Square Knot LLC MTT# 25-002191 answer.pdf
Square Knot LLC, Petitioner Vs. City Of Detroit, Respondent · 25-002191-TT
Text extracted from the reviewed PDF, organized by page. OCR and reading order may contain errors; confirm details in the PDF below.
Page 1
1 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.
Page 2
2 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.
Page 3
3 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
Page 4
4 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