Respondent's Answer to Petition.pdf
Canterbury Square LLC, Petitioner Vs. City Of Troy, Respondent · 25-001803-TT
Text extracted from the reviewed PDF, organized by page. OCR and reading order may contain errors; confirm details in the PDF below.
Page 1
STATE OF MICHIGAN DEPARTMENT OF LICENSING AND REGULATORY AFFAIRS MICHIGAN TAX TRIBUNAL CANTERBURY SQUARE, LLC Petitioner, : MTT Docket: 25-001803 V Parcel ID 88-20-13-228-019 CITY OF TROY, Respondent. / JAY A. SCHWARTZ LORI GRIGG BLUHM (P46908) PROPERTY TAX REDUCTION SERVICES, TROY CITY ATTORNEY LCC. Attorney for Respondent Petitioner Representative 500 W. Big Beaver Road 37887 West Twelve Mile Rd. Troy, MI 48084 Suite B (248) 524-3320 Farmington Hills, MI 48331 BluhmLG@TroyMl.qov (248) 672-1922 JSchwartz@propertytaxreductionservices.org RESPONDENT'S ANSWER TO PETITION 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 admits the allegation. 2. As to Paragraph 2, Respondent admits the allegation. 3. As to Paragraph 3, No answer is required.
Page 2
7. As to Paragraph 7, No answer is required. 8. As to Paragraph 8, No answer is required. 9. As to Paragraph 9, No answer is required. 10. As to Paragraph 10, Respondent admits the allegation. 11. As to Paragraph 11, Respondent admits the allegation. 12. As to Paragraph 12, Respondent neither admits nor denies the allegation, and leaves Petitioner to its proofs. 13. As to Paragraph 13, Respondent denies that Petitioner has any support for its challenge to the subject property’s true cash and taxable values. 14. As to Paragraph 14, Respondent admits the allegation. 15. As to Paragraph 15, No answer is required. 16. As to Paragraph 16, Respondent admits the allegation. 17. As to Paragraph 17, Respondent denies that Petitioner has any support or basis for its contention of the true cash, assessed and taxable values for the Subject Property. 18. As to Paragraph 18, Respondent does not contest the Petitioner's math calculations, but denies that Petitioner has any support or basis for its contention of the true cash, assessed, and taxable values for the subject property. 19. As to Paragraph 19, Respondent denies that Petitioner is entitled to its requested relief. 20. As to Paragraph 20, Respondent denies that Petitioner has set forth a viable claim
Page 3
WHEREFORE, Respondent, CITY OF TROY, requests the Tribunal dismiss the Petition, affirm or increase the assessed and taxable values for the subject property, subject to county and state equalization, and award Respondent its costs and attorney fees. Dated: September 22, 2025 /s/ Lori Grigg Bluhm Lori Grigg Bluhm (P46908) City of Troy Attorney's Office Attorney for Defendant 500 W. Big Beaver Road Troy, MI 48084 (248) 524-3320 BluhmLG@troymi.gov
Page 4
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 applied in the case of all properties in the City of Troy for 2024. Any decrease in the value of Petitioner's properties was a result of its own intentional acts and/or negligence and cannot be allowed to reduce Petitioner's otherwise equitable tax burden. Respondent has properly and lawfully assessed Petitioner's property and established its assessed and taxable values in accordance with statutory and constitutional requirements. Respondent reserves the right to argue additional Affirmative Defenses during the
Page 5
affirmed or increased, that Petitioners’ Petition be dismissed with prejudice, and that Respondent be granted costs and attorney fees so wrongfully sustained. Dated: September 22, 2025 [sl Lori Grigg Bluhm Lori Grigg Bluhm (P46908) City of Troy Attorney’s Office Attorney for Defendant 500 W. Big Beaver Road Troy, MI 48084 (248) 524-3320 BluhmLG@troymi.gov Certificate of Service | hereby certify that on September 22, 2025, | served a copy of this Answer and Affirmative Defenses via email to Petitioner's representative Jay A. Schwartz at JSchwartz@PropertyTaxReductionServices.org and to the following via first class mail: Michigan Department of Treasury, State Treasurer, 430 W. Allegan, Lansing, MI 49822; Secretary of School Board, Troy Public Schools, 4400 Livernois Road, Troy, MI 48084; 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. i j x Dated: September 22, 2025 Da le M NAGA LL Haley M. Cranston City of Troy Attorney's Office 500 W. Big Beaver Road Troy, MI 48084