Respondent Answer and Affirmative Defenses.pdf

Lreh California, LLC, Petitioner Vs. City Of Troy Respondent · 26-000872-TT

← View full record

Text extracted from the reviewed PDF, organized by page. OCR and reading order may contain errors; confirm details in the PDF below.

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

LREH California, LLC, 

Petitioner, 

MTT Docket: 26-000872 

\ 

Parcel ID 88-20-06-353-005 

CITY OF TROY, 

Respondent. 

/ 

JEROME P. PESICK (P29039) 

LORI GRIGG BLUHM (P46908) 

JASON C. LONG (P59244) 

JULIE QUINLAN DUFRANE (P59000) 

WILLIAMS WILLIAMS RATTNER 

TROY CITY ATTORNEY'S OFFICE 

& PLUNKETT, P.C. 

Attorneys for Respondent 

Attorneys for Petitioner 

500 W. Big Beaver Road 

380 N. Old Woodward Ave. 

Troy, Ml 48084 

Suite 300 

(248) 524-3320 

Birmingham, Mi 48009 

BluhmLG@TroyMl.gov 

(248) 642-0333 

j.dufrane@troymi.gov 

RESPONDENT'S ANSWER TO PETITION 

NOW COMES, Respondent, CITY OF TROY, by and through its attorney, Lori Grigg 

Bluhm, and for its Answer to Petitioner's Petition, states as follows: 

1. 

As to Paragraph 1, Respondent neither admits nor denies the allegations, lacking 

knowledge or information sufficient to form a belief as to the truth of the allegations and, 

therefore, leaves Petitioner to its proofs. 

2. 

As to Paragraph 2, Respondent admits.

4, 

As to Paragraph 4, Respondent denies. The subject property is located in the 

Bloomfield Hills School District, which is in Oakland County, Michigan. 

5. 

As to Paragraph 5, Respondent admits. 

6. 

As to Paragraph 6, Respondent admits that the classification of the property 

is commercial-office. 

7. 

As to Paragraph 7, Respondent admits. 

8. 

As to Paragraph 8, Respondent denies that Petitioner has any support for its 

conclusions as to its alleged true cash value, assessed value or taxable value for the subject 

property. 

9. 

As to Paragraph 9, Respondent doesn’t challenge Petitioner's calculation, but 

denies that Petitioner has any support for its conclusions as to its true cash value, assessed 

value, or taxable value for the subject property. 

10. 

As to Paragraph 10, no response is required. 

11. 

As to Paragraph 11, Respondent denies the allegations, since they are untrue. 

12. 

As to Paragraph 12, Respondent admits that the 2026 assessment is uniform, 

and denies the remainder of the allegations. 

WHEREFORE, Respondent, CITY OF TROY, requests the Tribunal dismiss the 

Petition, affirm or increase Respondent's assessed and taxable values, subject to county and 

state equalization, and award Respondent its costs and attorney fees. 

Dated: July 14, 2026 

Fa rca

AFFIRMATIVE DEFENSES 

For its further Answer to Petitioner's Petition, Respondent relies on the following 

Affirmative Defenses: 

1. 

Petitioner fails to allege specific and sufficient facts to set forth a cause of action 

against Respondent and to support its claim for relief. 

2. 

Petitioner fails to allege specific and sufficient facts to establish fraud, error of 

law, discrimination, application of wrong principles or illegality on the part of the Respondent or 

its agents. 

3. 

Petitioner fails to allege specific and sufficient facts to establish the true cash 

value, assessed value, and taxable value of its property. 

4. 

Petitioner fails to allege specific and sufficient facts to support its allegations that 

the property’s taxable value is improper, or failed to conform with the mode and method 

applied in the case of all properties in the City of Troy for 2026. 

5. 

Any decrease in the value of Petitioner's property was a result of its own 

intentional acts and/or negligence and cannot be allowed to reduce Petitioner's otherwise 

equitable tax burden. 

6. 

Respondent has properly and lawfully assessed Petitioner's property and 

established its taxable value in accordance with statutory and constitutional requirements. 

7. 

Respondent reserves the right to argue additional Affirmative Defenses during 

the pendency of this action.

Dated: July 14, 2026 

OF TROY 

[LENS 

LORI GRIGG BLUHM (P46908) 

Attorney for Respondent 

500 W. Big Beaver Road 

Troy, MI 48084 

(248) 524-3320 

BluhmLG@TroyMI.gov 

Certificate of Service 

I hereby certify that on July 14, 2026, 

| served a copy of this Answer and Affirmative 

Defenses to the following: 

Petitioner's Attorney Jerome Pesick via email at: 

JPesick@WWRPLaw.com; and via first class mail: Michigan Department of Treasury, State 

Treasurer, 430 W. Allegan, Lansing, MI 49822; Secretary of School Board, Bloomfield Hills 

Schools, 7273 Wing Lake Road, Bloomfield Hills, MI 48301; Director of Equalization; 

Oakland Pointe Office Building, 250 Elizabeth Lake Road Suite 1000; Pontiac, MI 48341; and 

Clerk, Oakland County; 1200 N. Telegraph, Building 12 East, Pontiac, MI 48341. 

Dated: July 14, 2026 

CITY OF TROY 

(15 

Clara Reid 

} 

Legal Administrative Coordinator 

500 W. Big Beaver Road 

Troy, MI 48084 

(248) 524-3320

← View full record