Brooks v. Rollins

The issue presented by this case is whether service of process by publication was proper pursuant to Civ. R. 4.4(A) and R.C. 2703.14(L). More specifically, the question is whether proof which is limited to a showing of reasonable diligence in attempting to locate a defendant but does not prove actual intent by that defendant to conceal herself is sufficient to satisfy the requirements for service of process by publication. This court concludes that such a showing of diligence raises an inference of concealment sufficient to support service by publication.

Civ. R. 4.4(A) sets forth the…