Answer Clinton Detroit 26-001116.pdf
Clinton Detroit LLC Petitioner Vs. City Of Detroit Respondent · 26-001116-TT
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1 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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2 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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3 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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4 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