Interface Fin. Group, Inc. v. Margagliotti, 2012 Ohio 3666

Gempel Masonry assigned its right to collect money from Margagliotti to IFG and this was memorialized to Margagliotti.
IFG filed suit against Margagliotti for $79,936.50 and named Gempel, which defaulted.
IFG sought a prejudgment attachment on funds owed to Gempel by the main contractor.
Trial court granted IFG summary judgment against Margagliotti and found proper notification under R.C. 1309.406(A).
Margagliotti argued IFG failed to provide reasonable proof as required by R.C. 1309.406(C).
This court reversed in part and remanded for further proceedings, noting genuine issues of material fact regarding invocation of 1309.406(C).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether 1309.406(C) proof was properly requested and provided	Margagliotti asserts IFG did not furnish reasonable proof.	IFG argues no proof was required because notification sufficed.	Genuine issue of material fact exists; neither side is entitled to summary judgment on this issue.
Whether the absence of proof precludes continuation of payments to the assignor	Margagliotti continued paying Gempel due to lack of proof.	IFG contends notification alone suffices.	Remanded for further proceedings to determine whether Margagliotti discharged the debt.

First Bank of Marietta v. Roslovic & Partners, Inc., 86 Ohio St.3d 116 (Ohio 1999) (notification must include required elements; reasonable proof may be demanded)
Grafton v. Ohio Edison Co., 77 Ohio St.3d 102 (Ohio 1996) (summary judgment standard applied de novo)
Dresher v. Burt, 75 Ohio St.3d 280 (Ohio 1996) (burden shift for summary judgment established)
Temple v. Wean United, Inc., 50 Ohio St.2d 317 (Ohio 1977) (summary judgment criteria and burden on movant)
Estate of Heintzelman v. Air Experts, Inc., 126 Ohio St.3d 138 (Ohio 2010) (statutory interpretation and enforcing plain terms)
IIG Capital LLC v. Archipelago, L.L.C., N.Y.S.2d 10 (N.Y. App. Div. 2007) (debtor may require proof of assignment upon request)