Full record / Indian Trails LLC MTT 26-001466 answer.pdf

Indian Trails LLC MTT 26-001466 answer.pdf

Indian Trails LLC F/K/A Indian Trails Inc Petitioner Vs. City Of Detroit Respondent · 26-001466-TT

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

 

INDIAN TRAILS, LLC f/k/a 

INDIAN TRAILS, INC., 

 

Petitioner, 

v. 

 

 

 

 

 

 

 

Docket No. 26-001466 

 

CITY OF DETROIT, 

 

 

 

 

 

 

Respondent. 

________________________________/ 

 

ANSWER 

 

 

NOW COMES RESPONDENT, CITY OF DETROIT, by and through its undersigned 

counsel, and in Answer to the Petition filed in this matter states as follows: 

1. Respondent admits. 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. 

2. 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. 

3. 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. 

4. Respondent admits. 

5. Respondent admits. 

6. Respondent admits.

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7. Respondent admits. 

8. Respondent admits. 

9. Respondent admits that the subject property is utilized as a bus terminal, however, 

denies as untrue that it is a “public bus terminal”. The property is leased and utilized 

by a private for profit business as a bus terminal 

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

involving the subject property’s true cash value, taxable value, and exemption, however, 

Respondent denies that any such allegations have merit. 

11. Respondent admits. 

12. Respondent admits as to Petitioner’s statement as it pertains to the assessed and taxable 

values of the subject property, however, denies as untrue its allegation regarding the 

true cash value of the subject property. The 2026 true cash value for the subject 

property is $1,153,000. 

13. 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. 

14. Based solely upon Petitioner’s unsubstantiated and erroneous contentions Respondent 

admits. 

15. Paragraph 15 references provisions of state law which speak for themselves and no 

response is required. Additionally, Paragraph 15 states Petitioner’s opinion and no 

response is necessary. To the extent a response is required, Respondent denies the 

statement as untrue and leaves Petitioner to its proofs.

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16. Request for relief and no response is necessary. To the extent a response is required, 

Respondent denies the statement as untrue and leaves Petitioner to its proofs. 

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: September 17, 2026

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STATE OF MICHIGAN 

DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS 

MICHIGAN TAX TRIBUNAL 

 

INDIAN TRAILS, LLC f/k/a 

INDIAN TRAILS, INC., 

 

Petitioner, 

v. 

 

 

 

 

 

 

 

Docket No. 26-001466 

 

CITY OF DETROIT, 

 

Respondent. 

________________________________/ 

 

PROOF OF SERVICE 

 

On September 17, 2026, I sent by First Class U.S. mail a copy of Respondent’s Answer 

w/Affirmative Defenses in the instant matter to: 

 

Deborah J. Ondersma 

Adam J. Brody 

Varnum LLP 

333 Bridge Street, N.W. 

P.O. Box 352 

Grand Rapids, MI. 49501 

 

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) 

 

 

 

 

 

 

Senior Assistant Corporation Counsel 

 

 

 

 

 

 

City of Detroit Law Department 

 

 

 

 

 

 

Coleman A. Young Municipal Center 

 

 

 

 

 

 

2 Woodward Avenue, Suite 500 

Dated: September 17, 2026 

 

Detroit, Michigan 48226

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