Full record / Answer Clinton Detroit 26-001116.pdf

Answer Clinton Detroit 26-001116.pdf

Clinton Detroit LLC Petitioner Vs. City Of Detroit Respondent · 26-001116-TT

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DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

CLINTON DETROIT LLC 

 

Petitioner, 

 

 

 

 

 

v 

CITY OF DETROIT, 

 

 

 

Docket No. 26-001116 

 

Respondent. 

 

 

 

Parcel No. 1000216 

____________________________________________________________________________/ 

ANSWER TO PETITION and 

AFFIRMATIVE DEFENSES 

Now Comes Respondent, City of Detroit, by and through it undersigned counsel and in Answer 

to the Petition filed in this matter states the following: 

1. Respondent, City of Detroit, admits as true. 

2. Respondent admits as true. 

3. Respondent denies as untrue as there is only 1 parcel under appeal. 

4. No response is required. 

5. No response is required. 

6. Respondent admits as true. 

7. Respondent admits as true. 

8. No response is required. 

9. No response is required. 

10. Respondent admits as true. 

11. Respondent admits as true.

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12. Respondent, City of Detroit, neither admits nor denies and leaves Petitioner to its 

proofs. 

13. Respondent admits that that this appeal contains issues of the properties’ taxable 

value and true cash values as it relates to the subject property, but further states that 

these allegations lack merit. 

14. Respondent admits as true. 

15. No response is required. 

16. Respondent admits as true. 

17. Respondent, City of Detroit, neither admits nor denies and leaves Petitioner to its 

proofs. 

18. Respondent, City of Detroit, neither admits nor denies and leaves Petitioner to its 

proofs. 

19. Respondent respectfully requests that the Michigan Tax Tribunal deny Petitioner’s 

requests for relief and dismiss this petition or in the alternative grant any such other 

and further relief as is just and equitable. 

20. Respondent denies as untrue the allegations contained in sub-paragraphs a and b. 

CONCLUSION and REQUEST FOR RELIEF 

Wherefore, Respondent respectfully requests that this Honorable Tribunal dismiss the 

Petition in this matter and award attorney fees and costs to Respondent. 

Dated: September 10, 2026 

 

/s/Mary Beth Cobbs 

 

 

 

 

 

 

By: Mary Beth Cobbs ( P40080) 

 

 

 

 

 

 

Kevin C. Richard ( P 43417) 

 

 

 

 

 

 

Attorneys for Respondent 

 

 

 

 

 

 

City of Detroit Law Department 

 

 

 

 

 

 

2 Woodward Ave., Ste. 500 

 

 

 

 

 

 

Detroit, MI 48226

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AFFIRMATIVE DEFENSES 

 

NOW COMES Respondent, City of Detroit, and asserts the following Affirmative 

Defenses to the Petitioner’s claims: 

1. 

Petitioner lacks standing and/or capacity to bring forth this Petition. 

2. 

Petitioner’s claims may be barred by the applicable statute of limitations. 

3. 

This Tribunal lacks subject matter jurisdiction. 

 

4. 

Petitioner has failed to state a claim upon which relief can be granted. 

Wherefore, Respondent respectfully requests that this Honorable Tribunal dismiss the 

Petition in this matter and award attorney fees and costs to Respondent. 

Dated: 

September 10, 2026 

/s/Mary Beth Cobbs 

 

 

 

 

 

 

By: Mary Beth Cobbs ( P40080) 

 

 

 

 

 

 

Kevin C. Richard ( P 43417) 

 

 

 

 

 

 

Attorneys for Respondent 

 

 

 

 

 

 

City of Detroit Law Department 

 

 

 

 

 

 

2 Woodward Ave., Ste. 500 

 

 

 

 

 

 

Detroit, MI 48226 

 

 

 

 

 

 

313.237.3075 

 

 

 

 

 

 

cobbm@detroitmi.gov

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

CLINTON DETROIT LLC 

 

Petitioner, 

 

 

 

 

 

v 

CITY OF DETROIT, 

 

 

 

Docket No. 26-00116 

 

Respondent. 

 

 

 

Parcel No. 01000216 

____________________________________________________________________________/ 

 

PROOF OF SERVICE 

 

On September 10, 2026, I mailed by first class mail, a copy of Respondent’s Answer and 

Affirmative Defenses to: 

 

 

 

 

 

Sarah R. Belloli 

 

 

 

 

 

101 West Big Beaver Road, 

 

 

 

 

 

Suite 945 

 

 

 

 

 

Troy, MI 48084 

 

 

 

 

 

I declare that the above statement is true to the best of my information, knowledge, and 

belief. 

 

Dated: September 10, 2026 

 

 

 

 

 

 /s/Mary Beth Cobbs 

 

 

 

 

 

 

Mary Beth Cobbs ( P40080) 

 

 

 

 

 

 

City of Detroit Law Department 

 

 

 

 

 

 

2 Woodward Ave., Ste. 500 

 

 

 

 

 

 

Detroit, MI 48226

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