Answer Square Knot 25002184 642 Forest .pdf
Square Knot LLC, Petitioner Vs. City Of Detroit, Respondent · 25-002184-TT
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1 STATE OF MICHIGAN DEPARTMENT OF LICENSING & REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL SQUARE KNOT, LLC Petitioner, v CITY OF DETROIT, Docket No. 25-002184 MTT Respondent. ________________________________________________________________________________/ ANSWER TO PROPERTY TAX PETITION Respondent, City of Detroit, by and through it undersigned counsel and for its Answer to this Petition states the following: 1. Respondent, City of Detroit, admits as true. 2. Respondent admits as true. 3. No response is required to the allegations in Paragraph 3. 4. No response is required to the allegations in Paragraph 4. 5. No response is required to the allegation in Paragraph 5. 6. Respondent admits as true. 7. No response is required to the allegation in Paragraph 7. 8. No response is required to the allegation in Paragraph 8. 9. No response is required to the allegation in Paragraph 9. 10. Respondent admits as true. 11. Respondent admits as true.
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2 12. Respondent, City of Detroit, neither admits nor denies as Respondent lacks sufficient knowledge or information to form a belief as to the truth of the allegations and leaves Petitioner to its proofs. 13. Respondent admits that this appeal relates to issues of the property’s true cash and taxable values, but further states that these allegations lack merit. 14. Respondent admits as true. 15. Respondent, City of Detroit, admits as true. 16. Respondent, City of Detroit, admits as true. 17. Respondent neither admits nor denies as Respondent lacks sufficient knowledge or information to form a belief as to the truth of the allegations and leaves Petitioner to its proofs. 18. Respondent admits as true. 19. Respondent leaves Petitioner to its proofs as to any relief requested. 20. Respondent leaves Petitioner to its proofs as to any relief requested. Wherefore, Respondent respectfully requests that this Honorable Tribunal dismiss the Petition in this matter and award attorney fees and costs to Respondent. Dated: 10/3/2025 /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
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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’s 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: 10/3/2025 /s/Mary Beth Cobbs By: Mary Beth Cobbs ( P40080) Kevin C. Richard ( P43417) 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 , SQUARE KNOT, LLC Petitioner, v CITY OF DETROIT, Docket No. 25-002184 -MTT Respondent. _______________________________________________________________________ PROOF OF SERVICE On 10/3 /2025, I mailed by first class mail a copy of Respondent’s Answer and Affirmative Defenses to: Troy Otto , Esq. FISCHER, FRANKLIN & FORD 24725 W. 12 Mile Rd. Suite 230 Southfield, MI 48034 I declare that the above statement is true to the best of my information, knowledge, and belief. Dated: October 3, 2025 /s/Mary Beth Cobbs Mary Beth Cobbs ( P40080) City of Detroit Law Department 2 Woodward Ave., Ste. 500 Detroit, MI 48226