On September 29, 2021 a
Motion,Ex Parte
was filed
involving a dispute between
Founders Insurance Company,
and
Hamilton-Little, Quinte,
for SUBROGATION
in the District Court of Summit County.
Preview
CV-2021-09-3089 MICHAEL, KATHRYN 02/10/2022 09:11:14 AM MOTI Page 1 of 2
127091 HLN/nab
IN THE COURT OF COMMON PLEAS
SUMMIT COUNTY, OHIO
Founders Insurance Company
CASE NO. CV-2021-09-3089
Plaintiff
JUDGE: KATHRYN MICHAEL
vs.
Quinte J. Sammual Hamilton-Little PLAINTIFE’S MOTION TO DEEM
SERVICE PERFECTED
Defendant
Now comes Plaintiff, by and through its undersigned counsel, and moves this Honorable
Court to deem service perfected upon the Defendant on December 3, 2021 by FedEx at the 305
Bell St., Barberton, Ohio 44203 address, signed for by "M. Hamilton.” Plaintiff is hereby
providing proof of delivery from FedEx tracking number 424087363893, attached as Exhibit A.
Plaintiff states that this Motion is not made for the purposes of delay.
Plaintiff's proposed Order is attached hereto.
Respectfully submitted,
/s/ Herbert L. Nussle
Herbert L. Nussle 0063551
Patrick J. O'Malley 0064987
KEIS | GEORGE llp
Attorneys for Plaintiff
55 Public Square, #800
Cleveland, Ohio 44113
216.241.4100 / F 216.771.3111
hnussle@keisgeorge.com
pomalley@keisgeorge.com
Sandra Kurt, Summit County Clerk of Courts
CV-2021-09-3089 MICHAEL, KATHRYN 02/10/2022 09:11:14 AM MOTI Page 2 of 2
FedEx. February 09, 2022
Dear Customer,
The following is the proof-of-delivery for tracking number: 424087363893
Delivery Information:
Status: Delivered Delivered To: Residence
Signed for by: M.HAMILTON Delivery Location:
Service type: FedEx Express Saver
Special Handling: Deliver Weekday; BARBERTON, OH,
Residential Delivery;
Direct Signature Required
Delivery date: Dec 3, 2021 14:45
‘Shipping Information:
Tracking number: 424087363893 Ship Date: Dec 2, 2021
Weight: 0.5 LB/0.23 KG
Recipient: ‘Shipper:
BARBERTON, OH, US, AKRON, OH, US,
Reference V2021093089_3012943
Department Number Legal Division
Proof-of-delivery details appear below; however, no signature is available for this FedEx Express shipment
because a signature was not required.
Thank you for choosing FedEx
Sandra Kurt, Summit County Clerk of Courts
Document Filed Date
February 10, 2022
Case Filing Date
September 29, 2021
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CV-2021-09-3089 MICHAEL, KATHRYN 02/10/2022 09:11:14 AM MOTI Page 1 of 2 127091 HLN/nab IN THE COURT OF COMMON PLEAS SUMMIT COUNTY, OHIO Founders Insurance Company CASE NO. CV-2021-09-3089 Plaintiff JUDGE: KATHRYN MICHAEL vs. Quinte J. Sammual Hamilton-Little PLAINTIFE’S MOTION TO DEEM SERVICE PERFECTED Defendant Now comes Plaintiff, by and through its undersigned counsel, and moves this Honorable Court to deem service perfected upon the Defendant on December 3, 2021 by FedEx at the 305 Bell St., Barberton, Ohio 44203 address, signed for by "M. Hamilton.” Plaintiff is hereby providing proof of delivery from FedEx tracking number 424087363893, attached as Exhibit A. Plaintiff states that this Motion is not made for the purposes of delay. Plaintiff's proposed Order is attached hereto. Respectfully submitted, /s/ Herbert L. Nussle Herbert L. Nussle 0063551 Patrick J. O'Malley 0064987 KEIS | GEORGE llp Attorneys for Plaintiff 55 Public Square, #800 Cleveland, Ohio 44113 216.241.4100 / F 216.771.3111 hnussle@keisgeorge.com pomalley@keisgeorge.com Sandra Kurt, Summit County Clerk of Courts CV-2021-09-3089 MICHAEL, KATHRYN 02/10/2022 09:11:14 AM MOTI Page 2 of 2 FedEx. February 09, 2022 Dear Customer, The following is the proof-of-delivery for tracking number: 424087363893 Delivery Information: Status: Delivered Delivered To: Residence Signed for by: M.HAMILTON Delivery Location: Service type: FedEx Express Saver Special Handling: Deliver Weekday; BARBERTON, OH, Residential Delivery; Direct Signature Required Delivery date: Dec 3, 2021 14:45 ‘Shipping Information: Tracking number: 424087363893 Ship Date: Dec 2, 2021 Weight: 0.5 LB/0.23 KG Recipient: ‘Shipper: BARBERTON, OH, US, AKRON, OH, US, Reference V2021093089_3012943 Department Number Legal Division Proof-of-delivery details appear below; however, no signature is available for this FedEx Express shipment because a signature was not required. Thank you for choosing FedEx Sandra Kurt, Summit County Clerk of Courts