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25-001847.pdf

Comerica Bank, Petitioner Vs. Township Of Blackman, Respondent · 25-001847-TT

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Page 1

Eric C. White 

eric 

@whiteandhotchkiss.com 

Kenneth R. Hotchkiss 

ken @whiteandhotchkiss.com 

Michael K. Falahee 

White & Hotchkiss, PLLC 

michael @whiteandhotchkiss.com 

Attorneys at Law 

Matthew D. Hotchkiss 

matt@whiteandhotchkiss.com 

July 31, 2025 

Michigan Tax Tribunal 

Ottawa State Office Building 

P.O. Box 30232. 

611 W. Ottawa Street 

Lansing, Michigan 48913 

Re: 

Comerica Bank v Blackman Charter Township 

MTT Docket No.: 25-001847-TT 

Dear Sir/Madam: 

1000 Laurence Avenue 

Jackson, Michigan 49202 

Telephone 517.784.6250 

Facsimile §17.784.0011 

RECEIVED 

AUG 06 2025 

MICHIGAN TAX TRIBUNAL 

Please find enclosed an Answer to Entire Tribunal Property Tax Petition and Proof of 

Service in the above captioned matter. Please file these in accord with your usual 

manner. 

In the meantime, 

if you have any questions or concerns, please do not hesitate to 

contact me. 

Sincerely, 

White & Hotchkiss, PLLC 

Eric C. White

Page 2

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN ADMINISTRATIVE HEARING SYSTEM 

MICHIGAN TAX TRIBUNAL 

Comerica Bank, 

Petitioner, 

v 

Blackman Charter Township, 

Respondent. 

Mark McMerrell 

Ryan, LLC 

Petitioner's Representative 

600 Superior Avenue E, Suite 1810 

Cleveland, OH 44114 

216-685-9448 

MTT Docket No. 25-001847-TT 

Eric C. White, P53527 

White & Hotchkiss, PLLC 

Attorney for Respondent 

1000 Laurence Avenue 

Jackson, Michigan 49202 

517-784-6250 

ANSWER TO ENTIRE TRIBUNAL PROPERTY TAX PETITION 

Blackman Charter Township, by and through its attorneys, White, Hotchkiss & 

Falahee, PLLC, states for its Answer as follows: 

1. 

This allegation is admitted as true.

Page 3

10. 

11. 

12. 

13. 

14. 

15. 

16. 

This allegation does not require a response. 

This allegation not require a response. 

This allegation is admitted as true. 

This allegation does not require a response. 

This allegation does not require a response. 

This allegation does not require a response. 

This allegation is admitted as true. 

This allegation is admitted as true. 

This allegation is admitted as true. 

This allegation is admitted as true. 

This allegation is admitted as true. 

This allegation does not require a response. 

This allegation is admitted as true.

Page 4

19. 

This allegation is a request for relief and as such does not require a response. 

20. 

This allegation is denied as untrue. 

WHEREFORE, Respondent respectfully requests that the Tribunal deny the relief 

sought by the Petitioner. 

NN: 3A 

i=. 

Eric C. White, P53527 

White & Hotchkiss, PLLC 

Attorney for Respondent 

Dated:

Page 5

ABET, 

& 

STATE OF MICHIGAN 

GRETCHEN WHITMER 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MARLON I. BROWN, DPA 

GOVERNOR 

DIRECTOR 

Comerica Bank 

. 

MICHIGAN TAX TRIBUNAL 

Petitioner(s) 

v 

MTT Docket No. 25-001847-TT 

Blackman Charter Township 

Respondent(s) 

PROOF OF SERVICE 

Maggie Gibney 

states that on 7-31-2025 

he/she 

[Name of person serving/mailing petition] 

[date of service] 

served a copy of the Answer to Petition 

relative to the above-captioned matter upon: 

[Provide name and address of the party/people being served] 

Mark McMerrell, Ryan, LLC, 600 Superior Ave. E, Suite 1810, Cleveland, OH 44114 

ee ad ya 

[Signature ofbgrson who is-sgfving/mailing copy] 

Maggie Gibney 

[Print/type name of person serving/mailing copy]

Page 6

“ty 

White, Hotchkiss & Falahee, PLLC 

Attorneys at Law 

1000 Laurence Avenue 

Jackson, Michigan 49202 

Michigan Tax Tribunal 

Ottawa State Office Building 

P.O. Box 30232 

611 W. Ottawa Street 

Lansing, Michigan 48913 

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