Answer Christine Perv Condo Docket No 26-001444.pdf
Christine Pervolarakis Petitioner Vs. City Of Detroit Respondent · 26-001444-TT
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1 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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2 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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3 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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4 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