Preview
T/W 375.00
LUCAS COUNTY COMMON PLEAS COURT
FORECLOSURE CASE DESIGNATION
G-4801-TF-0202401 235-000
TO: J. Bernie Quilter, Clerk of Courts CASE NO.
Judge Eric Allen Marks
JUDGE
The following type of foreclosure case is being filed:
Foreclosure (E)
Ejowrer Occupied Property
O Commercial! Docket
[2] Tenant Occupied Property
NOTE: Pursuant to Gen.R. 8.02(A)(2), counsel for plaintiff must serve notice by
ordinary mail to the occupier/tenant that a foreclosure complaint has been filed.
[Wacant Property
NOTE: Clerk of Courts is to provide a copy of this designation form to the
assigned Judge.
[Taxes being challenged on amount or priority of lien.
By submitting the complaint, with the signature of the Attorney, the Attorney affirms that
the name of person with settlement authority and his/her direct phone number will be
provided upon request to a party or counsel in this matter
This case was previously dismissed pursuant to CIVIL RULE 41 and is to be assigned to
Judge , the original Judge at the time of dismissal. The
previously filed case number was Cl.
Attorney
Joseph P. Boyle, tll (0042440)
Address
One Government Center, Suite 500
Toledo, Ohio 43604
Telephone (419) 213-4061
EFILED LUCAS COUNTY
6/13/2024 10:31 AM
COMMON PLEAS COURT
BERNIE QUILTER, CLERK
EFILE ID: 114581
IN THE COMMON PLEAS COURT OF LUCAS COUNTY, OHIO
G-4801-TF-0202401 235-000
Treasurer of Lucas County, Ohio, Case No.
Year Certified: 2017
Plaintiff Permanent Parcel No.: 20-96704
vs.
COMPLAINT
Kuhn Family Ventures, LLC, an Ohio
Limited Liability Company aka Kuhn Julia R. Bates
Family Ventures, LLC Prosecuting Attorney
c/o Tracy Kuhn, S.A. By: Joseph P. Boyle, III (#0042440)
P.O. Box 2592 Maureen O. Atkins (#0063379)
Whitehouse, Ohio 43571 Thomas E. Puffenberger (#0082782)
One Government Center
and Suite 500
Toledo, Ohio 43604
The Waterville Gas Company Phone: (419) 213-2602
P.O. Box 259 Fax: (419) 213-4070
Waterville, Ohio 43566 Email: jboyle@co.lucas.oh.us
matkins@co.lucas.oh.us
and tepuffen@co.lucas.oh.us
Judge Eric Allen Marks
K Kern Painting, LLC Judge
c/o Phil Cook, CEO/ COO
211 N. Reynolds Road
Toledo, Ohio 43615
and
City of Toledo
Department of Development
c/o John Mattimoe, Esq.
One Government Center, Suite 2250
Toledo, Ohio 43604
and
City of Toledo,
Department of Public Utilities
c/o Dale Emch, Law Director
One Government Center, Suite 2250
Toledo, Ohio 43604
Defendant(s)
1. Plaintiff, Lindsay M. Webb, says that she is the duly elected and qualified Treasurer of Lucas
County, Ohio. On the 8th day of March, 2024, the Lucas County Auditor duly filed with the Lucas County
Treasurer a delinquent tax list/list of delinquent tracts pursuant to Chapter 5721 of the Ohio Revised Code,
the relevant tract of which is more particularly described as follows:
Lot number one hundred seventy-six (176) in Weston Gardens, First
Extension in the City of Toledo, Lucas County, Ohio, in accordance with
Volume 42A of Plats, page 16. (T.D. 20 Parcel 96704)
The taxes, assessments, penalties, interest and charges upon said property remain unpaid.
2. Plaintiff further states that there is now due and owing the below sum which amount represents
the taxes, assessments, penalties and interest against said property:
T.D. Parcel Delinquency
20-96704 $10,644.53
That said taxes continue to accrue on the real estate. That the amount of money appearing to be due and
unpaid on the delinquent land list is due and unpaid and is a lien against the property described.
3. Defendant City of Toledo, Department of Development may claim to have an interest in the
subject real property under the provisions of Chapter 5722 of the Ohio Revised Code. Defendant City of
Toledo, Department of Development is being joined as a party defendant as notice by the Prosecuting
Attomey of Lucas County, Ohio to said defendant City of Toledo, Department of Development that this
foreclosure has been commenced as to the parcel described as required by Section 5722.03 of the Ohio
Revised Code. Failure of defendant City of Toledo, Department of Development to notify the Prosecuting
Attorney by timely answer certified to the Prosecuting Attorney, ofany election after receipt of notice shall
be an election by City of Toledo, Department of Development not to acquire the parcel described.
4. Defendants Kuhn Family Ventures, LLC, an Ohio Limited Liability Company aka Kuhn Family
Ventures, LLC, The Waterville Gas Company, K Kern Painting, LLC and City of Toledo, Department of
Public Utilities have or claim to have some interest as set forth in the title work attached hereto. That said
interest or lien, if any, is inferior and subsequent to the Plaintiff's lien and prays that said defendants be
required to set up their lien or claims or forever be barred from asserting same against the described
property.
5. If the owner of the property that is the subject of this foreclosure complaint is not the occupier
of the property, notice that a foreclosure complaint is being filed was sent by regular U.S. Mail to the
occupier(s) tenant(s) for the property pursuant to Local Rule 8.02(A) (2).
6. {ifapplicable] Plaintiff states that this action in foreclosure proceedings is convened under
provisions of Sections 323.25 and/or 5721.18 and/or 323.65 to 323.79 of the Ohio Revised Code, that the
parcel(s) constitutes abandoned lands pursuant to R.C. 323.65 to 323.79 or are non-productive land as
defined in R.C. $722.01(F).
WHEREFORE, Plaintiff prays that the defendants be notified of the pendency and prayer of the
complaint; that the Court upon hearing determine the amount of taxes, assessments, penalties and interest
and that the State of Ohio has the first lien against the premises and that such lien be foreclosed; that the
defendants be required to set up what, if any, interest they may have in said property, or be forever barred
from asserting the same; the Court will determine the respective amounts due to the defendants and the
priorities of their liens; that upon determination of the amount due for taxes, assessments, penalties,
interest, and charges to date of sale or transfer, the Court will order said property to be directly conveyed
to an eligible township, municipality, county, school district, land reutilization corporation, or community
development group pursuant to Revised Code Sections 323.26, 323.28, 323.65 to 323.79, or $721.19 (1),
or sold by the Sheriffof this county in accord with the laws of the State of Ohio; that unless the amount
found due the Plaintiff together with all costs of this proceeding be tendered to the Plaintiff prior to the
conveyance or confirmation of sale, or the expiration of the alternative right of redemption if ordered by
the Court as prescribed in Sections 323.65(J), 323.28, or 323.78 and 5721.19(F)(2) of the Revised Code,
and demonstrate that the property is in compliance with all applicable zoning regulations, land use
restrictions and building, health, and safety codes as prescribed in Sections 323.25, 323.69 and $721.25 of
the Revised Code, then the equity of redemption of said parties shall be foreclosed; that an Order to Convey
Title or Order of Sale be issued to the Sheriff of Lucas County directing him to either convey directly the
property to an eligible township, municipality, county, school district or land reutilization corporation or
community development group pursuant to Revised Code Chapters 323 or 5721, or advertise and sell the
property at public sale in accord with the laws of the State of Ohio; and for such other and further reliefto
which she may be entitled.
Respectfully submitted,
Treasurer of Lucas County, Ohio,
Julia R. Bates, Prosecuting Attorney Lucas County, Ohio
/s/Joseph P. Boyle, III
Assistant Prosecuting Attorney
PARID: 2096704 ASSESSOR #: 05424051
NBHD: 1312R ROLL: RP_OH
KUHN FAMILY VENTURES LLC AN OHIO LIMITED 629 FOREDALE AVE
PRO Codes: 2FCL
Current Values
Tax Year 2023 Land Building Total
Appraised Value (100%) 12,400 15,600 28,000
Assessed Value (35%) 4,340 5,460 9,800
Roll Values (100%) 12,400 15,600 28,000
Roll Values (35%) 4,340 5,460 9,800
Other Values
Hmstd Red. Val. Forest Red. Val. CAUV Red. Val. CAUV Savings Recoupment Gross Rate
Q oO 0 0.00 0.00 101.47
Current Taxes
1st Half 2nd Half
Tax Year 2023:
General; 496.92 496.92
House Bill 920: 172.33 172.33
Non-Business Credit: 27,97 27.97
Owner Occupied Credit: 0.00 0.00
Homestead Reduction: 0.00 0.00
Net General: 296.62 296.62
Adjustment General: 0.00 0.00
Penalty General: 29.66 0.00
interest General:
Jan-Aug Int 0.00 0.00
Sept-Dec Int: 306.73 0.00
Prior General: 3,281.48 4,386.60
Prior Years Adjustments: 0.00 0.00
Net Special Assessments 90.86 90.84
Adjustment Special Assessments: 0.00 0.00
Penalty Special Assessments: 9.09 0.00
Interest Special Assessments:
Jan-Aug int 0.00 0.00
Sept-Dec int: 86.28 0.00
Prior Years Special Assessments 924.81 1,232.40
Prior Years Special Assessments Adjustments: 0.00 0.00
Prior Delinquent Charges 10,218.30
Ist ‘Half Tax, Assessments, and/or Penalty/interest 426.23
* 1st Half Total Before Payments 10,644.53
2nd Half Tax, Assessments, and/or Penalty/interest 387.46
* Full Year Total Before Payments 11,031.99
** TOTAL PAYMENTS ** 0.00
** TOTAL DUE AFTER PAYMENTS: ** 11,031.99
Last Change Date: Feb 09, 2024
Last Payment Date:
Notes on Taxes
= Ist Half Total Before Payments includes 1st half taxes, assessments,
any penalty, any interest, and any delinquent amount.
- Full Year Total Before Payments includes 1st and 2nd half taxes, assessments,
any penalty, any interest, and any delinquent amount,
MAR 08 2024 FIRST HALF DELINQUENT TRE EIST = 2023 FOR ROLLTYPE : RP_OH 4,758
10:16 TAX DIST/NAME:; 20 ‘TOLEDO CITY - TOLEDO TX1020H
PARID/STUB/PROJECT PR INTEREST A-TAX ASPEN B-TAX B-PEN TOTAL NAME/LEGAL ACRES
20-96704 KUHN FAMILY VENTURES LLC*CER DEL*2017
40.46 20.79 2.50 0.25 0.00 0.00 64.00 LIABILITY COM ‘cobs A
0000F 1052.72 936.38 66.63 6.66 0:00 0.00 2662.39 WESTON GDNS 1ST EXTN Lor 176 6.0000
ooooL 131:86 72.63 0.63 0:00 0.00 211.42
0000 25.93 12:87 1.67 0117 0:00 40.64
0000T™ 229.45 120.40 137 1.38 0.00 0.00 364
5226.20 2748.61 296.62 23.66 0:00 010
‘SUM 6706 62 3511.68 387.48 38,75 0.00 0100 10644.53*
“20-56707 TOLEDO REALTY A LLC *CER DEL*2023
REAL 9,00 0.00 15.69 0.78 0.00 9.00 16.47 CODE A
9000 0100 0:00 0.09 9.00 0.00 0.00 0.09 WESTON GDNS 1ST EXTN LOT 177 0.0000
00007™ 0100 0:00 0.66 0.03 0.00 0.00 0.69
00001, 0100 90.90 0.30 0.02 0.00 0,00 0:32
0,00 0.00 0.12 0.02 0.00 0.00 0.13
0000F 9.00 0:00 3147 0116 0.00 9,00 3.33
0.00 0.00 20.03 0199 0.00 0,00 21.02"
20-96714 MODERN SPACE PROPERTIES LLC
REAL 0.00 0.00 325.38 32 54 0.00 9.00 357.92 6.0000
0:00 2.50 25 0.00 010 2.75 WESTON GDNS 1ST EXTN LOT 179
0000 0.00 9.00 1:83 18 0.00 9.00 2.01 c
ooooTm 0:00 0,00 13.76 38 0:00 9.00 15114
0000L 0:00 0.00 63 0:00 9,00 6.93
0000F 0:00 0.00 66.63 66 0.00 9.00 73.23
SUM 0,00 0.00 416.40 4h 64 9.00 0.00 458.04*
20-96781 KHAN KHALIF *CER_DEL*2020
0000 4.99 1.22 0.56 0.06 0.00 0.00 6.83
govern 199140 41.96 25.60 2.56 0.00 0:00 269.52 WESTON GDNS 1ST EXTN LOT 199 6.0000
948.95 241.33 99.59 9.96 0.00 9.00 1299.83 c
boodn 113.36 24.78 41.72 1117 9:00 0100 151,03
14.31 408 0.00 9.00 0100 28.33
o00or 1901.26 228.17 123.92 12,39 9.00 e100 1365.74
2282.27 541.54 261.39 26.34 9.00 0.00 311134
\
20-96791 FLORIO GRISELDA CANO ETA*CER DEL*2023
1354.06 54.16 614.41 61.44 0.00 0.00 2084.07 DE A
0000L 0.61 6.30 0.63 0:00 0.00 22.70 WESTON GONS 1ST EXTN LOT 202 0.0000
5150 0122 2.50 0125 0:00 0.00 8147
o000T™M 30.38 1122 13.76 1.38 0.00 0.00 46.74
0000F 128.65 5.15 66.63 6.66 0:00 0.00 207.09
0000 0133 3.58 0:00 6.00
SUM 1541.54 61.67 707.44 70.71 0:00 0100 2381.06*
hea, Preliminary Judicial Report
First American Title™ ISSUED BY
WwYY Svs
First American Title Insurance Company
REPORT NUMBER:
Judicial Report ce
Guaranteed Party Name: Lucas County Treasurer File No.: 68453
Guaranteed Party Address: One Government Center Effective Date: 5/13/2024 @ 06:30 AM
City, State, Zip: Toledo, OH 43604
Pursuant to your request for a Preliminary Judicial Report (hereinafter “the Report’) for use in judicial proceedings, FIRST
AMERICAN TITLE INSURANCE COMPANY (hereinafter “the Company”) hereby guarantees in an amount not to exceed
$ 11,031.99 that it has examined in the public records in LUCAS County, Ohio as to the land described in Schedule A,
that the record title to the land is at the date hereof vested in Kuhn Family Ventures, LLC, an Ohio Limited Liability
Company by instrument recorded in 20180816-0035695 and free from all encumbrances, liens or defects of record,
except as shown in Schedule B.
This is a guarantee of the record title only and is made for the use and benefit of the Guaranteed Party and the purchaser
at judicial sale thereunder and is subject to the Exclusions from Coverage, the Exceptions contained in Schedule B and
the Conditions and Stipulations contained herein.
This Report shall not be valid or binding until it has been signed by either an authorized agent or representative of the
Company and Schedules A and B have been attached hereto.
Tn Witness Whereof, First American Title Insurance Company has caused its corporate name to be hereunto affixed by its
authorized officers as of Date of Policy shown in Schedule A.
First American Title Insurance Company For Reference:
File #: 68453
OM P-feBrm
Policy #:
Issued By:
AREA Title Agency, Inc.
Kenneth D. DeGlorgio, President
Hy Fad
3234 Executive Parkway, Suite 107
Toledo, OH 43606
Account No: om
Telephone: (419) 242-5485
Greg L. Smith, Secretary
By: This Jacket was created electrontcally and constitutes an original document
Authorized Coundinatyp
Form 5007339 (9-1-14) Page 1 of 2 Preliminary Judicial Report (4-15-10)
Ohio
Order Number: 68453
Report Number: 5007339-0060148e
First American Title Insurance Company
Schedule A
Description of Land
Lot number one hundred seventy-six (176) in Weston Gardens, First Extension in the City of Toledo, Lucas
County, Ohio, in accordance with Volume 42A of Plats, page 16.
(Tax Parcel No. 20-96704)
ALTA Preliminary Judicial Report
Order Number: 68453
Report Number: 5007339-
0060148c
Preliminary Judicial Report
SCHEDULE B
The matters shown below are exceptions to this Preliminary Judicial Report and the Company assumes
no liability arising therefrom.
1 Commonly Known As: 629 Foredale Ave., Toledo, OH 43609
On January 15, 2022, a Judgment Lien Certificate was filed in the Common Pleas Court of Lucas County,
Ohio, Certificate Number LNO202203725, wherein it appears that a judgment was rendered in favor of City
of Toledo Dept of Public Utilities, against Kuhn Family Ventures, LLC, for $3,121.20 with interest and for
costs.
NOTE: The above was refiled on January 19, 2024 as Judgment Lien Number LNO202402540, Filed by
Thomas L, Sooy, Attorney.
Affidavit for Mechanic's Lien filed for record in the Office of the County Recorder, Lucas County, Ohio, on
September 21, 2021 as Instrument Number 20210921-0050010, copy attached.
On April 22, 2022, a Judgment Lien Certificate was filed in the Common Pleas Court of Lucas County, Ohio,
Certificate Number LNO202201644, wherein it appears that a judgment was rendered in favor of The
Waterville Gas Company, PO Box 259 Waterville, OH 43566, against Kuhn Family Ventures LLC, for
$919.42 with interest and for costs. Filed by M. Charles Collins, Attorney.
Taxes for the first half of 2023, including delinquencies, penalties and interest, total $10,644.53 and are
unpaid, The half tax amount is $387.46. (Tax Parcel Number 20-96704)
Taxes for second half of 2023 are a lien not yet due and payable.
Taxes for the year 2024 are a lien not yet due and payable.
Subsequent years' installments are not yet due and payable.
No examination for special assessments not yet certified to the county Auditor/Treasurer's Office.
No liability is assumed by the Company for tax increases occasioned by retroactive revaluation or changes in
land usage or loss of any Homestead Exemption status for the insured premises.
NOTE: The above figures are taken from the Auditor/Treasurer's Office computer. We assume no liability
for any variance between the above figures and different figures hereafter shown on any current or future tax
bills,
Delinquent sewer bills, water bills, charges for weed cutting, cleaning up trash and other nuisance abatement
charges may become a lien on the real estate. No liability is assumed by the Company for ascertaining the
status of these charges. The proposed insured is cautioned to obtain the current status of these charges, if any.
We have made no examination as to building lines, easements, rights of way or restrictions and terms and
conditions of record in Lucas County, Ohio.
Policy #:
CONDITIONS AND STIPULATIONS OF THIS PRELIMINARY JUDICIAL REPORT
Definition of Terms receives actual notice that they may be required to pay money
(a) “Guaranteed Party’: The party or parties named herein or or other compensation for a matter covered by this Report or
the purchaser at judicial sale. actual notice someone claims an interest in the Land covered by
(b) “Guaranteed Claimant”: Guaranteed Party claiming loss or this Report.
damage hereunder. Extent of Liability
() “Land”: The land described specifically or by reference in The liability of the Company shall in no case exceed in all the
Schedule A, and improvements affixed thereto, which by amount stated herein and shall in all cases be limited to the
law constitute real property; provided however the term actual loss, including but not limited to attorneys fees and costs
“land” does not include any property beyond the lines of the of defense, only of the Guaranteed Claimant. Any and all
area specifically described or referred to in Schedule A, nor payments under this Report shall reduce the amount of this
any right, title, interest, estate, or easement in abutting Report pro tanto and the Company's liability shall terminate
streets, roads, avenues, lanes, ways or waterways. when the total amount of the Report has been paid.
(d) “Public Records”: Those records under state statute and, if Options to Pay or Otherwise Settle Claims; Termination of
a United States District Court resides in the county in which Liability
the Land is situated, the records of the clerk of the United The Company in its sole discretion shall have the following
States District Court, which impart constructive notice of options:
matters relating to real property to purchasers for value (a) To pay or tender to the Guaranteed Claimant the amount of
without knowledge and which are required to be the Report or the balance remaining thereof, less any
maintained in certain public offices in the county in which attorneys fees, costs or expenses paid by the Company to
the land is situated. the date of tender. If this option is exercised, all liability of
Determination of Liability the Company under this Report terminates including but
This Report together with any Final Judicial Report or any not limited to any liability for attorneys fees, or any costs of
‘Supplement or Endorsement thereof, issued by the Company is defense or prosecution of any litigation.
the entire contract between the Guaranteed Party and the (b) To pay or otherwise settle with other parties for or in the
Company. name of the Guaranteed Claimant any claims guaranteed
Any claim of monetary loss or damage, whether or not based on by this Report.
negligence, and which arises out of the status of the title to the () To continue, re-open or initiate any judicial proceeding in
estate or interest guaranteed hereby or any action asserting order to adjudicate any claim covered by this Report. The
such claim, shall be restricted to this Report. Company shall have the right to select counsel of its choice
Liability of Company (subject to the right of the Guaranteed Claimant to object
This Report is a guarantee of the record title of the Land only, as for reasonable cause) to represent the Guaranteed
disclosed by an examination of the Public Records herein Claimant and will not pay the fees of any other counsel.
defined. (d) To pay or tender to the Guaranteed Claimant the difference
Notice of Claim to be given by Guaranteed Party between the value of the estate or interest as guaranteed
In case knowledge shall come to the Guaranteed Party of any and the value of the estate or interest subject to the defect,
lien, encumbrance, defect, or other claim of title guaranteed lien or encumbrance guaranteed against by this Report.
against and not excepted in this Report, whether in a legal Notices
proceeding or otherwise, the Guaranteed Party shall notify the All notices required to be given to the Company shall be given
Company within a reasonable time in writing and secure to the promptly and any statements in writing required to be furnished
Company the right to oppose such proceeding or claim, or to to the Company shall be addressed to First American Title
remove said lien, encumbrance or defect at its own cost. Any Insurance Company, Attn: Claims National Intake Center, 5
action for the payment of any loss under this Report must be First American Way, Santa Ana, California 92707, Phone
commenced within one year after the Guaranteed Party 888-632-1642 (claims.nic@firstam.com).
EXCLUSIONS FROM COVERAGE
The Company assumes no liability under this Report for any 4 The Company assumes no liability under this Report for the
loss, cost or damage resulting from any physical condition of the proper form or execution of any pleadings or other documents to
Land. be filed in any judicial proceedings.
The Company assumes no liability under this Report for any The Company assumes no liability under this Report for any
loss, cost or damage resulting from any typographical, clerical or loss, cost, or damage resulting from the failure to complete
other errors in the Public Records. service on any parties shown in Schedule B of the Preliminary
The Company assumes no liability under the Report for matters Judicial Report and the Final Judicial Report or any
affecting title subsequent to the date of this Report or the Final Supplemental Report issued thereto.
Judicial report or any supplement thereto.
Form 5007339 (9-1-14) Page 2 of 2 Preliminary Judicial Report (4-15-10)
Ohio
Preview
T/W 375.00 LUCAS COUNTY COMMON PLEAS COURT FORECLOSURE CASE DESIGNATION G-4801-TF-0202401 235-000 TO: J. Bernie Quilter, Clerk of Courts CASE NO. Judge Eric Allen Marks JUDGE The following type of foreclosure case is being filed: Foreclosure (E) Ejowrer Occupied Property O Commercial! Docket [2] Tenant Occupied Property NOTE: Pursuant to Gen.R. 8.02(A)(2), counsel for plaintiff must serve notice by ordinary mail to the occupier/tenant that a foreclosure complaint has been filed. [Wacant Property NOTE: Clerk of Courts is to provide a copy of this designation form to the assigned Judge. [Taxes being challenged on amount or priority of lien. By submitting the complaint, with the signature of the Attorney, the Attorney affirms that the name of person with settlement authority and his/her direct phone number will be provided upon request to a party or counsel in this matter This case was previously dismissed pursuant to CIVIL RULE 41 and is to be assigned to Judge , the original Judge at the time of dismissal. The previously filed case number was Cl. Attorney Joseph P. Boyle, tll (0042440) Address One Government Center, Suite 500 Toledo, Ohio 43604 Telephone (419) 213-4061 EFILED LUCAS COUNTY 6/13/2024 10:31 AM COMMON PLEAS COURT BERNIE QUILTER, CLERK EFILE ID: 114581 IN THE COMMON PLEAS COURT OF LUCAS COUNTY, OHIO G-4801-TF-0202401 235-000 Treasurer of Lucas County, Ohio, Case No. Year Certified: 2017 Plaintiff Permanent Parcel No.: 20-96704 vs. COMPLAINT Kuhn Family Ventures, LLC, an Ohio Limited Liability Company aka Kuhn Julia R. Bates Family Ventures, LLC Prosecuting Attorney c/o Tracy Kuhn, S.A. By: Joseph P. Boyle, III (#0042440) P.O. Box 2592 Maureen O. Atkins (#0063379) Whitehouse, Ohio 43571 Thomas E. Puffenberger (#0082782) One Government Center and Suite 500 Toledo, Ohio 43604 The Waterville Gas Company Phone: (419) 213-2602 P.O. Box 259 Fax: (419) 213-4070 Waterville, Ohio 43566 Email: jboyle@co.lucas.oh.us matkins@co.lucas.oh.us and tepuffen@co.lucas.oh.us Judge Eric Allen Marks K Kern Painting, LLC Judge c/o Phil Cook, CEO/ COO 211 N. Reynolds Road Toledo, Ohio 43615 and City of Toledo Department of Development c/o John Mattimoe, Esq. One Government Center, Suite 2250 Toledo, Ohio 43604 and City of Toledo, Department of Public Utilities c/o Dale Emch, Law Director One Government Center, Suite 2250 Toledo, Ohio 43604 Defendant(s) 1. Plaintiff, Lindsay M. Webb, says that she is the duly elected and qualified Treasurer of Lucas County, Ohio. On the 8th day of March, 2024, the Lucas County Auditor duly filed with the Lucas County Treasurer a delinquent tax list/list of delinquent tracts pursuant to Chapter 5721 of the Ohio Revised Code, the relevant tract of which is more particularly described as follows: Lot number one hundred seventy-six (176) in Weston Gardens, First Extension in the City of Toledo, Lucas County, Ohio, in accordance with Volume 42A of Plats, page 16. (T.D. 20 Parcel 96704) The taxes, assessments, penalties, interest and charges upon said property remain unpaid. 2. Plaintiff further states that there is now due and owing the below sum which amount represents the taxes, assessments, penalties and interest against said property: T.D. Parcel Delinquency 20-96704 $10,644.53 That said taxes continue to accrue on the real estate. That the amount of money appearing to be due and unpaid on the delinquent land list is due and unpaid and is a lien against the property described. 3. Defendant City of Toledo, Department of Development may claim to have an interest in the subject real property under the provisions of Chapter 5722 of the Ohio Revised Code. Defendant City of Toledo, Department of Development is being joined as a party defendant as notice by the Prosecuting Attomey of Lucas County, Ohio to said defendant City of Toledo, Department of Development that this foreclosure has been commenced as to the parcel described as required by Section 5722.03 of the Ohio Revised Code. Failure of defendant City of Toledo, Department of Development to notify the Prosecuting Attorney by timely answer certified to the Prosecuting Attorney, ofany election after receipt of notice shall be an election by City of Toledo, Department of Development not to acquire the parcel described. 4. Defendants Kuhn Family Ventures, LLC, an Ohio Limited Liability Company aka Kuhn Family Ventures, LLC, The Waterville Gas Company, K Kern Painting, LLC and City of Toledo, Department of Public Utilities have or claim to have some interest as set forth in the title work attached hereto. That said interest or lien, if any, is inferior and subsequent to the Plaintiff's lien and prays that said defendants be required to set up their lien or claims or forever be barred from asserting same against the described property. 5. If the owner of the property that is the subject of this foreclosure complaint is not the occupier of the property, notice that a foreclosure complaint is being filed was sent by regular U.S. Mail to the occupier(s) tenant(s) for the property pursuant to Local Rule 8.02(A) (2). 6. {ifapplicable] Plaintiff states that this action in foreclosure proceedings is convened under provisions of Sections 323.25 and/or 5721.18 and/or 323.65 to 323.79 of the Ohio Revised Code, that the parcel(s) constitutes abandoned lands pursuant to R.C. 323.65 to 323.79 or are non-productive land as defined in R.C. $722.01(F). WHEREFORE, Plaintiff prays that the defendants be notified of the pendency and prayer of the complaint; that the Court upon hearing determine the amount of taxes, assessments, penalties and interest and that the State of Ohio has the first lien against the premises and that such lien be foreclosed; that the defendants be required to set up what, if any, interest they may have in said property, or be forever barred from asserting the same; the Court will determine the respective amounts due to the defendants and the priorities of their liens; that upon determination of the amount due for taxes, assessments, penalties, interest, and charges to date of sale or transfer, the Court will order said property to be directly conveyed to an eligible township, municipality, county, school district, land reutilization corporation, or community development group pursuant to Revised Code Sections 323.26, 323.28, 323.65 to 323.79, or $721.19 (1), or sold by the Sheriffof this county in accord with the laws of the State of Ohio; that unless the amount found due the Plaintiff together with all costs of this proceeding be tendered to the Plaintiff prior to the conveyance or confirmation of sale, or the expiration of the alternative right of redemption if ordered by the Court as prescribed in Sections 323.65(J), 323.28, or 323.78 and 5721.19(F)(2) of the Revised Code, and demonstrate that the property is in compliance with all applicable zoning regulations, land use restrictions and building, health, and safety codes as prescribed in Sections 323.25, 323.69 and $721.25 of the Revised Code, then the equity of redemption of said parties shall be foreclosed; that an Order to Convey Title or Order of Sale be issued to the Sheriff of Lucas County directing him to either convey directly the property to an eligible township, municipality, county, school district or land reutilization corporation or community development group pursuant to Revised Code Chapters 323 or 5721, or advertise and sell the property at public sale in accord with the laws of the State of Ohio; and for such other and further reliefto which she may be entitled. Respectfully submitted, Treasurer of Lucas County, Ohio, Julia R. Bates, Prosecuting Attorney Lucas County, Ohio /s/Joseph P. Boyle, III Assistant Prosecuting Attorney PARID: 2096704 ASSESSOR #: 05424051 NBHD: 1312R ROLL: RP_OH KUHN FAMILY VENTURES LLC AN OHIO LIMITED 629 FOREDALE AVE PRO Codes: 2FCL Current Values Tax Year 2023 Land Building Total Appraised Value (100%) 12,400 15,600 28,000 Assessed Value (35%) 4,340 5,460 9,800 Roll Values (100%) 12,400 15,600 28,000 Roll Values (35%) 4,340 5,460 9,800 Other Values Hmstd Red. Val. Forest Red. Val. CAUV Red. Val. CAUV Savings Recoupment Gross Rate Q oO 0 0.00 0.00 101.47 Current Taxes 1st Half 2nd Half Tax Year 2023: General; 496.92 496.92 House Bill 920: 172.33 172.33 Non-Business Credit: 27,97 27.97 Owner Occupied Credit: 0.00 0.00 Homestead Reduction: 0.00 0.00 Net General: 296.62 296.62 Adjustment General: 0.00 0.00 Penalty General: 29.66 0.00 interest General: Jan-Aug Int 0.00 0.00 Sept-Dec Int: 306.73 0.00 Prior General: 3,281.48 4,386.60 Prior Years Adjustments: 0.00 0.00 Net Special Assessments 90.86 90.84 Adjustment Special Assessments: 0.00 0.00 Penalty Special Assessments: 9.09 0.00 Interest Special Assessments: Jan-Aug int 0.00 0.00 Sept-Dec int: 86.28 0.00 Prior Years Special Assessments 924.81 1,232.40 Prior Years Special Assessments Adjustments: 0.00 0.00 Prior Delinquent Charges 10,218.30 Ist ‘Half Tax, Assessments, and/or Penalty/interest 426.23 * 1st Half Total Before Payments 10,644.53 2nd Half Tax, Assessments, and/or Penalty/interest 387.46 * Full Year Total Before Payments 11,031.99 ** TOTAL PAYMENTS ** 0.00 ** TOTAL DUE AFTER PAYMENTS: ** 11,031.99 Last Change Date: Feb 09, 2024 Last Payment Date: Notes on Taxes = Ist Half Total Before Payments includes 1st half taxes, assessments, any penalty, any interest, and any delinquent amount. - Full Year Total Before Payments includes 1st and 2nd half taxes, assessments, any penalty, any interest, and any delinquent amount, MAR 08 2024 FIRST HALF DELINQUENT TRE EIST = 2023 FOR ROLLTYPE : RP_OH 4,758 10:16 TAX DIST/NAME:; 20 ‘TOLEDO CITY - TOLEDO TX1020H PARID/STUB/PROJECT PR INTEREST A-TAX ASPEN B-TAX B-PEN TOTAL NAME/LEGAL ACRES 20-96704 KUHN FAMILY VENTURES LLC*CER DEL*2017 40.46 20.79 2.50 0.25 0.00 0.00 64.00 LIABILITY COM ‘cobs A 0000F 1052.72 936.38 66.63 6.66 0:00 0.00 2662.39 WESTON GDNS 1ST EXTN Lor 176 6.0000 ooooL 131:86 72.63 0.63 0:00 0.00 211.42 0000 25.93 12:87 1.67 0117 0:00 40.64 0000T™ 229.45 120.40 137 1.38 0.00 0.00 364 5226.20 2748.61 296.62 23.66 0:00 010 ‘SUM 6706 62 3511.68 387.48 38,75 0.00 0100 10644.53* “20-56707 TOLEDO REALTY A LLC *CER DEL*2023 REAL 9,00 0.00 15.69 0.78 0.00 9.00 16.47 CODE A 9000 0100 0:00 0.09 9.00 0.00 0.00 0.09 WESTON GDNS 1ST EXTN LOT 177 0.0000 00007™ 0100 0:00 0.66 0.03 0.00 0.00 0.69 00001, 0100 90.90 0.30 0.02 0.00 0,00 0:32 0,00 0.00 0.12 0.02 0.00 0.00 0.13 0000F 9.00 0:00 3147 0116 0.00 9,00 3.33 0.00 0.00 20.03 0199 0.00 0,00 21.02" 20-96714 MODERN SPACE PROPERTIES LLC REAL 0.00 0.00 325.38 32 54 0.00 9.00 357.92 6.0000 0:00 2.50 25 0.00 010 2.75 WESTON GDNS 1ST EXTN LOT 179 0000 0.00 9.00 1:83 18 0.00 9.00 2.01 c ooooTm 0:00 0,00 13.76 38 0:00 9.00 15114 0000L 0:00 0.00 63 0:00 9,00 6.93 0000F 0:00 0.00 66.63 66 0.00 9.00 73.23 SUM 0,00 0.00 416.40 4h 64 9.00 0.00 458.04* 20-96781 KHAN KHALIF *CER_DEL*2020 0000 4.99 1.22 0.56 0.06 0.00 0.00 6.83 govern 199140 41.96 25.60 2.56 0.00 0:00 269.52 WESTON GDNS 1ST EXTN LOT 199 6.0000 948.95 241.33 99.59 9.96 0.00 9.00 1299.83 c boodn 113.36 24.78 41.72 1117 9:00 0100 151,03 14.31 408 0.00 9.00 0100 28.33 o00or 1901.26 228.17 123.92 12,39 9.00 e100 1365.74 2282.27 541.54 261.39 26.34 9.00 0.00 311134 \ 20-96791 FLORIO GRISELDA CANO ETA*CER DEL*2023 1354.06 54.16 614.41 61.44 0.00 0.00 2084.07 DE A 0000L 0.61 6.30 0.63 0:00 0.00 22.70 WESTON GONS 1ST EXTN LOT 202 0.0000 5150 0122 2.50 0125 0:00 0.00 8147 o000T™M 30.38 1122 13.76 1.38 0.00 0.00 46.74 0000F 128.65 5.15 66.63 6.66 0:00 0.00 207.09 0000 0133 3.58 0:00 6.00 SUM 1541.54 61.67 707.44 70.71 0:00 0100 2381.06* hea, Preliminary Judicial Report First American Title™ ISSUED BY WwYY Svs First American Title Insurance Company REPORT NUMBER: Judicial Report ce Guaranteed Party Name: Lucas County Treasurer File No.: 68453 Guaranteed Party Address: One Government Center Effective Date: 5/13/2024 @ 06:30 AM City, State, Zip: Toledo, OH 43604 Pursuant to your request for a Preliminary Judicial Report (hereinafter “the Report’) for use in judicial proceedings, FIRST AMERICAN TITLE INSURANCE COMPANY (hereinafter “the Company”) hereby guarantees in an amount not to exceed $ 11,031.99 that it has examined in the public records in LUCAS County, Ohio as to the land described in Schedule A, that the record title to the land is at the date hereof vested in Kuhn Family Ventures, LLC, an Ohio Limited Liability Company by instrument recorded in 20180816-0035695 and free from all encumbrances, liens or defects of record, except as shown in Schedule B. This is a guarantee of the record title only and is made for the use and benefit of the Guaranteed Party and the purchaser at judicial sale thereunder and is subject to the Exclusions from Coverage, the Exceptions contained in Schedule B and the Conditions and Stipulations contained herein. This Report shall not be valid or binding until it has been signed by either an authorized agent or representative of the Company and Schedules A and B have been attached hereto. Tn Witness Whereof, First American Title Insurance Company has caused its corporate name to be hereunto affixed by its authorized officers as of Date of Policy shown in Schedule A. First American Title Insurance Company For Reference: File #: 68453 OM P-feBrm Policy #: Issued By: AREA Title Agency, Inc. Kenneth D. DeGlorgio, President Hy Fad 3234 Executive Parkway, Suite 107 Toledo, OH 43606 Account No: om Telephone: (419) 242-5485 Greg L. Smith, Secretary By: This Jacket was created electrontcally and constitutes an original document Authorized Coundinatyp Form 5007339 (9-1-14) Page 1 of 2 Preliminary Judicial Report (4-15-10) Ohio Order Number: 68453 Report Number: 5007339-0060148e First American Title Insurance Company Schedule A Description of Land Lot number one hundred seventy-six (176) in Weston Gardens, First Extension in the City of Toledo, Lucas County, Ohio, in accordance with Volume 42A of Plats, page 16. (Tax Parcel No. 20-96704) ALTA Preliminary Judicial Report Order Number: 68453 Report Number: 5007339- 0060148c Preliminary Judicial Report SCHEDULE B The matters shown below are exceptions to this Preliminary Judicial Report and the Company assumes no liability arising therefrom. 1 Commonly Known As: 629 Foredale Ave., Toledo, OH 43609 On January 15, 2022, a Judgment Lien Certificate was filed in the Common Pleas Court of Lucas County, Ohio, Certificate Number LNO202203725, wherein it appears that a judgment was rendered in favor of City of Toledo Dept of Public Utilities, against Kuhn Family Ventures, LLC, for $3,121.20 with interest and for costs. NOTE: The above was refiled on January 19, 2024 as Judgment Lien Number LNO202402540, Filed by Thomas L, Sooy, Attorney. Affidavit for Mechanic's Lien filed for record in the Office of the County Recorder, Lucas County, Ohio, on September 21, 2021 as Instrument Number 20210921-0050010, copy attached. On April 22, 2022, a Judgment Lien Certificate was filed in the Common Pleas Court of Lucas County, Ohio, Certificate Number LNO202201644, wherein it appears that a judgment was rendered in favor of The Waterville Gas Company, PO Box 259 Waterville, OH 43566, against Kuhn Family Ventures LLC, for $919.42 with interest and for costs. Filed by M. Charles Collins, Attorney. Taxes for the first half of 2023, including delinquencies, penalties and interest, total $10,644.53 and are unpaid, The half tax amount is $387.46. (Tax Parcel Number 20-96704) Taxes for second half of 2023 are a lien not yet due and payable. Taxes for the year 2024 are a lien not yet due and payable. Subsequent years' installments are not yet due and payable. No examination for special assessments not yet certified to the county Auditor/Treasurer's Office. No liability is assumed by the Company for tax increases occasioned by retroactive revaluation or changes in land usage or loss of any Homestead Exemption status for the insured premises. NOTE: The above figures are taken from the Auditor/Treasurer's Office computer. We assume no liability for any variance between the above figures and different figures hereafter shown on any current or future tax bills, Delinquent sewer bills, water bills, charges for weed cutting, cleaning up trash and other nuisance abatement charges may become a lien on the real estate. No liability is assumed by the Company for ascertaining the status of these charges. The proposed insured is cautioned to obtain the current status of these charges, if any. We have made no examination as to building lines, easements, rights of way or restrictions and terms and conditions of record in Lucas County, Ohio. Policy #: CONDITIONS AND STIPULATIONS OF THIS PRELIMINARY JUDICIAL REPORT Definition of Terms receives actual notice that they may be required to pay money (a) “Guaranteed Party’: The party or parties named herein or or other compensation for a matter covered by this Report or the purchaser at judicial sale. actual notice someone claims an interest in the Land covered by (b) “Guaranteed Claimant”: Guaranteed Party claiming loss or this Report. damage hereunder. Extent of Liability () “Land”: The land described specifically or by reference in The liability of the Company shall in no case exceed in all the Schedule A, and improvements affixed thereto, which by amount stated herein and shall in all cases be limited to the law constitute real property; provided however the term actual loss, including but not limited to attorneys fees and costs “land” does not include any property beyond the lines of the of defense, only of the Guaranteed Claimant. Any and all area specifically described or referred to in Schedule A, nor payments under this Report shall reduce the amount of this any right, title, interest, estate, or easement in abutting Report pro tanto and the Company's liability shall terminate streets, roads, avenues, lanes, ways or waterways. when the total amount of the Report has been paid. (d) “Public Records”: Those records under state statute and, if Options to Pay or Otherwise Settle Claims; Termination of a United States District Court resides in the county in which Liability the Land is situated, the records of the clerk of the United The Company in its sole discretion shall have the following States District Court, which impart constructive notice of options: matters relating to real property to purchasers for value (a) To pay or tender to the Guaranteed Claimant the amount of without knowledge and which are required to be the Report or the balance remaining thereof, less any maintained in certain public offices in the county in which attorneys fees, costs or expenses paid by the Company to the land is situated. the date of tender. If this option is exercised, all liability of Determination of Liability the Company under this Report terminates including but This Report together with any Final Judicial Report or any not limited to any liability for attorneys fees, or any costs of ‘Supplement or Endorsement thereof, issued by the Company is defense or prosecution of any litigation. the entire contract between the Guaranteed Party and the (b) To pay or otherwise settle with other parties for or in the Company. name of the Guaranteed Claimant any claims guaranteed Any claim of monetary loss or damage, whether or not based on by this Report. negligence, and which arises out of the status of the title to the () To continue, re-open or initiate any judicial proceeding in estate or interest guaranteed hereby or any action asserting order to adjudicate any claim covered by this Report. The such claim, shall be restricted to this Report. Company shall have the right to select counsel of its choice Liability of Company (subject to the right of the Guaranteed Claimant to object This Report is a guarantee of the record title of the Land only, as for reasonable cause) to represent the Guaranteed disclosed by an examination of the Public Records herein Claimant and will not pay the fees of any other counsel. defined. (d) To pay or tender to the Guaranteed Claimant the difference Notice of Claim to be given by Guaranteed Party between the value of the estate or interest as guaranteed In case knowledge shall come to the Guaranteed Party of any and the value of the estate or interest subject to the defect, lien, encumbrance, defect, or other claim of title guaranteed lien or encumbrance guaranteed against by this Report. against and not excepted in this Report, whether in a legal Notices proceeding or otherwise, the Guaranteed Party shall notify the All notices required to be given to the Company shall be given Company within a reasonable time in writing and secure to the promptly and any statements in writing required to be furnished Company the right to oppose such proceeding or claim, or to to the Company shall be addressed to First American Title remove said lien, encumbrance or defect at its own cost. Any Insurance Company, Attn: Claims National Intake Center, 5 action for the payment of any loss under this Report must be First American Way, Santa Ana, California 92707, Phone commenced within one year after the Guaranteed Party 888-632-1642 (claims.nic@firstam.com). EXCLUSIONS FROM COVERAGE The Company assumes no liability under this Report for any 4 The Company assumes no liability under this Report for the loss, cost or damage resulting from any physical condition of the proper form or execution of any pleadings or other documents to Land. be filed in any judicial proceedings. The Company assumes no liability under this Report for any The Company assumes no liability under this Report for any loss, cost or damage resulting from any typographical, clerical or loss, cost, or damage resulting from the failure to complete other errors in the Public Records. service on any parties shown in Schedule B of the Preliminary The Company assumes no liability under the Report for matters Judicial Report and the Final Judicial Report or any affecting title subsequent to the date of this Report or the Final Supplemental Report issued thereto. Judicial report or any supplement thereto. Form 5007339 (9-1-14) Page 2 of 2 Preliminary Judicial Report (4-15-10) Ohio