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Answer 26-001388-TT.pdf

Juniors Place LLC Petitioner Vs. Township Of East Bay Respondent · 26-001388-TT

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

 

JUNIORS PLACE LLC, 

 

 

 

Petitioner, 

 

 

 

MTT Docket No. 26-001388-TT 

 

V 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

EAST BAY CHARTER TOWNSIP, 

 

 

 

Respondent. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Aaron M. Fales (P72864) 

 

 

 

Robert E. Thall (P46421) 

Law Offices of Aaraon M. Fales, P.C. 

 

Bauckham, Thall, Seeber, 

Attorney for Petitioner 

 

 

 

Kaufman, & Koches, P.C. 

330 Hamilton Row, Ste. 350 

 

 

Attorney for Respondent 

Birmingham, MI 48009 

 

 

 

470 W. Centre Ave., Ste. A 

248-767-9840 

 

 

 

 

Portage, MI 49024 

afaleslaw@gmail.com 

 

 

 

269-382-4500 

 

 

 

 

 

 

 

thall@michigantownshiplaw.com 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

ANSWER TO PETITION WITH AFFIRMATIVE DEFENSES 

Respondent, East Bay Charter 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 allegations 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 allegations therein. 

4. 

In answer to paragraph 4 of the Petition, Respondent admits the allegations therein. 

5. 

In answer to paragraph 5 of the Petition, Respondent admits that the Petitioner has 

raised such issues.

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6. 

In answer to paragraph 6 of the Petition, Respondent denies the allegations therein 

as untrue. 

7. 

In answer to paragraph 7 of the Petition and its subparts, 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 valuations 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. 

4. 

The subject property is under assessed and/or the taxable value and/or state equalized value 

of the subject property is too low, and should therefore be appropriately increased to comply with 

the mandate of the applicable provisions of law. 

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.

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Respectfully submitted, 

 

 

 

 

 

BAUCKHAM, THALL, SEEBER, 

 

 

 

 

 

KAUFMAN, & KOCHES, P.C. 

 

 

Date: September 24, 2026 

 By: /s/ Robert E. Thall 

 

 

 

 

 

 Robert E. Thall (P46421) 

 

 Attorney for Respondent

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