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Answer to Petition & Affirmative Defenses 25-002037.pdf

Dearborn Elite Hospitality LLC, Petitioner Vs. City Of Dearborn, Respondent · 25-002037-TT

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Page 1

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEMS 

MICHIGAN TAX TRIBUNAL 

 

DEARBORN ELITE HOSPITALITY LLC, 

 

Petitioner, 

 

 

MTT Docket No. 25-002037 

 

 

 

v 

 

 

CITY OF DEARBORN, 

 

Respondent. 

_____________________________________________________________________/ 

 

LAURA M. HALLAHAN (P42101) 

SETH A. O’LOUGHLIN (P80257) 

HALLAHAN & ASSOCIATES, P.C. 

Attorney for Petitioner 

1750 S. Telegraph Road, Ste. 202 

Bloomfield Hills, MI 48302 

(248) 731-3089 

(248) 731-3086 fax 

lhallahan@hallahanlaw.com 

 

JEREMY J. ROMER (P77287) 

GOPI P. PATEL (P77727) 

CITY OF DEARBORN 

Attorneys for Respondent 

16901 Michigan Ave., Ste. 14 

Dearborn, MI 48126 

(313) 943-2035 

(313) 943-2469 fax 

jromer@dearborn.gov 

gpatel@dearborn.gov 

_____________________________________________________________________/ 

 

RESPONDENT'S ANSWER TO PETITION 

AND AFFIRMATIVE DEFENSES 

 

 

NOW COMES Respondent, City of Dearborn, by and through its attorney, JEREMY J. 

ROMER, and for its Answer to Petition states as follows: 

ANSWER TO THE PETITION 

 

1. 

As to the allegations contained in Paragraph 1, this Respondent admits the 

allegation contained therein. 

 

2. 

As to the allegations contained in Paragraph 3, this Respondent admits the 

allegations contained therein.

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2 

 

3. 

As to the allegation contained in Paragraph 4, this Respondent is without sufficient 

information or knowledge to form a belief as to the truth of the allegation stated therein and leaves 

Petitioner to her proofs. 

 

4. 

As to the allegation contained in Paragraph 5, this Respondent is without sufficient 

information or knowledge to form a belief as to the truth of the allegation stated therein and leaves 

Petitioner to her proofs. 

 

5. 

As to the allegation contained in Paragraph 6, this Respondent is without sufficient 

information or knowledge to form a belief as to the truth of the allegation stated therein and leaves 

Petitioner to her proofs. 

 

6. 

As to the allegation contained in Paragraph 7, this Respondent admits the 

allegations contained therein. 

 

7. 

As to the allegation contained in Paragraph 8, this Respondent denies each and 

every allegation contained therein for the reason that they are untrue 

 

8. 

As to the allegations contained in Paragraph 9, this Respondent is without sufficient 

information or knowledge to form a belief as to the truth of the allegation stated therein and leaves 

Petitioner to her proofs. 

 

9. 

As to the allegations contained in Paragraph 10, this Respondent is without 

sufficient information or knowledge to form a belief as to the truth of the allegation stated therein 

and leaves Petitioner to her proofs. 

 

10. 

As to the allegations contained in Paragraph 11, this Respondent denies each and 

every allegation contained therein for the reason that they are untrue.

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WHEREFORE, Respondent respectfully requests that this Honorable Tribunal dismiss this 

Petition with prejudice, deny the legal and/or equitable relief requested, and order Petitioner to pay 

Respondent the costs and attorney fees so wrongfully sustained by the necessity of the defense. 

 

Respectfully submitted, 

Jeremy J. Romer 

 

________________________ 

 

JEREMY J. ROMER 

 

 

 

 

 

 

 

Attorney for Respondent 

 

 

 

 

 

 

 

16901 Michigan Ave., Ste. 14 

 

 

 

 

 

 

 

Dearborn, MI 48126 

 

 

 

 

 

 

 

(313) 943-2035 

 

 

 

 

 

 

 

(313) 943-2069 fax 

 

 

 

 

 

 

 

jromer@dearborn.gov 

 

 

Dated: August 20, 2025

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AFFIRMATIVE DEFENSES 

 

 

For its further answer to Petition, and by way of its affirmative defenses, Respondent 

respectfully represents to this Honorable Tribunal as follows: 

1. Petitioner lacks standing to bring this matter before the Michigan Tax Tribunal. 

2. 

Petitioner has failed to allege specific and sufficient acts to set forth a cause of action 

against Respondent. 

3. 

Petitioner has failed to allege specific and sufficient facts to establish fraud, error of 

law, discrimination, and application of wrong principles or illegality on the part of Respondent. 

4. 

Petitioner has failed to allege that the mode and method of appraising its property failed 

to conform to the mode and method applied in the case of all other properties in the Respondent 

taxing unit. 

5. 

Petitioner has failed to allege specific and sufficient facts to establish the true cash 

value of its property. 

6. 

Petitioner has failed to file a petition which conforms to the requirements of TTR 240 

and its subsections sufficient to apprise Respondent of the grounds of its Petition. 

7. 

Petitioner has failed to show that any rate other than 50%, after equalization, was 

applied to the true cash value of Petitioner’s property as well as to the properties of all others to 

arrive at the respective equalized assessments appearing on Respondent’s assessment roll. 

8. 

Petitioner failed in its appearance, if required, before the Board of Review to allege that 

the assessment is unlawful and is based upon the application of wrong principles and thereby 

operates as a fraud upon the taxpayer. 

9. 

Petitioner, in essence, seeks by its Petition to challenge the process of County and State 

equalization as to which it has no legal standing and cannot maintain a cause of action.

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10. 

The property at issue is subject to taxation under the relevant provisions of the General 

Property Tax Act, and Respondent reserves the right to file a Motion for Summary Disposition on 

that issue upon close of discovery. 

11. 

Respondent reserves the right to supplement this notice and assert any affirmative 

defenses and/or special defenses as additional information becomes known through the discovery 

process or otherwise. 

WHEREFORE, Respondent respectfully requests that this Honorable Tribunal dismiss this 

Petition with prejudice, deny the legal and/or equitable relief requested, and order Petitioner to pay 

Respondent the costs and attorney fees so wrongfully sustained by the necessity of the defense. 

 

 

 

 

 

 

 

Respectfully submitted, 

Jeremy J. Romer 

 

________________________ 

 

JEREMY J. ROMER 

 

 

 

 

 

 

 

Attorney for Respondent 

 

 

 

 

 

 

 

16901 Michigan Ave., Ste. 14 

 

 

 

 

 

 

 

Dearborn, MI 48126 

 

 

 

 

 

 

 

(313) 943-2035 

 

 

 

 

 

 

 

(313) 943-2069 fax 

 

 

 

 

 

 

 

jromer@dearborn.gov 

 

Dated: August 20, 2025 

 

PROOF OF SERVICE 

The undersigned certifies that the foregoing was 

served upon all parties to the above cause to each of 

the attorneys/parties of record herein at their 

respective addresses disclosed on the pleadings on 

August 20, 2025. 

 

BY: 

 U.S. Mail 

 Telefacsimile 

 

Hand Delivered 

Overnight courier 

 

Federal Express 

E-mail 

 

Signature: __ Jeremy J. Romer 

 

 Jeremy J. Romer

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