

Grand Rapids, MI 49503 

(616) 608-1131 

ewhitemcdonnell@clarkhill.com 

sfitzgerald@clarkhill.com

 

/

 

PROOF OF SERVICE 

The undersigned certifies that on the date below, a copy of Respondent’s Answer to Petition 

and Appearance was served via electronic mail, upon: 

Laura M. Hallahan 

lhallahan@hallahanlaw.com 

 

 

 

Date: August 7, 2026 

 

 

 

/s/ Bailey Dettloff 

 

 

 

 

 

 

 

 

 

 

Bailey Dettloff

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