concurring in part and dissenting in part.
I dissent from the majority’s holding that mother’s objections to father’s ORCP 68 petition for attorney fees are properly before this court. Because the trial court record does not establish when, if ever, mother served her objections on father, I would not consider mother’s objections and would affirm the trial court’s judgment awarding attorney fees to father. However, I concur with the majority that mother’s request for attorney fees remains pending before the trial court and, therefore, it is not necessary to reach mother’s other assignments of error. 218 Or App at 327.
As the majority correctly notes, the facts are procedural. After a general judgment was entered, father, on May 11, 2006, timely filed and served his ORCP 68 request for attorney fees. On May 26, 2006, mother filed her objections to father’s request for attorney fees and requested a hearing. The certificate of mailing attached to mother’s objections stated that the objections were mailed to father’s attorney by first-class mail on May 26, 2006. However, that certificate of mailing was not signed. There is no signed document *328in the record establishing that mother ever served a copy of her objections to father’s ORCP 68 request for attorney fees.
Without holding a hearing, the trial court issued a letter opinion, awarding father attorney fees and directing father’s attorney to draft the supplemental judgment. The supplemental judgment awarding father attorney fees was entered. Mother filed her notice of appeal within 30 days after entry of that supplemental judgment.
Mother argues that the trial court erred in awarding attorney fees to father. Mother asserts that her objections to father’s ORCP 68 request for attorney fees were timely and proper. In addition, mother argues that ORCP 68 C(4)(c)(i), as interpreted in Bradach and Bradach, 203 Or App 477, 124 P3d 1288 (2005), required the trial court to hold a hearing to consider mother’s objections to father’s ORCP 68 request for attorney fees before awarding father attorney fees. ORCP 68 C(4)(c)(i) provides, in part:
“If objections are filed in accordance with paragraph C(4)(b) * * *, the court * * * shall hear and determine all issues of law and fact raised by the statement of attorney fees * * * and by the objections.”
Mother is correct that ORCP 68 C(4)(c)(i) requires the court to hold a hearing if a party timely files and properly serves an objection under ORCP 68 C(4)(b).
The problem with mother’s argument is that there is no evidence in this record that mother perfected her objections by mailing a copy to father. Furthermore, our review is limited to the record before us. The trial court record does not establish that mother ever served father with a copy of her objections because mother’s attorney did not sign the certificate of mailing that she filed with the trial court. The only certificate of mailing of mother’s ORCP 68 objections in this record is unsigned.
The majority does not consider father’s argument regarding the unsigned certificate of mailing because, according to the majority, father did not raise this argument in response to mother’s assignment of error. 218 Or App at 324-25.1 disagree. Father did discuss mother’s failure to sign the certificate of mailing in his brief and at oral argument. In his *329statement of facts in his brief, father stated that “[t]he proof of service * * * which was filed with the trial court on May 26, 2006, which proof [of service] was not signed.” In responding in his brief to mother’s assignment of error, father stated that there were problems with mother’s certificate of mailing. Finally, in his conclusion, father stated that mother “misled the court in [her] certificate of service filed in the court records.” In her reply brief, mother responded to father’s argument that her objections were not properly served. In both her summary of argument and statement of facts, mother stated that she “served” her objections. Mother concluded her argument by again stating that she served her objections well within the deadline. Thus, contrary to the majority’s assertion, father did raise the issue of the certificate of service in father’s brief in response to mother’s assignment of error, and mother responded to father’s arguments in her reply brief. This issue was also discussed at oral argument. At oral argument, mother’s attorney stated that he did not know whether he filed a signed or unsigned certificate of mailing because he had no idea what was in the trial court record.
The majority also states that there is no “indication that the trial court ever considered” mother’s failure to sign the certificate of mailing. 218 Or App at 325. The majority’s statement is correct, but the majoritys statement does not resolve this issue. As noted, the trial court did not hold a hearing on attorney fees. If mother’s objections to father’s ORCP 68 request for attorney fees were not properly before the trial court, the trial court was not required to hold a hearing. It is not proper to fault father for not raising an argument at a hearing when there was no hearing.
The majority opinion relies on ORCP 17 B to support its argument that it is father’s obligation to notify mother and, by implication, the court, of mother’s failure to sign the certificate of mailing that her attorney filed with the court. 218 Or App at 325. In addition, the majority relies on a footnote in Bruner v. Cascade Western Corp., 88 Or App 501, 504 n 1, 746 P2d 231 (1987), rev den, 305 Or 103 (1988). 218 Or App at 325-26.
*330The starting point for a discussion regarding the service and filing of documents is ORCP 9. ORCP 9 governs the service and filing of pleadings and other papers. ORCP 9 A requires that every written request “shall be served upon each of the parties.” Mother’s objection to father’s ORCP 68 request for attorney fees had to be served on father. Under ORCP 9 B, service by mail is permissible. However, mother had to perfect her objections; that is, mother had to file a separate document establishing that her objections were served; “proof of service may be made upon the papers served or as a separate document attached to the papers.” ORCP 9 C. One permissible method for proving service on the opposing party is a certificate signed by an attorney, certifying that service was made. ORCP 9 C. It was mother’s obligation to establish that she properly served her objections on father, and an unsigned certificate of service does not establish that mother properly served her objections on father. Thus, there were no perfected objections for the trial court to review and, as a consequence, the trial court did not err when it did not hold a hearing.
I then turn to ORCP 17. ORCP 17 A requires that mother’s attorney “shall” sign “[e]very pleading, motion and other paper.” Mother’s certificate oif mailing was not signed. ORCP 17 B provides:
“If a pleading, motion or other paper is not signed, it shall be stricken unless it is signed promptly after the omission is called to the attention of the pleader or movant.”
The majority cites ORCP 17 B for the implicit proposition that father had the duty to notify mother of her failure to comply with ORCP 9 C and ORCP 17 A:
“[T]he failure to sign a certificate of mailing does not invalidate the filing or service of the objections unless the failure is called to the attention of the movant and the movant then fails to sign the certificate.”
218 Or App at 325-26. The problem with the majority’s reasoning is that the language in ORCP 17 B does not expressly provide that an attorney must notify the opposing party of its failure to sign the certificate. The majority reads into ORCP *33117 B an affirmative duty that is not expressed in the text of the statute. See ORS 174.010.
As previously noted, the majority relies on Bruner to support its position that, unless mother is informed of her failure to comply with the rules of civil procedure, her failure to so comply has no consequence. However, the issue in Bruner was whether the trial court abused its discretion in dismissing a complaint for failure to respond to a court order under ORCP 54 B(l) and for failure to prosecute the claim under ORCP 54 B(3). We held that the trial court did not abuse its discretion and affirmed. 88 Or App at 504. In a footnote, we responded to the defendant’s argument regarding an out-of-state attorney signing the complaint:
“On appeal, defendant argues for the first time that the original complaint was void, because it was not properly signed under ORCP 17A. It argues that the first properly signed complaint was filed after the time limitation of ORS 12.110 and that the dismissal can be sustained on that basis. Defendant did not raise that issue below and, assuming that it has not waived that defense, see ORCP 21G(2), ORCP 17B requires a motion to strike a pleading that is not properly signed. We decline to address whether the action was timely commenced.”
Id. at 504 n 1 (emphasis added). That footnote is the majority’s sole support for its position that “ORCP 17 B appears to require a formal motion to strike a pleading that is not properly signed before the lack of a signature is raised on appeal.” 218 Or App at 326.
The majority places too much reliance on this footnote for several reasons. Bruner is inapposite to the facts and issues of this case. First, the issue in Bruner was whether the trial court abused its discretion in dismissing a complaint, whereas, here, the issue is whether mother perfected her objections to father’s ORCP 68 statement of attorney fees. Second, we did not decide Bruner on the basis of ORCP 17 B. Third, the discussion of what ORCP 17 B requires is dictum.1 Fourth, it does not appear that ORCP 17 B has been cited, let *332alone relied on, in any other case before or after Bruner. In addition, Bruner has not previously been cited regarding its discussion of either ORCP 17 A or ORCP 17 B.
It was mother’s obligation to perfect her objections to father’s ORCP 68 request for attorney fees. Mother could have perfected her objections by (1) timely filing her objections (which she did) and (2) proving that she served a copy of her objections by signing a certificate of mailing (which she did not do). The clerk’s office of any trial court is too busy to review every document filed to make certain that the attorney signed every document that the attorney is required to sign. It is not father’s attorney’s obligation to review the original of every document that mother’s attorney filed with the trial court to ascertain that mother’s attorney properly signed every document. Nothing in ORCP 17 B expressly places that obligation on father’s attorney; in other words, ORCP 17 B does not expressly require that father’s attorney must call attention to mother’s failure to sign the document. To place such a requirement on father’s attorney is to turn the representation of parties on its head.
I dissent.
In addition, the entire discussion is contained in a footnote, and a footnote is just that: a footnote. Sedgwick Claims Management Services v. Jones, 214 Or App 446, 454, 166 P3d 547 (2007).