Daily Legal News - Common Pleas Notices
924867—Fanger & Associates, LLC vs. Naomi Kirk.
Naomi Kirk, whose last known place of residence is 329 Great Oaks Trails, Wadsworth, OH 44281, otherwise whose place of residence is unknown, will take notice that on November 11, 2019, the undersigned, Fanger & Associates, LLC, filed its complaint in the Court of Common Pleas, 1200 Ontario Street, Cleveland, Ohio 44113, of Cuyahoga County, Ohio, alleging that on or about November 14, 2016, Defendant Naomi Kirk (hereinafter referred to as Defendant) retained Plaintiff, Fanger & Associates, LLC, for legal services and representation; that Defendant currently owes, (less all applicable payments, credits and deposits) to Plaintiff the sum of $25,562.81 as of November 1, 2019 at terms Due Upon Invoice with interest at the rate of 1.5% per month; that Plaintiff has fulfilled all its duties and obligation of representation agreed to between the parties with the exception, if any, of any duties not billed for that remain uncompleted due to actions or inaction of Defendant.
The Defendant has directly benefited and has been unjustly enriched from the services provided by the Plaintiff. The Defendant's failure to pay the sum due and owing to the Plaintiff operates to unjustly enrich the Defendant who has benefited from legal services delivered by the Plaintiff.
Wherefore, Plaintiff demands judgment against the Defendant(s) on Count One and Two of its Complaint in the sum of $25,562.81, plus interest thereon at the rate of 1.5% per month, from November 1, 2019, reasonable attorney fees and its costs herein, and such other and further relief to which Plaintiff may be entitled.
The defendant named above is required to answer on or before the 11th day of May, 2020.
Fanger & Associates, LLC.
By Jeffrey J. Fanger and Gerry Davidson, Attorneys for Plaintiff.