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Blair Park Answer to Petitions and Affirmative Defenses and POS.pdf

Blair Park 2005, LLC, Petitioner Vs. City Of Jackson, Respondent · 25-003119-TT

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

BLAIR PARK 2005, LLC, 

Petitioner, 

-vs- 

CITY OF JACKSON, 

Respondent. 

MOAHR Docket No. 25-003119 

Parcel No. 8-191400000 

ANSWER TO PETITION AND 

AFFIRMATIVE DEFENSES 

PETER ELLENSON (P47383) 

LAW OFFICE OF PETER ELLENSON PC 

Attorney for Petitioner 

30500 Northwestern Highway, Ste 500 

Farmington Hills, MI 48334 

248/406-4443 

peter@ellensonlaw.com 

JACKSON CITY ATTORNEY'S OFFICE 

BY: Matthew M. Hagerty (P66015) 

Mark M. Porterfield (P57917) 

Attorneys for Respondent 

161 W. Michigan Avenue 

Jackson, MI 49201 

(517) 788-4050 

mhagerty@cityofjackson.org 

mporterfield@cityofjackson.org 

RESPONDENT CITY OF JACKSON'S 

ANSWER TO PETITION 

NOW COMES Respondent, City of Jackson, by and through its attorneys, the City 

Attorney’s Office, and for its Answer to Petitioner’s Petition, states as follows: 

1. 

Respondent neither admits nor denies the allegation contained in Paragraph 

1 of 

Petitioner’s Petition. 

2. 

Respondent neither admits nor denies the allegation contained in Paragraph 2 of 

Petitioner’s Petition.

Page 2

10. 

11. 

12. 

13. 

14. 

15. 

In response to Paragraph 

3, Respondent states that the City of Jackson Assessing 

department assesses property taxes on the subject property which are collected by 

collected by the City of Jackson Treasurer. 

Respondent admits the allegation contained in Paragraph 4 of Petitioner’s Petition. 

Respondent admits the allegation contained in Paragraph 5 of Petitioner’s Petition. 

Respondent neither admits nor denies the allegations contained in Paragraph 6 of 

Petitioner’s Petition and leaves Petitioner to its strict proofs. 

Respondent admits the allegation contained in Paragraph 7 of Petitioner’s Petition. 

Respondent neither admits nor denies the allegations contained in Paragraph 

8 of 

Petitioner’s Petition and leaves Petitioner to its strict proofs. 

Respondent neither admits nor denies the allegations contained in Paragraph 9 of 

Petitioner’s Petition and leaves Petitioner to its strict proofs. 

Respondent neither admits nor denies the allegations contained in Paragraph 10 of 

Petitioner’s Petition and leaves Petitioner to its strict proofs. 

Respondent admits the allegation contained in Paragraph 11 of Petitioner’s Petition. 

Respondent admits the allegation contained in Paragraph 12 of Petitioner’s Petition. 

Respondent denies the allegation contained in Paragraph 13 of Petitioner’s Petition. 

Respondent states that the allegations contained in paragraph 14 merely represent the 

conclusion of the pleader. 

Respondent states that the allegations contained in paragraph 15 merely represent the 

conclusion of the pleader and that Petitioner’s claims to a refund, interest and costs are 

denied as untrue.

Page 3

16. Respondent denies the allegation contained in Paragraph 16 of Petitioner’s Petition as 

untrue. 

17. Respondent admits that the assessments for TY 2025 are currently under appeal in 

docket no. 25-001273 are neither admit nor deny the remaining allegations. 

WHEREFORE, 

Respondent 

requests 

this Honorable 

Tribunal 

dismiss 

Petitioner’s 

Petition in its entirety, that it assess actual costs and attorney fees against Petitioner for costs 

incurred in responding to the Petition, and further requests all other relief the Tribunal deems to be 

just and equitable. 

Respectfully submitted, 

4 

DATED: October 22, 2025 

BY: 

Z = AN 

Office of the City Attorney 

City of Jackson, Michigan 

161 W. Michigan Ave. 

Jackson, MI 49201 

AFFIRMATIVE DEFENSES 

NOW COMES Respondent, City of Jackson, by and through 

its attorneys, the City 

Attorney’s Office, and states the following Affirmative Defenses alternatively and consecutively: 

1. 

The subject property’s assessed, 

true cash, and taxable values are levied 

in 

accordance with the Michigan General Property Tax Act and Michigan Constitution. 

2. 

The subject property is assessed in accordance with generally accepted assessing 

standards. 

B82 

The subject property is assessed at no more than 50% of its true cash value.

Page 4

4. 

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

5. 

Respondent reserves the right 

to amend 

its affirmative defenses through the 

conclusion of discovery. 

Respectfully submitted, 

DATED: October 22, 2025 

BY: 

pA 

{ 

MATHEW M. HAGERTY 

(R66015) 

MARK M. PORTERFIE 

57917) 

Office of the C 

fney 

City of Jackson, Michigan 

161 W. Michigan Ave. 

Jackson, MI 49201 

CERTIFICATE OF SERVICE 

STATE OF MICHIGAN 

) 

) ss 

COUNTY OF JACKSON 

) 

The undersigned certifies under penalty of perjury that on October 22, 2025 she served copies of 

Respondent City of Jackson’s Answer to Petition and Affirmative Defenses upon the Petitioner 

by first class mail with postage fully prepaid to the following address: 

PETER ELLENSON 

LAW OFFICE OF PETER ELLENSON PC 

30500 Northwestern Highway, Ste 500 

Farmington Hills, MI 48334 

DATED: 

October 22, 2025 

Rott tattobtctl 

ROBERTA HUBBELL

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