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Answer and Affirmative Defenses.pdf

Federated Retail Holdings Petitioner Vs. City Of Troy Respondent · 26-001587-TT

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

FEDERATED RETAIL HOLDINGS, LLC 

Petitioner, 

MTT Docket No. 26-001587 

Parcel No. 88-20-20-351-005 

V. 

CITY OF TROY, 

Respondent. 

/ 

ELLEN G. BERKSHIRE 

LORI GRIGG BLUHM (P46908) 

VERROS BERKSHIRE 

JULIE Q. DUFRANE (P59000) 

Attorney for Petitioner 

TROY CITY ATTORNEY'S OFFICE 

15660 Midwest Road 

Attorneys for Respondent 

Suite 300 

500 W. Big Beaver Road 

Oakbrook Terrace, IL 60181 

Troy, MI 48084 

(312) 604-3810 

(248) 524-3320 

EBerkshire@VerrosBerkshire.com 

BluhmLG@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 

2. 

As to Paragraph 1, Respondent admits the allegations. 

As to Paragraph 2, Respondent admits the allegations. 

As to Paragraph 3, no answer is required.

Page 2

9. 

As to Paragraph 9, no answer is required. 

10. 

As to Paragraph 10, Respondent admits the allegations. 

11. 

As to Paragraph 11, Respondent admits the allegations. 

12. 

As to Paragraph 12, Respondent neither admits nor denies the allegations, and 

leaves Petitioner to its proofs. 

13. 

As to Paragraph 13, Respondent denies that there is a viable dispute or issue as 

to the valuation, assessment, or taxable value of the Subject Property. 

14. 

As to Paragraph 14, Respondent admits the allegation. 

15. 

As to Paragraph 15, no answer is required. 

16. 

As to Paragraph 16, Respondent denies that Petitioner has correctly identified 

the Respondent's True Cash and SEV for the Subject Property. Respondent has determined 

the True Cash Value for the Subject Property is $21,958,260; the State Equalized Value is 

$10,979,130. The Taxable Value was correctly stated as $8,570,140. 

17. 

As to Paragraph 17, Respondent denies the Petitioner's contentions are accurate 

or supported by any documentation or other information. 

18. 

As to Paragraph 18, Respondent denies that Petitioner has accurately stated all 

of the values in dispute, and furthermore denies that Petitioner's value contentions are 

accurate or supported by any documentation. The True Cash Value in dispute is $13,758,260 

and the State Equalized Value in dispute is $6,508,990. The Taxable Value in dispute is 

$4,470,140.

Page 3

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: June 26, 2026 

CITY OK TROY 

Poel 

LORI GRIGG BLUHM (P46908) 

Attorney for Respondent 

500 W. Big Beaver Road 

Troy, MI 48084 

(248) 524-3320 

BluhmLG@TroyMl.gov

Page 4

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.

Page 5

subject property be affirmed or increased, that Petitioner's Petition be dismissed with 

prejudice, and that Respondent be granted costs and attorney fees so wrongfully sustained. 

Dated: June 26, 2026 

ES 

LORI GRIGG BLUHM (P46908) 

Attorney for Respondent 

500 W. Big Beaver Road 

Troy, MI 48084 

(248) 524-3320 

BluhmLG@TroyMl.gov 

Certificate of Service 

| hereby certify that on June 26, 2026, 

| served a copy of this Answer and Affirmative 

Defenses to the following via email: 

Petitioner's Attorney Ellen G. Berkshire via email at: 

EBerkshire@VerrosBerkshire.com and via first class mail to the following; 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: June 26, 2026 

CITY OF 

TROY

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