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Answer Baracus 26-001581.pdf

Baracus Partners, LLC Petitioner Vs. City Of Detroit Respondent · 26-001581-TT

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

BARACUS PARTNERS, LLC 

 

Petitioner, 

 

 

 

 

 

v 

CITY OF DETROIT, 

 

 

 

Docket No. 26- 001581 MTT 

Respondent. 

________________________________________________________________________________/ 

ANSWER TO PROPERTY TAX PETITION 

 Respondent, City of Detroit, by and through its 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. Respondent admits as true. 

4. Respondent admits as true. 

5. Respondent admits that this appeal involves issues of (a) valuation, (b) assessment,(c) 

taxable value and (d) uniformity, but states that Petitioner’s allegations lack merit. 

6. Respondent admits as true that this appeal involves issues of taxable values imposed 

upon the Subject Property, but states that these allegations of the value of a loss lack 

merit.

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

information to form a belief as to the truth of the allegation and leaves Petitioner to its 

proofs. 

8. Respondent, City of Detroit, admits that Petitioner appeal is challenging the 2026 

assessment, assessed value, state equalized value and taxable values imposed upon the 

Subject Property, but states that these allegations, including those contained in sub-

paragraphs a-d lack merit. 

Wherefore, Respondent respectfully requests that this Honorable Tribunal dismiss the 

Petition in this matter and award attorney fees and costs to Respondent. 

Dated: October 1, 2026 

 

 

 

 

 

 

/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 

 

 

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.

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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: October 1, 2026 

/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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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

BARACUS PARTNERS , LLC 

 

Petitioner, 

 

 

 

 

 

v 

CITY OF DETROIT, 

 

 

 

Docket No. 26-001581- MTT 

Respondent. 

 

_______________________________________________________________________ 

PROOF OF SERVICE 

 

On 10/1/2026 , I mailed by first class mail a copy of Respondent’s Answer and Affirmative 

Defenses to: 

 

 

 

Jason Conti, Esq. 

 

 

 

FOLEY & LARDNER LLP 

 

 

 

500 Woodward Ave., Suite 2700 

 

 

 

Detroit, MI 48226 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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

belief. 

 

Dated: October 1, 2026 

 

 

 

 

 

 

/s/Mary Beth Cobbs 

 

 

 

 

 

 

Mary Beth Cobbs ( P40080) 

 

 

 

 

 

 

City of Detroit Law Department 

 

 

 

 

 

 

2 Woodward Ave., Ste. 500 

 

 

 

 

 

 

Detroit, MI 48226

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