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Landy Land LLC MTT 26-000448 answer & affirmative defenses.pdf

Landy Land LLC Petitioner Vs. City Of Detroit Respondent · 26-000448-TT

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

LANDY LAND, LLC, 

 

Petitioner, 

v. 

 

 

 

 

 

 

 

Docket No. 26-000448 

 

CITY OF DETROIT, 

 

 

 

 

 

 

Respondent. 

________________________________/ 

 

ANSWER 

 

 

NOW COMES RESPONDENT, CITY OF DETROIT, by and through its undersigned 

counsel, and in Answer to the Petition filed in this matter states as follows: 

1. Respondent admits. 

2. No response is necessary. 

3. Respondent admits. 

4. Respondent admits. 

5. Respondent admits. 

6. Respondent admits only that Petitioner’s instant Tax Tribunal appeal alleges issues 

involving the subject property’s true cash and taxable values, however, Respondent denies 

that any such allegations have merit. 

7. Respondent admits. 

8. Respondent admits. 

9. Respondent neither admits nor denies as Respondent lacks sufficient knowledge or 

information to form a belief as to the truth of the allegation. 

10. Based solely upon Petitioner’s unsubstantiated value contentions Respondent admits.

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11. Respondent neither admits nor denies as Respondent lacks sufficient knowledge or 

information to form a belief as to the truth of the allegation. 

AFFIRMATIVE DEFENSES 

Respondent further asserts that Petitioner’s claims are barred, in whole or in part, by: 

1. Petitioner’s claims are barred by the applicable statute of limitations. 

2. Petitioner has failed to state a claim for which relief may be granted. 

3. This Tribunal lacks subject matter jurisdiction. 

WHEREFORE, Respondent City of Detroit respectfully requests that this Honorable 

Tribunal dismiss the Petition in this matter and award costs and attorney fees. 

 

 

 

 

 

Respectfully Submitted, 

 

 

 

 

 

/s/ Kevin C. Richard 

 

 

 

 

 

Kevin C. Richard (P43417) 

 

 

 

 

 

City of Detroit Law Department 

 

 

 

 

 

Coleman A. Young Municipal Center 

 

 

 

 

 

2 Woodward Avenue, Suite 500 

 

 

 

 

 

Detroit, Michigan 48226 

 

 

 

 

 

(313) 237-3061 

 

Dated: August 11, 2026

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

LANDY LAND, LLC, 

 

Petitioner, 

v. 

 

 

 

 

 

 

 

Docket No. 26-000448 

 

CITY OF DETROIT, 

 

Respondent. 

________________________________/ 

 

PROOF OF SERVICE 

 

On August 11, 2026, I sent by Email a copy of Respondent’s Answer w/Affirmative Defenses in 

the instant matter to: 

 

Laura M. Hallahan 

lhallahan@hallahanlaw.com 

 

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

 

 

 

 

 

 

 

 

/s/ Kevin C. Richard 

 

 

 

 

 

 

Kevin C. Richard (P43417) 

 

 

 

 

 

 

Senior Assistant Corporation Counsel 

 

 

 

 

 

 

City of Detroit Law Department 

 

 

 

 

 

 

Coleman A. Young Municipal Center 

 

 

 

 

 

 

2 Woodward Avenue, Suite 500 

Dated: August 11, 2026 

 

 

Detroit, Michigan 48226

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