Full record / Square Knot LLC MTT# 25-002191 answer.pdf

Square Knot LLC MTT# 25-002191 answer.pdf

Square Knot LLC, Petitioner Vs. City Of Detroit, Respondent · 25-002191-TT

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

SQUARE KNOT, LLC, 

 

Petitioner, 

v. 

Docket No. 25-002191 

 

CITY OF DETROIT, 

 

Respondent. 

 

/ 

 

ANSWER 

 

RESPONDENT, CITY OF DETROIT, for its Answer to the Petition filed in this matter 

states as follows: 

1. Respondent admits. 

 

2. Respondent admits. 

 

3. No response necessary. 

 

4. No response necessary. 

 

5. No response necessary. 

 

6. Respondent denies as untrue. The subject property is classified as residential. 

 

7. Upon information and belief, Petitioner did not file an appeal to the Board of Review as 

required by MCL 205.735a(3) 

8. Respondent asserts that this Honorable Tribunal does not have jurisdiction over this 

matter as Petitioner failed to file an appeal to the Board of Review as required by MCL 

205.735a(3). 

9. No response necessary. 

 

10. Respondent admits.

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11. Respondent admits. 

 

12. Respondent admits. 

 

13. Respondent admits only that Petitioner’s instant Tax Tribunal appeal alleges issues 

relating to true cash and taxable values, however, Respondent denies that any such 

allegation has merit. 

14. Respondent admits. 

 

15. No response necessary. 

 

16. Respondent admits. 

 

17. Respondent neither admits nor denies the allegation, there being an insufficient basis at 

this time upon which to form a belief as to the truth of the allegation. 

18. Based solely upon Petitioner’s unsubstantiated value contentions Respondent admits. 

19. Prayer for relief, no response necessary. 

20. Respondent denies as untrue. 

 

 

AFFIRMATIVE DEFENSES 

Respondent further asserts that Petitioner’s claims are barred, in whole or in part, by: 

 

1. Petitioner’s claims are barred by the applicable statute of limitations. 

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

 

3. Petitioner lacks standing. 

 

4. This Honorable Tribunal lacks jurisdiction over this matter.

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WHEREFORE, Respondent City of Detroit respectfully requests that this Honorable 

Tribunal dismiss the petition in this matter and award costs and attorney fees. 

Respectfully Submitted, 

 

/s/ Kevin C. Richard 

Kevin C. Richard (P43417) 

Mary Beth Cobbs (P40080) 

City of Detroit Law Department 

Coleman A. Young Municipal Center 

2 Woodward Avenue, Suite 500 

Detroit, Michigan 48226 

(313) 237-3061 

Dated: September 4, 2025

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

SQUARE KNOT, LLC, 

 

Petitioner, 

v. 

Docket No. 25-002191 

 

CITY OF DETROIT, 

 

Respondent. 

 

/ 

 

PROOF OF SERVICE 

 

On September 4, 2025, I mailed by first class mail a copy of Respondent’s Answer w/Affirmative 

Defenses in the instant matter to: 

 

Troy C. Otto 

Fischer, Franklin & Ford 

24725 W. 12 Mile Road, Suite 230 

Southfield, Michigan 48034 

 

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

 

 

/s/ Kevin C. Richard 

Kevin C. Richard (P43417) 

Senior Assistant Corporation Counsel 

City of Detroit Law Department 

Coleman A. Young Municipal Center 

2 Woodward Avenue, Suite 500 

Dated: September 4, 2025 

Detroit, Michigan 48226

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