25-002004-TT08098320250819122506.pdf

Medical Behavioral Hospital Of Mi LLC Dba Kalamazoo Bh Hospital, Petitioner Vs. Township Of Texas, Respondent · 25-002004-TT

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

MEDICAL BEHAVIORAL HOSPITAL 

OF MICHIGAN LLC, D/B/A KALAMAZOO 

BEHAVIORAL HEALTH HOSPITAL, 

Petitioner, 

MTT Docket No. 25-002004-TT 

\% 

TEXAS TOWNSHIP, 

Respondent. 

Jackie J. Cook (P68781) 

Robert E. Thall (P46421) 

Honigman LLP 

Bauckham, Thall, Seeber, 

Attorney for Petitioner 

Kaufman & Koches, P.C. 

39400 Woodward Ave., Ste. 101 

Attorney for Respondent 

Bloomfield Hills, MI 48304 

470 W. Centre Ave., Suite A 

248-566-8474 

Portage, MI 49024-5362 

jcook@honigman.com 

269-382-4500 

thall@michigantownshiplaw.com 

ANSWER TO PETITION WITH AFFIRMATIVE DEFENSES 

Respondent, Texas Township states the following in response to the respective paragraphs 

of the Petition filed in this matter: 

1. 

In answer to paragraph 

1 of the Petition, Respondent admits the allegation therein. 

2. 

In answer to paragraph 2 of the Petition, Respondent admits the allegation therein. 

3. 

In answer to paragraph 3 of the Petition, Respondent admits the allegation therein.

8. 

In answer to paragraph 8 of the Petition, Respondent admits the allegation therein. 

9. 

In answer to paragraph 9 of the Petition, Respondent admits the allegations therein. 

10. 

In answer to paragraph 10 of the Petition, Respondent admits that the Petitioner has 

raised the issues identified therein. 

11. 

In answer 

to paragraph 

11 

of the Petition, Respondent lacks knowledge 

or 

information sufficient to form a belief about the truth of the allegations therein. 

12. 

In answer 

to paragraph 

12 

of the Petition, Respondent lacks knowledge 

or 

information sufficient to form a belief about the truth of the allegations therein. 

13. 

Inanswer to paragraph 13 of the Petition, Respondent admits the allegation therein. 

14. 

In answer to paragraph 14 (a) through (d) of the Petition, Respondent denies the 

allegations therein as untrue. 

WHEREFORE, Respondent respectfully request that the Tribunal enter an Order denying 

the relief requested by Petitioner and uphold and affirm the valuation as established by the 

Respondent and require Petitioner to pay Respondent’s costs and attorney fees. 

AFFIRMATIVE DEFENSES 

Please take notice that Respondent may rely on one or more of the following affirmative 

defenses: 

1. 

Petitioner has failed to state a claim upon which relief may be granted. 

2. 

The Tribunal lacks jurisdiction over Petitioner and/or the subject property. 

3. 

The service of process was insufficient.

5. 

Respondent reserves the right to file such additional affirmative defenses as may become 

apparent pursuant to discovery procedures during the pendency of this matter. 

WHEREFORE Respondent requests that the Tribunal enter a determination of no cause in 

its favor, and such other and further relief as is appropriate including costs and attorney fees. 

Respectfully submitted, 

BAUCKHAM, THALL, SEEBER, 

KAUFMAN & KOCHES, P.C. 

Date: August 19, 2025 

By: 

/s/ Kobert 

£ Thal 

Robert E. Thall 

Attorney for Respondent

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

MEDICAL BEHAVIORAL HOSPITAL 

OF MICHIGAN LLC, D/B/A KALAMAZOO 

BEHAVIORAL HEALTH HOSPITAL, 

Petitioner, 

MTT Docket No. 25-002004-TT 

Vv 

TEXAS TOWNSHIP, 

Respondent. 

Jackie J. Cook (P68781) 

Robert E. Thall (P46421) 

Honigman LLP 

Bauckham, Thall, Seeber, 

Attorney for Petitioner 

Kaufman & Koches, P.C. 

39400 Woodward Ave., Ste. 101 

Attorney for Respondent 

Bloomfield Hills, MI 48304 

470 W. Centre Ave., Suite A 

248-566-8474 

Portage, MI 49024-5362 

jcook@honigman.com 

269-382-4500 

thall@michigantownshiplaw.com 

APPEARANCE 

The 

law 

firm 

of Bauckham, 

Thall, 

Seeber, Kaufman 

& 

Koches, 

P.C., 

enters 

this 

appearance for and on behalf of Respondent, Texas Township, in this matter. 

Respectfully submitted, 

BAUCKHAM, THALL, SEEBER, 

KAUFMAN & KOCHES, P.C.

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

MEDICAL BEHAVIORAL HOSPITAL 

OF MICHIGAN LLC, D/B/A KALAMAZOO 

BEHAVIORAL HEALTH HOSPITAL, 

Petitioner, 

MTT Docket No. 25-002004-TT 

\Y% 

TEXAS TOWNSHIP, 

Respondent. 

Jackie J. Cook (P68781) 

Robert E. Thall (P46421) 

Honigman LLP 

Bauckham, Thall, Seeber, 

Attorney for Petitioner 

Kaufman & Koches, P.C. 

39400 Woodward Ave., Ste. 101 

Attorney for Respondent 

Bloomfield Hills, MI 48304 

470 W. Centre Ave., Suite A 

248-566-8474 

Portage, MI 49024-5362 

jcook@honigman.com 

269-382-4500 

thall@michigantownshiplaw.com 

PROOF OF SERVICE 

Sandra L. Bosse states that on August 19, 2025, she served a copy of an Appearance, 

Answer to Petition with Affirmative Defenses and Proof of Service in this matter by first-class 

mail, postage fully prepaid, upon the representative for Petitioner at the address shown above. 

A, a, 

Sandra L. Bosse

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