The State v. Doane (1990), 69 Ohio App.3d 638, 591 N.E.2d 735, 7 Anderson's Ohio App. Cas. 503 court was concerned with whether a purpose to defraud could be present when a defendant issued a check to satisfy a pre-existing debt. The court rejected the rule from other jurisdictions, which held that a purpose to defraud existed only where checks were issued in a contemporaneous exchange for a benefit. Other jurisdictions had held that even if the check was not honored, in a pre-existing debt situation, the underlying relationship of the parties had not changed -- "the drawer is still liable for the debt, while the payee did not give up anything for the check." Id.