PLAINTIFF,

VS.

RICHARD L. BULLEN,

DEFENDANTS.

Richard L. Bullen and Jane Doe, unknown spouse of Richard L. Bullen, whose last known places of residence is 161 S. Roanoke Avenue, Austintown, OH 44515, PPN 48-011-174.00, each of you will take notice that on the 15th day of November, 2001, the undersigned, KeyBank USA, NA, filed a Complaint for Money, Foreclosure, and Other Equitable Relief in the Mahoning County Court of Common Pleas, alleging that there is due to the Plaintiff the sum of $51,810.57 plus interest at the rate of 13.99% per annum from March 1, 2001, plus late charges applicable to the terms of the Note and Mortgage, on a Promissory Note secured by a Mortgage Deed of even date conveying the following-described property, to-wit:

Situated in the Township of Austintown, County of Mahoning and State of Ohio: Lot No. 1169 of the Re-Plat of Clovermeade Subdivision of Wickliffe, as found recorded in Volume 28, Page 85, Mahoning County Records of Plats. Said Lot No. 1169 fronts 50 feet on the East line of South Roanoke Avenue and extends back therefrom, of even width throughout, a distance of 140 feet.

Known for street numbering purposes as 161 S. Roanoke Avenue, Austintown, OH 44515

PERMANANENT PARCEL NO. 48-011-174.00

The Plaintiff further alleges that by reason of the default of the Defendant obligors in the payment of said Note according to its tenor, the conditions of said Mortgage Deed have been broken and the same has become absolute.

Plaintiff prays that the Defendants named above be required to answer and set forth their interest in said real estate, or be forever barred from asserting the same, for foreclosure of said mortgage, marshalling of liens, and the sale of said real estate, and the proceeds of said sale applied to the payment of Plaintiff‘s claim in the proper order of its priority, and for such other relief as is just and equitable.

The Defendants named above are required to answer on or before the 9th day of August, 2002.

WELTMAN, WEINBERG &

REIS CO., L.P.A.

BY:  RONALD J. CHERNEK

Attorney for Plaintiff.

Jun 7,14,21,28; Jul 5,12, 2002  02-02210