Resp Answer Affirm Defense POS Orion Twp 26-000446-TT.pdf

Asht Laxmi LLC Petitioner Vs. Township Of Orion Respondent · 26-000446-TT

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

ASHT LAXMI LLC, 

 

 

Petitioner, 

 

 

 

 

 

MTT Docket No.: 26-000446-TT 

 

 

 

 

 

Parcel No.: O-09-23-402-012, 

 

 

 

 

 

and additional parcels 

 

v. 

 

 

 

 

 

 

 

 

 

CHARTER TOWNSHIP OF ORION, 

Respondent. 

_____________________________________________________________________________ 

Laura M. Hallahan (P42101) 

 

 

Zachary Learman (P71005) 

HALLAHAN LAW 

 

 

 

Daniel J. Kelly (P41315) 

Attorney for Petitioner 

 

 

 

THE KELLY FIRM, PLC 

1750 S. Telegraph Rd. Ste 202 

 

 

Attorneys for Respondent 

Bloomfield Hills, MI 48302 

 

 

512 E. 11 Mile Rd 

(248) 731-3089 

 

 

 

 

Royal Oak, MI 48067 

lhallahan@hallahanlaw.com 

 

 

(248) 655-7025 

 

 

 

 

 

 

 

zack@kellyfirmpc.com 

 

 

 

 

 

 

 

dan@kellyfirmpc.com 

 

RESPONDENT’S ANSWER TO PETITION, 

AFFIRMATIVE DEFENSES, AND PROOF OF SERVICE 

 

 

NOW COMES the Respondent, CHARTER TOWNSHIP OF ORION, by its attorneys, 

THE KELLY FIRM, PLC, and for its answer to the Entire Tribunal Property Tax Petition, states 

as follows: 

1. In response to paragraph 1, Respondent neither admits nor denies same for lack of 

sufficient information and leave Petitioner to its proofs. 

2. In response to paragraph 2, Respondent neither admits nor denies same for lack of 

sufficient information and leave Petitioner to its proofs. 

3. In response to paragraph 3, Respondent admits the allegations contained therein.

4. In response to paragraph 4, Respondent admits the allegations contained therein. 

5. In response to paragraph 5, Respondent neither admits nor denies same for lack of 

sufficient information and leave Petitioner to its proofs. 

6. In response to paragraph 6, Respondent neither admits nor denies same for lack of 

sufficient information and leave Petitioner to its proofs. 

7. In response to paragraph 7, Respondent admits the allegations contained therein. 

8. In response to paragraph 8, Respondent neither admits nor denies same for lack of 

sufficient information and leave Petitioner to its proofs. 

9. In response to paragraph 9, Respondent neither admits nor denies same for lack of 

sufficient information and leave Petitioner to its proofs. 

10. In response to paragraph 10, Respondent neither admits nor denies same for lack of 

sufficient information and leave Petitioner to its proofs. 

AFFIRMATIVE DEFENSES 

NOW COMES the Respondent, CHARTER TOWNSHIP OF ORION, by its 

attorneys, THE KELLY FIRM, PLC, and files the following Affirmative Defenses in 

support of its Answer to the Petition: 

1. The facts as alleged by the Petitioner do not establish mutual mistake of fact. 

2. Petitioner has failed to allege specific and sufficient facts upon which the mode 

and method of appraising property fails to conform with mode and method applied to 

all other properties in the community. 

3. Petitioner has failed to show that any fact other than fifty percent (50%) was 

applied to the true cash value of the property.

4. Petitioner’s claim, if prevailed upon, would create a windfall for Petitioner and 

create a burden upon the Township, schools, County taxes, and other property owners 

in the community. 

5. Petitioner is asking this Honorable Tribunal to make an underassessment based 

upon an arbitrary basis. 

6. A levy of all taxes is required to be made based upon the assessment of fifty 

percent (50%) of true cash value as ultimately determined by the process of County 

and State equalization. 

7. Respondent reserves the right to file additional Affirmative Defenses as may 

become apparent in this case. 

 

 

 

 

 

 

 

THE KELLY FIRM, PLC 

 

 

 

 

 

 

 

 

Respectfully submitted, 

 

 

Dated: July 21, 2026 

 

 

 

/s/ Zachary Learman 

 

 

 

 

 

 

 

 

Zachary Learman (P71005) 

 

 

 

 

 

 

 

Attorney for Plaintiff 

 

 

 

 

 

 

 

512 E. Eleven Mile Rd 

Royal Oak, Michigan 48067 

(248) 655-7025 

 

 

 

 

 

 

 

zack@kellyfirmpc.com 

 

 

 

PROOF OF SERVICE 

 

 

The undersigned states that on July 21, 2026, she electronically filed Appearance, 

Respondent's Answer to Petition, Affirmative Defenses, and this Proof of Service with the 

Michigan Tax Tribunal via the Tribunal's E-filing System and served a copy upon Representative 

for Petitioner via electronic mail to Petitioners address at lhallahan@hallahanlaw.com. 

 

 

 

/s/ Julian Slavsky 

 Julian Slavsky

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