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Answer Grand Time Square 25-002226.pdf

Grand Time Square LLC, Petitioner Vs. City Of Detroit, Respondent · 25-002226-TT

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

GRAND TIME SQUARE LLC 

 

 

Petitioner 

 

 

v 

CITY OF DETROIT, 

 

 

 

Docket No. 25-002226 MTT 

Respondent. 

________________________________________________________________________________/ 

ANSWER TO PROPERTY TAX PETITION 

 Respondent, City of Detroit, by and through it undersigned counsel and for its Answer to this 

Petition states the following: 

1. Respondent, City of Detroit, admits as true the allegation in the corresponding paragraph. 

2. Respondent admits as true. 

3. No response is required to the allegations in the corresponding paragraph. 

4. No response is required to the allegations in the corresponding paragraph. 

5. No response is required. 

6. Respondent admits as true. 

7. No response is required. 

8. No response is required to the allegations in the corresponding paragraph. 

9. No response is required to the allegations in the corresponding paragraph. 

10. Respondent admits as true. 

11. Respondent admits as true.

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12. Respondent admits as true. 

13. Respondent admits that the issues involved in this appeal are related to (a) true cash and 

(b) taxable value, but further states that these allegations lack merit. 

14. Respondent admits as true. 

15. Respondent states that no response is required to the allegations in the corresponding 

paragraph. 

16. Respondent admits as true. 

17. Respondent, City of Detroit, neither admits nor denies as Respondent lacks sufficient 

knowledge or information to form a belief as to the truth of the allegations and leaves 

Petitioner to its proofs. 

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

19. Respondent admits that Petitioner’s appeal is challenging and seeking a reduction in the 

true cash value and the taxable value imposed upon the Subject Property, but leaves 

Petitioner to its proofs as to the relief requested by Petitioner. 

20. Respondent, leaves Petitioner to its proofs to establish the basis for the relief sought in 

this appeal. 

Wherefore, Respondent respectfully requests that this Honorable Tribunal dismiss the 

Petition in this matter and award attorney fees and costs to Respondent. 

Dated: 10/22/2025 

 

 

 

 

 

 

/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

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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: 10/22/2025 

/s/Mary Beth Cobbs 

 

 

 

 

 

 

By: Mary Beth Cobbs ( P40080) 

 

 

 

 

 

 

Kevin C. Richard ( P43417) 

 

 

 

 

 

 

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 

 

GRAND TIME SQUARE LLC 

 

Petitioner, 

 

 

 

 

 

v 

CITY OF DETROIT, 

 

 

 

Docket No. 25-002226 -MTT 

Respondent. 

 

_______________________________________________________________________ 

PROOF OF SERVICE 

 

On 10/22/2025, I mailed by first class mail a copy of Respondent’s Answer and Affirmative 

Defenses to: 

 

 

 

 

 

 

 

The Victor Firm 

 

 

 

29777 Telegraph Road, Suite 2410 

 

 

 

Southfield, MI 48034 

 

 

 

 

 

 

 

 

 

 

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

belief. 

 

Dated: October 22,2025 

 

 

 

 

 

 

/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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