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LEGAL NOTICE

ROBERT E. LEE

Attorney At Law

2483 South Main Street

Akron, Ohio 44319

Telephone: 330-644-6161

IN THE COURT OF

COMMON PLEAS,

MAHONING COUNTY, OHIO

120 Market Street

Youngstown, Ohio 44503-1751

Case No. 03CV 2152

BENEFICIAL OHIO, INC DBA BENEFICIAL MORTGAGE COMPANY OF OHIO

PLAINTIFF,

VS.

JOHN C. PROTAIN, ET AL

DEFENDANTS.

Bankers Trust Company of California, whose last known place of residence was 3 Park Plaza, Irvine, CA 92614, is hereby notified that on June 25, 2003, Beneficial Ohio, Inc. dba Beneficial Mortgage Company of Ohio as Plaintiff filed its Complaint against you and others in the Common Pleas Court of Mahoning County, Ohio being Case No. 03CV 2152 alleging that on July 18, 2000 the Defendants, John C. Protain and Debra L. Protain executed an Agreement in the amount of $60,007.11; that said Defendants have failed to make the monthly payments required by said Agreement and that there is due on said Agreement, $63,324.41, plus interest at $21.94 per diem from June 24, 2003, plus late charges, plus costs incurred in this foreclosure action for which the Plaintiff asks Judgment; that to secure said Agreement, the Defendants, John C. Protain and Debra L. Protain executed a Mortgage Deed covering the following described real estate:

PARCEL 1:

Situated in the City of Campbell, County of Mahoning and State of Ohio, and known as Campbell City Lot Number One Thousand Three Hundred Seventy-Nine (1379) according to the latest enumeration of lots in said City. Said Campbell City Lot No. 1379 has a frontage of Fifty (50) feet on the North side of Whipple Avenue and extends back therefrom between parallel lines a distance of One Hundred Fifty (150) feet, be the same more or less.

PARCEL 2:

Situated in the City of Campbell, County of Mahoning, and State of Ohio:

And known as being City Lot Number 1981 of the Robinson Plat according to the latest enumeration of lots in said City. Said Lot #1981 has a frontage of Forty (40) feet on the South side of Bright Avenue and extends back therefrom to an equal width of One Hundred Forty (140) feet to an alley. Subject to easements, right-of-ways, leases, conditions, restrictions, and legal highways, if any of record Plaintiff further prays that the mortgage be foreclosed and all equities or redemptions be forever cut off; that the liens on the property be marshaled that said premises be sold as upon execution free and clear of all liens interest and dower, and that the proceeds thereof be applied to Plaintiff's claim as set out in the foregoing Complaint; that the Defendants be required to set forth their liens upon or interest in said property or be forever bared from asserting the same; for costs of this action; and for such further relief as the Court deems just and equitable.

PERMANENT PARCEL NO.: 46-008-0-283.00-0

PROPERTY LOCATION: 109 Bright Avenue.

Said above named Defendant will further take notice that it is required to answer said Complaint on or before October 9, 2003 which includes 28 days from the last publication, or said Judgment may be rendered as demanded therein.

MALLO & LEE

BY:  ROBERT E. LEE,

  Plaintiff's Attorney.

Aug 7,14,21,28; Sep 4,11, 2003   03-01185