311 Grand River LLC MTT# 26-001228 answer.pdf
311 Grand River LLC Petitioner Vs. City Of Detroit Respondent · 26-001228-TT
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1 STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL 311 GRAND RIVER LLC, Petitioner, v. Docket No. 26-001228 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 to parcel identification only, as to the remainder of the averment Respondent denies as untrue. Specifically, the address for the subject parcels is 267 E. Grand River. 2. Respondent admits. 3. Respondent admits. 4. Respondent admits. 5. Respondent admits only that Petitioner’s instant Tax Tribunal appeal alleges issues involving valuation, assessment, taxable value and uniformity, however, Respondent denies that any such allegations have merit. 6. 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. 7. Respondent denies as untrue.
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2 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. 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 15, 2026
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3 STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL 311 GRAND RIVER LLC, Petitioner, v. Docket No. 26-001228 CITY OF DETROIT, Respondent. / PROOF OF SERVICE On September 15, 2026, I mailed by first class mail a copy of Respondent’s Answer with Affirmative Defenses in the instant matter to: Aaron Fales Law Offices of Aaron Fales, P.C. 330 Hamilton Row, Suite 350 Birmingham, Michigan 48226 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 15, 2026 Detroit, Michigan 48226