held in escrow; however, according to Hanlin-Rainaldi, Jeepers defaulted on Notes 2 and 3. r P11] On May 20, 2002, Hanlin-Rainaldi sued Jeepers in the Franklin County Court of Common Pleas, asserting five causes of action, that Jeepers: (1) wrongfully withheld payment under Note 1 and was liable for all amounts due und