PLAINTIFF,

VS.

CHARLES P. HENDERSON

DEFENDANT

NOW COMES the Plaintiff, Oak Baptist Church, by and through undersigned counsel, Anthony Donofrio, and for its complaint to quiet title states as follows:

1. Plaintiff, Oak Baptist Church, is the owner and has a right to possession of the real estate known for street numbering purposes as Elk Street, located in the City of Youngstown, County of Mahoning, State of Ohio, and having legal description as being:

Situated in the City of Youngstown, County of Mahoning and State of Ohio, and known as being the easterly part of City Lot Number 534 according to the latest enumeration of Lots in said City.

Said easterly part of City Lot Number 534 has a frontage of 39.6 feet on the northerly side of Elk Street, formerly Oak Street, and extends back therefrom, between parallel lines, a distance of 132 feet, be the same more or less but subject to all legal highways and restrictions and easements of records.

Further described as being located on the northerly side of Elk Street between Meadow Street and North Watt Street.

Previous Deed Reference: Volume 944, Page 461, Permanent Parcel Number 53-022-0-019

2. Plaintiff obtained its interest on behalf of transfer of the property to Oak Baptist Church, of which Mr. Randall Charles Kitchen is the reverend pastor, when Mr. Charles P. Henderson granted said premises to Oak Baptist Church on August 24, 1960.

3. The described lot consists of the easterly half of City Lot Number 534. Mr. Charles P. Henderson subsequently acquired the westerly half of City Lot Number 534 on April 14, 1961. Mr Charles P. Henderson died prior transferring the above-described easterly half of City Lot Number 534 to Oak Baptist Church.

4. The easterly half of City Lot Number 534 consists of the parking lot of Oak Baptist Church, said church has been maintaining the property taxes on said property for the past thirty (30) years.

5. Plaintiff believes that it was the intention of Charles P. Henderson to transfer the above-described real property to Oak Baptist Church prior to his death.

6. The Plaintiff represents that it has an interest or a right to possession in the above-described real property.

7. Diligent efforts and attempts have been made to locate the family of Charles P. Henderson in order to clear title of said property, said diligent efforts and attempts being unsuccessful.

Wherefore, Plaintiff prays for judgment quieting title and all other judicial relief that this Court deems just and proper.

You are required to answer the Complaint within Twenty-eight (28) days from the last date of publication of this notice, which will be published for six (6) successive weeks, said answer day being the 4th day of July, 2003.

BY:  ANTHONY DONOFRIO (#0051849),

Plaintiff's Attorney.

May 2,9,16,23,30; Jun 6, 2003   03-00697