Full record / Answer Christine Perv Condo Docket No 26-001444.pdf

Answer Christine Perv Condo Docket No 26-001444.pdf

Christine Pervolarakis Petitioner Vs. City Of Detroit Respondent · 26-001444-TT

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 CHRISTINE PERVOLARAKIS 

 

Petitioner, 

 

 

 

 

 

v 

CITY OF DETROIT, 

 

 

 

Docket No. 26-001444 

 

Respondent. 

 

 

 

Parcel No. 01004235.246 

____________________________________________________________________________/ 

ANSWER TO PETITION and 

AFFIRMATIVE DEFENSES 

Now Comes Respondent, City of Detroit, by and through it undersigned counsel and in Answer 

to the Petition filed in this matter 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 as true. 

6. Respondent admits as true. 

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 admits that that this appeal contains issues of the properties’ taxable 

value and true cash values as it relates to the subject property, but further states that 

these allegations lack merit.

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9. Respondent admits as true. 

10. Respondent admits as true. 

11. Respondent, City of Detroit, neither admits nor denies and leaves Petitioner to its 

proofs. 

12. Respondent admits that these values, based only upon Petitioner’s contention of the 

values for the subject property, are the amounts in dispute. 

13. Respondent lacks knowledge or information sufficient to form a belief as to the truth 

of the allegations contained in this paragraph, and therefore denies these allegations. 

14. Respondent, in replying to the facts Petitioner relies upon states the following: 

A. Respondent admits that Petitioner has property quoted Section 44-4-10 of the 

City Code, but as to the timing of the subject property’s appraisal, Respondent 

neither admits nor denies and leaves Petitioner to its proofs. 

B. Respondent, City of Detroit, neither admits nor denies and leaves Petitioner 

to its proofs. 

C. Respondent, City of Detroit, neither admits nor denies and leaves Petitioner 

to its proofs. 

D. Respondent, City of Detroit, neither admits nor denies and leaves Petitioner 

to its proofs. 

 

CONCLUSION and REQUEST FOR RELIEF 

Wherefore, Respondent respectfully requests that this Honorable Tribunal dismiss the 

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

Dated: October 21, 2026 

 

/s/Mary Beth Cobbs 

 

 

 

 

 

 

By: Mary Beth Cobbs ( P40080)

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Kevin C. Richard ( P 43417) 

 

 

 

 

 

 

Attorneys for Respondent 

 

 

 

 

 

 

City of Detroit Law Department 

 

 

 

 

 

 

2 Woodward Ave., Ste. 500 

 

 

 

 

 

 

Detroit, MI 48226 

 

AFFIRMATIVE DEFENSES 

 

NOW COMES Respondent, City of Detroit, and asserts the following Affirmative 

Defenses to the Petitioner’s claims: 

1. 

Petitioner 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. 

5. 

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

conform with the mode and method of appraising applied in the case of all other properties in the 

community for the year in question. 

 

Wherefore, Respondent respectfully requests that this Honorable Tribunal dismiss the 

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

Dated: 

October 21, 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 

 

 

 

 

 

 

cobbm@detroitmi.gov

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING & REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

CHRISTINE PERVOLARAKIS 

 

Petitioner, 

 

 

 

 

 

v 

CITY OF DETROIT, 

 

 

 

Docket No. 26-001444 

 

Respondent. 

 

 

 

Parcel No. 01004235.246 

____________________________________________________________________________/ 

 

PROOF OF SERVICE 

 

On October 21, 2026 , I mailed by first class mail, a copy of Respondent’s Answer and 

Affirmative Defenses to: 

 

 

 

 

 

Brian Summerfield 

 

 

 

 

 

Schenk & Bruetsch, PLC 

 

 

 

 

 

211 W. Fort Street, Suite 1410 

 

 

 

 

 

Detroit, MI 48226 

 

 

 

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

belief. 

 

Dated: October 21, 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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