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Answer and Affirmative Defenses.pdf

E And F Agency Inc Petitioner Vs. City Of Troy Respondent · 26-001063-TT

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

E and F Agency, Inc., 

Petitioner, 

MTT Docket: 26-001063 

\Y 

Parcel ID 88-20-22-380-033 

City of Troy, 

Respondent. 

/ 

JOSHUA T. SHILLAIR (P72674) 

LORI GRIGG BLUHM (P46908) 

Vice President/ Tax Appeal 

JULIE QUINLAN DUFRANE (P59000) 

COLLIERS INTERNATIONAL 

TROY CITY ATTORNEY'S OFFICE 

Attorney for Petitioner 

Attorneys for Respondent 

400 W. 4th Street, Suite 350 

500 W. Big Beaver Road 

Royal Oak, MI 48067 

Troy, MI 48084 

(248) 226-1632 

(248) 524-3320 

Joshua.Shillair@Colliers.com 

BLUHMLG@TROYMI.gov 

/ 

RESPONDENT'S ANSWER TO PETITION AND AFFIRMATIVE DEFENSES 

NOW COMES, Respondent, CITY OF TROY, by and through its attorney, Lori Grigg 

Bluhm, and for its Answer to Petitioner's Petition, states as follows: 

1. 

As to Paragraph 1, Respondent neither admits nor denies the allegation, lacking 

knowledge or information sufficient to form a belief as to the truth of the allegations and

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denies the allegation, lacking knowledge or information sufficient to form a belief as to the truth 

of the allegations and therefore and leaves Petitioners to the proofs. 

5. 

As to Paragraph 5, Respondent admits that there was no board of review protest 

filed. 

6. 

As to Paragraph 6, Respondent admits. 

7. 

As to Paragraph 7, Respondent denies that there are any issues concerning the 

valuation, assessment, taxable value, and/or uniformity. 

8. 

As to paragraph 8, Respondent admits. 

9. 

As to Paragraph 9, Respondent admits. 

10. 

As to Paragraph 10, Respondent denies the allegation in its entirety, as it is 

untrue. 

11. 

As to Paragraph 11, Respondent denies that the Petitioner's alleged values for the 

subject parcels are correct or supported by any basis. 

12. 

As to Paragraph 12, Respondent admits that Petitioner has correctly calculated 

the difference between Petitioner's claimed assessed values for the subject property and the 

Respondent's assessed value determination. Respondent denies that the Petitioner's assessed 

values are correct. 

13. 

As to Paragraph 13, Respondent denies that Petitioner has correctly determined

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Dated: August 13, 2026 

CITY OF TROY 

Had 

LORT GRIGG BLUHM (P46908) 

Attorney for Respondent 

500 W. Big Beaver Road 

Troy, MI 48084 

(248) 524-3320 

BluhmLG@troymi.gov 

AFFIRMATIVE DEFENSES 

For its further Answer to Petitioners’ Petition, Respondent relies on the following 

Affirmative Defenses: 

1. 

Petitioners fail to allege specific and sufficient facts to set forth a cause of action 

against Respondent and to support its claim for relief. 

Petitioners fail to allege specific and sufficient facts to establish fraud, error of law, 

discrimination, application of wrong principles or illegality on the part of the 

Respondent or its agents. 

Petitioners fail to allege specific and sufficient facts to establish the true cash value, 

assessed value, and taxable value of its property. 

Petitioners fail to allege specific and sufficient facts to support its allegations that the 

property's taxable value is improper, or failed to conform with the mode and method

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6. 

Respondent has properly and lawfully assessed Petitioner's property and established 

its assessed and taxable value in accordance with statutory and constitutional 

requirements. 

7. 

Respondent reserves the right to argue additional Affirmative Defenses during the 

pendency of this action. 

WHEREFORE, Respondent, CITY OF TROY denies that Petitioner is entitled to its 

requested relief, and requests that the subject property's assessment and taxable value be 

affirmed or increased, that Petitioners’ Petition be dismissed with prejudice, and that 

Respondent be granted costs and attorney fees so wrongfully sustained. 

Dated: August 13, 2026 

CITY OF TROY 

teas 

LORI GRIGG BLUHM (P46908) 

Attorneys for Respondent 

500 W. Big Beaver Road 

Troy, MI 48084 

(248) 524-3320 

BluhmLG@troymi.gov

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Certificate of Service 

| hereby certify that on August 13, 2026, 

| served a copy of this Answer 

and Affirmative Defenses via email to Petitioner's representative Joshua Shillair 

at Joshua. Shillair@Colliers.com and to the following via first class mail: 

Chief 

Clerk, Michigan Tax Tribunal; P.O. Box 30232, Lansing, MI 48909; Michigan 

Department of Treasury, State Treasurer, 430 W. Allegan, Lansing, MI 49822; 

Secretary of School Board, Troy Public Schools, 4400 Livernois Road, Troy, MI 

48098; Director of Equalization; Oakland Pointe Office Building, 250 Elizabeth 

Lake Road Suite 1000; Pontiac, MI 48341; and Clerk, Oakland County; 1200 N. 

Telegraph, Building 12 East, Pontiac, MI 48341. 

Dated: August 13, 2026 

CITY li. ) 

/ 

Clara Reid 

Legal Administrative Coordinator 

500 W. Big Beaver Road 

Troy, MI 48084 

(248) 524-3320

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