Full record / Detroit Thermal LLC MTT# 26-000737 answer.pdf

Detroit Thermal LLC MTT# 26-000737 answer.pdf

Detroit Thermal, LLC Petitioner Vs. City Of Detroit Respondent · 26-000737-TT

← View full record

Text extracted from the reviewed PDF, organized by page. OCR and reading order may contain errors; confirm details in the PDF below.

Page 1

1 

 

STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

DETROIT THERMAL, LLC, 

 

Petitioner, 

v. 

 

 

 

 

 

 

 

Docket No. 26-000737 

 

CITY OF DETROIT, 

 

 

 

 

 

 

 

Respondent. 

________________________________/ 

 

ANSWER 

 

 

RESPONDENT, CITY OF DETROIT, for its Answer to the Petition filed in this matter 

states as follows: 

1. Respondent admits. 

2. Respondent admits. 

3. Respondent admits. 

4. Respondent admits. 

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

involving valuation, assessment, taxable value, due process, equal protection and 

uniformity, however, Respondent denies that any such allegations have merit. 

6. Respondent admits. 

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

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

Page 2

2 

 

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: June 2, 2026 

 

PROOF OF SERVICE 

 

On June 2, 2026, I sent via email a copy of Respondent’s Answer w/Affirmative 

Defenses in the instant matter to: 

 

Stewart L. Mandell 

SLMandell @Honigman.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) 

 

 

 

Assistant Corporation Counsel 

 

 

 

City of Detroit Law Department 

 

 

 

Coleman A. Young Municipal Center 

 

 

 

2 Woodward Avenue, Suite 500 

Dated:June 2, 2026 

Detroit, Michigan 48226

PDF reading copy

← View full record