MTT Conrad Group. Ans.POS.pdf
Conrad Group LLC Petitioner Vs. City Of St. Clair Shores Respondent · 26-000468-TT
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LAW OFFICES IHRIE O'BRIEN ALBRIGHT PERAKIS 24055 JEFFERSON AVE ST. CLAIR SHORES, MI 48080 ., SUITE 2000 TELEPHONE (586) 778-7778 STATE OF MICHIGAN DEPARTMENT OF LABOR & ECONOMIC GROWTH MICHIGAN TAX TRIBUNAL CONRAD GROUP LLC, Petitioner, MTT Docket No. 26-00468 v. CITY OF ST. CLAIR SHORES, Respondent. / HALLAHAN & ASSOCIATES, P.C. Attorney for Petitioner Laura M. Hallahan (P42101) 1750 S. Telegraph Road, Suite 202 Bloomfield Hills, MI 48302 (248) 731-3089 lhallahan@hallahanlaw.com IHRIE O’BRIEN ALBRIGHT PERAKIS Attorney for Respondent By: Matthew D. Haugh, P87473 24055 Jefferson Avenue, Suite 2000 St. Clair Shores, MI 48080 (586) 778-7778 office@ihrieobrienlaw.com / ANSWER TO PETITION NOW COMES Respondent, CITY OF ST. CLAIR SHORES, a Michigan municipal corporation, through its attorneys, IHRIE O’BRIEN ALBRIGHT PERAKIS, by Matthew D. Haugh, and in response to the instant petition, states as follows: 1. In response to paragraph 1, Respondent neither admits nor denies the allegations contained therein as it lacks sufficient information to form a reasonable belief as
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LAW OFFICES IHRIE O'BRIEN ALBRIGHT PERAKIS ST. CLAIR SHORES, MI 48080 ., SUITE 2000 24055 JEFFERSON AVE TELEPHONE (586) 778-7778 10. 11. to the truth of the matter asserted. No response required In response to paragraph 3, Respondent admits the allegation contained therein. In response to paragraph 4, Respondent admits the allegations contained therein. In response to paragraph 5, Respondent neither admits nor denies the allegations contained therein as it lacks sufficient information to form a reasonable belief as to the truth of the matter asserted. In response to paragraph 6, Respondent neither admits nor denies the allegations contained therein as it lacks sufficient information to form a reasonable belief as to the truth of the matter asserted. In response to paragraph 7, Respondent neither admits nor denies the allegations contained therein as it lacks sufficient information to form a reasonable belief as to the truth of the matter asserted. In response to paragraph 8, Respondent admits the allegation contained therein. In response to paragraph 9, Respondent neither admits nor denies the allegations contained therein as it lacks sufficient information to form a reasonable belief as to the truth of the matter asserted. In response to paragraph 10, Respondent neither admits nor denies the allegations contained therein as it lacks sufficient information to form a reasonable belief as to the truth of the matter asserted. In response to paragraph 11, Respondent denies the allegations contained therein. (a) In response to subparagraph a, Respondent denies the allegation contained
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LAW OFFICES IHRIE O’BRIEN ALBRIGHT PERAKIS ST. CLAIR SHORES, MI 48080 ., SUITE 2000 24055 JEFFERSON AVE TELEPHONE (586) 778-7778 therein. (b) In response to subparagraph b, Respondent denies the allegation contained therein. (c) In response to subparagraph c, Respondent denies the allegation contained therein. (d) In response to subparagraph d, Respondent denies the allegation contained therein. WHEREFORE, Respondent, CITY OF ST. CLAIR SHORES, respectfully requests that this Honorable Tribunal dismiss the instant petition and uphold the determination of Respondent’s Assessor’s Office or, in the alternative, increase the taxable value based on evidence to be revealed during these proceedings. AFFIRMATIVE DEFENSES NOW COMES Respondent, CITY OF ST. CLAIR SHORES, a Michigan municipal corporation, through its attorneys, IHRIE O'BRIEN ALBRIGHT PERAKIS, by Matthew D. Haugh, and in support of its affirmative defenses, states as follows: L 2 Lack of Jurisdiction. Respondent’s assessment was valid. Petitioner failed to comply with Tax Tribunal’s rules of practice and procedure governing the content of a petition filed with the Tax Tribunal. Failure to state a claim upon which relief can be granted. Respondent reserves the right to file additional defenses as information becomes
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LAW OFFICES IHRIE O'BRIEN ALBRIGHT PERAKIS ST. CLAIR SHORES, MI 48080 ., SUITE 2000 24055 JEFFERSON AVE TELEPHONE (586) 778-7778 known during discovery or as justice so requires. WHEREFORE, Respondent, CITY OF ST. CLAIR SHORES, respectfully requests that this Honorable Tribunal dismiss the instant petition and uphold the determination of Respondent’s Assessor’s Office or, in the alternative, increase the taxable value based on evidence to be revealed during these proceedings. Respectfully submitted, IHRIE O'BRIEN ALBRIGHT PERAKIS Attorney for Respondent By:/s/ Matthew D. Haugh Matthew D. Haugh, P87473 24055 Jefferson Ave., Suite 2000 St. Clair Shores, MI 48080 (586) 778-7778 Dated: July 31. 2026 PROOF OF SERVICE DAWN M. McNEILLY, hereby states that on the 3 day of August 2026, I served a copy of the Answer to Petition along with this Proof of Service by placing same in an envelope addressed to attorney Laura M. Hallahan at 1750 S. Telegraph Road, Suite 202, Bloomfield Hills, MI 48302 and placing said envelope in the United States Mail, with postage fully prepaid thereon. I certify that the same is true to the best of my knowledge, information, and belief. Dawn M. McNeilly ) IHRIE O’BRIEN ALBRIG ERAKIS