The Supreme Court of Ohio recently clarified in a decision issued in Deutsche Bank Nat'l Trust Co. vs. Holden 2016-Ohio-4603; 2016 Ohio LEXIS 1803, that equitable rights and remedies which a party holds in and to a mortgage lien on real property are separate and apart from the legal rights and remedies a party holds in and to the underlying promissory note which is secured by the mortgage.

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