Answer and Affirmative Defenses.pdf
1071 Rochester LLC Petitioner Vs. City Of Troy Respondent · 26-001273-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
STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL 1071 ROCHESTER LLC, Petitioner, MTT Docket: 26-001273 \ Parcel ID 88-20-34-201-025 CITY OF TROY, Respondent. / BRIAN E. ETZEL (P54905) LORI GRIGG BLUHM (P46908) WILLIAMS, WILLIAMS, RATTNER JULIE QUINLAN DUFRANE (P59000) & PLUNKETT, P.C. TROY CITY ATTORNEY'S OFFICE Attorneys for Petitioner Attorneys for Respondent 380 N. Old Woodward Ave. 500 W. Big Beaver Road Suite 300 Troy, MI 48084 Birmingham, MI 48009 (248) 524-3320 (248) 642-0333 BluhmLG@TroyMl.gov Bee@Wwrplaw.com / RESPONDENT'S ANSWER TO PETITION AND AFFIRMATIVE DEFENSES 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,
Page 2
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 the true cash value, assessed value, or taxable value for the subject property. 10. As to Paragraph 10, Respondent denies that there are any viable issues regarding the valuation of the Subject Property. Respondent neither admits nor denies the remainder of the allegations, and leaves Petitioner to its proofs. 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: August 13, 2026 "WF 2 LORI GRIGG'BLUHM (P46908)
Page 3
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
Page 4
Dated: August 13, 2026 be TROY LORI GRIGG BLUHM (P46908) Attorney for Respondent 500 W. Big Beaver Road Troy, MI 48084 (248) 524-3320 BluhmLG@TroyMIl.gov Certificate of Service | hereby certify that on August 13, 2026, | served a copy of this Answer and Affirmative Defenses to the following: Petitioner's Attorney Brian Etzel via email at: Bee@wwrplaw.com; and via first class mail: Michigan Department of Treasury, State Treasurer, 430 W. Allegan, Lansing, MI 49822; Secretary of School Board, Troy Public Schools, 4400 Livernois Road, Troy, MI 48098; 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: August 13, 2026 CITY OF TROY lO Clara Réid Legal Administrative Coordinator