Service by publication for unknown trustees regarding church property in Russellville.

AFFIDAVIT FOR SERVICE BY PUBLICATION IN THE COURT OF COMMON PLEAS BROWN COUNTY, OHIOCase No. CVH20250810RUSSELLVILLE COMMUNITY CHURCH, Plaintiff,V.UNKNOWN TRUSTEES, THEIR HEIRS, ASSIGNS, AND ANYONE CLAIMING AN INTEREST IN THE REAL PROPERTY IDENTIFIED BY THE BROWN COUNTY AUDITOR AS PARCEL 18-900445.0000, PART LOT 19 & 20, VILLAGE OF RUSSELLVILLE, OHIO.Defendants.AFFIDAVIT FOR SERVICE BY PUBLICATION (Ohio Civ. R. 4.4)STATE OF OHIO|BROWN COUNTYI, James E. Schroeder, being first duly sworn, state as follows:1. I am an attorney at law duly admitted to practice in the State of Ohio (Bar No. 0098621) and am counsel for the Plaintiff, Russellville Community Church, in the above-captioned quiet title action concerning the real property identified by the Brown County Auditor as Parcel 18-900445.0000, Part Lot 19 & 20, Village of Russellville, Ohio.2. The Complaint in this matter seeks to quiet title to the above-described church property. on behalf of Russellville Community Church and its Administrative Board Chair, Joyce Wagoner.3. The record and historical background of this church property indicate that the original conveyances, trustees, and any parties who may have held or claimed an interest in the property extend back multiple generations to the founding of the church, and that the identities and whereabouts of any such potential trustees, heirs, successors, or assigns are unknown.4. Despite reasonable diligence, the Plaintiff is unable to ascertain the names, current identities, or addresses of the potential defendants who may claim or may have claimed an interest in the property, including any unknown trustees, their heirs, devisees, legatees, assigns, and any persons or entities claiming by, through, or under them, and no better or more complete information can be obtained through ordinary inquiry, search of public records, or investigation reasonably available to Plaintiff.5. Because the potential defendants are unknown, and because their claims, if any, arise from transactions and events related to the founding and continued existence of the church over a century ago, service of process cannot be made personally, by residence service, or by certified or ordinary mail on any such persons.6. The last known address for the subject real property is that reflected in the Brown County Auditor's records for Parcel 18-900445.0000, Part Lot 19 & 20, Village of Russellville, Ohio, but there is no known address for any specific unknown trustees, heirs, or other potential claimants that would permit service by methods other than publication.7. In light of the foregoing, service by publication under Ohio Civ. R. 4.4 is necessary and appropriate upon the following description of defendants:"Unknown Trustees, their heirs, devisees, legatees, assigns, and anyand all persons or entities claiming any right, title, or interest in the real property identified by the Brown County Auditor as Parcel 18- 900445.0000, Part Lot 19 & 20, Village of Russellville, Ohio."8. Plaintiff requests that service by publication be made in a newspaper of general circulation in Brown County, Ohio, once 1 week for six consecutive weeks, and that such publication include notice of this action, the description of the property, the case number CVH20250810, and the requirement that any interested party respond within twenty- eight (28) days after the last date of publication, as reflected in the draft notice previously prepared and transmitted for publication in this matter.Further affiant sayeth naughtJames Schroeder, Esq. (0098621)Schroeder Law Group338 West Main Street Hillsboro, OH 45133Phone: (937) 402-2348Email: jim@southwestohiolaw.comAttorney for Plaintiff Russellville Community ChurchSWORN TO AND SUBSCRIBED in my presence this 29 day of January 2026.Jeanne StevensNotary PublicMy commission Expires: 03/14/2026BCP 02-08-26, 02-15-26, 02-22-26, 03-01-26, 03-08-26, 03-15-26