Legal Notice IN THE COURT OF COMMON PLEAS CIVIL DIVISION LAKE COUNTY, OHIO BEL ACRE CONDOMINIUM ASSOCIATION, INC. Plaintiff, VS. ROBERT ALEXANDER, et al. Defendant(s) CASE NO: 25CF000979 • PPN:29B003D020310 NOW COMES Plaintiff, Bel Acre Condominiums Association, Inc. (hereinafter referred to as “Plaintiff”), by and through counsel, and for its Complaint for Foreclosure, states as follows: 1. Plaintiff is a non-profit corporation organized under Chapter 1702 of the Ohio Revised Code for the purpose of administering the property known Bel Acre Condominiums Association, Inc. contains units located in the City of Wickliffe, County of Lake, in the State of Ohio. 2. Pursuant to the Declaration and the Bylaws and the amendments thereto filed for record with the Lake County Recorder, Plaintiff is authorized to collect and receive monthly assessments and special assessments, and late fees from each and every unit owner. (Said documents have not been reproduced herein due to their voluminous nature, however, if a party or the Court would like a copy, counsel for Plaintiff will provide them upon request.) 3. Defendants, Robert Alexander and the Estate of Barbara Alexander are the titled owner of the property known as 29902 Euclid Ave. #15B Wickliffe, Ohio 44092 with permanent parcel number 29B003D020310. Situated in the City of Wickliffe, County of Lake and State of Ohio And known as being Suite, Family Unit or Parcel No. 15-B in Building 2 in Bel Acre Condominium of part of Original Willoughby Township Lot No. 10, Tract No. 12 as shown by the recorded plat in Volume Q, page 17 of Lake County Map Records, together with 3.26% ownership of the common areas, limited common areas, and facilities in said areas in said condominium as appears by said plat, be the same more or less, but subject to all legal highways. 29902 Euclid Avenue #15B Wickliffe, OH 44092 Deed Reference: Volume 763, Page 555. 4. Pursuant to the authority of Chapter 5311 of the Ohio Revised Code and the Bel Acre Condominiums Association, Inc. Declaration and Bylaws, Plaintiff, through its President, filed a Certificate of Lien in the amount of Three Thousand Three Hundred Fifty-Eight Dollars 2 and 38/100 ($3,358.38) on the property (attached hereto as Exhibit “B”), with the Lake County Recorder at Instrument Number 2023R025265 on December 19, 2023 to secure payment of the monthly assessments and late fees, plus interest and unpaid assessments accruing until the lien is satisfied. 5. Robert Alexander and the Estate of Barbara Alexander owe Plaintiff assessments in addition to the amount of the Certificates of Lien referenced above, for the total sum of Nine Thousand Nine Hundred Seventy Dollars and 30/100 ($9,970.30) as of May 29, 2025, based upon unpaid assessments and late fees. A copy of said account balance is attached hereto and incorporated herein as Exhibit C. 6. Plaintiff is further owed from Robert Alexander and the Estate of Barbara Alexander maintenance fees and assessments incurred subsequent to the filing of the above- referenced Certificate of Lien in an amount to be later determined. 7. In accordance with Plaintiff’s governing documents, recorded in Lake County Records, Robert Alexander and the Estate of Barbara Alexander, the titled lot owner, has, by covenant, agreed to be responsible for the legal fees and court costs incurred in the within action. In Nottingdale Homeowner’s Assn., Inc. v. Darby, 33 Ohio St. 3d 32 (1987) and First Fed. Sav. Bank v. WSB Investments, Inc., 67 Ohio App. 3d 277 (1990), courts have held that the association instruments make defaulting owners responsible for attorney fees. The titled owners of the unit have joint and several liability for maintenance fees and assessments. 8. Plaintiff claims an interest in the property subject to this foreclosure action, as the Association to which this property belongs, for the sum of Nine Thousand Nine Hundred Seventy Dollars and 30/100 ($9,970.30) as of May 29, 2025. 9. Said balance as described in Paragraphs 5 and 8, above, is continuing to accrue with each maintenance fee and late fee and with the legal fees for this foreclosure action. 10. Defendants, Robert Alexander and the Estate of Barbara Alexander, Known or Unknown Heirs of Barbara Alexander, State of Ohio, NAR Ohio, LLC and the Lake County Treasurer named herein have or may have claimed to have an interest in the property described in the Preliminary Judicial Report, a copy of which is filed herewith. (a) WHEREFORE, Plaintiff, Bel Acre Condominiums Association, Inc. prays: That it be granted judgment in foreclosure in the sum of Nine Thousand Nine Hundred Seventy Dollars and 30/100 ($9,970.30) as of May 29, 2025, for the liens it holds, upon which execution may issue; (b) That it be granted judgment for maintenance fees and assessments incurred subsequent to the filing of this action in an amount to be determined, plus interest and costs; (c) That it be granted a personal judgment against Defendant, Robert Alexander and the Estate of Barbara Alexander, for the sum of Nine Thousand Nine Hundred Seventy Dollars and 30/100 ($9,970.30) as of May 29, 2025, for its liens, and for subsequently accruing fees and assessments, upon which execution may issue; (d) That the Defendants be required to answer and set forth any claim they may have in said premises or be forever barred; (e) That Plaintiff’s liens be found to be good and valid liens upon said property; (f) That all liens on said property be marshaled and the premises be ordered appraised, advertised and sold at Sheriff’s Sale according to law; (g) That Plaintiff recovers its costs herein including, the cost incurred for the Judicial Title Reports; (h) That Plaintiff recovers attorney fees and court costs of the within action for the proceeds of the sale; or alternatively, that Plaintiff be granted judgment for attorney fees and costs, upon which execution may issue; and (i) That Plaintiff be granted any additional relief to which it may be entitled to by law or in equity including but not limited to additional maintenance fees and special assessment incurred subsequent to the filing of the within action. By Steven M. Ott, Hilary A. Hall, Devonice K. Austin, Attorneys for Plaintiff 2760925/November 3, 10, and 17, 2025