Public Notices
Public Notices
NOTICE OF PUBLIC SALE
Jam Pac Storage will hold a public sale to enforce a lien imposed on said property, as described below, pursuant to the South Carolina Self Storage Facility Act, SC Code Sections S9-20-10 to S9-20-50. There will be a sealed bid sale on: April 22, 2006 at 10:00am at 7940 Broad River Rd., Irmo, SC 29063, 749-8827.
Management reserves the right to withdraw any unit from sale.
B31-BLUNT-HHG
B65-HAYES-HHG
C29-MONROE-HHG
F9-HOLMES-TREADMILL
SUMMONS
STATE OF
SOUTH CAROLINA COUNTY OF RICHLAND
IN THE COURT OF
COMMON PLEAS
(NON-JURY)
06-CP-40-02080
WALLACE C. FORD,
Plaintiff,
vs.
DAVID A ADAMS, AS TREASURER OF RICHLAND COUNTY, STERLING M. DAVIS. AND IF THE SAID STERLING M. DAVIS IS DECEASED, THEN HIS HEIRS OR DEVISEES AT LAW, YVONNE GREEN, GARY SLATER, GREGORY SLATER, SHERRI SLATER, ANDREA ADAMS, RONALD SLATER, ALONZO E. CONYERS, SOUTH CAROLINA DEPARTMENT OF REVENUE, PALMETTO HEALTH ALLIANCE D/B/A RICHLAND MEMORIAL HOSPITAL, AND ALL OTHER PERSONS UNKNOWN CLAIMING ANY RIGHT, TITLE, INTEREST IN OR LIEN UPON THE REAL ESTATE DESCRIBED HEREIN AND ANY UNKNOWN INFANTS OR PERSONS UNDER DISABILITY OR PERSONS IN THE MILITARY SERVICE HEREBY DESIGNATED AS A CLASS AS JOHN DOE, Defendants.
TO THE ABOVE NAMED DEFENDANTS:
YOU ARE HEREBY SUMMONED AND REQUIRED to answer the Complaint in this action, a copy of which is hereby served upon you and to serve a copy of your Answer upon the Subscriber at 1418 Park Street, Columbia, South Carolina, within thirty (30) days, thirty-five (35) days if service is by certified mail, exclusive of the day of said service, and if you fail to answer, appear or defend this action within the time aforesaid, judgment by default will be rendered against you for the relief demanded in the Complaint.
H. Ronald Stanley
Attorney for Plaintiff
1418 Park Street
Post Office Box 7722
Columbia, SC 29202
(803) 799-4700
Columbia, South Carolina
April 10, 2006
NOTICE OF FILING
NOTICE IS HEREBY GIVEN that the Summons and Complaint in the above entitled action was filed in the Office of the Clerk of Court for Richland County on April 10, 2006.
H. Ronald Stanley
Attorney for Plaintiff
NOTICE OF PENDENCY
OF ACTION
LIS PENDENS
NOTICE IS HEREBY GIVEN THAT an action has been commenced and is now pending in this Court upon a Complaint of the above named Plaintiff against the above named Defendants for the purpose of quieting title to the hereinafter described property and forever barring all claims, rights, title, interest or lien of the above named Defendants in and to the property hereinafter described.
The property affected by this action is situated in the County of Richland, in the State of South Carolina and is described as follows:
All that certain piece, parcel or lot of land, situate, lying and being in the County of Richland, State of South Carolina, lying and being near the City of Columbia, known as 1016 Denton Drive, the same being shown as Lot Nineteen (19) of Block "L" on a plat of North Twenty-One Terrace, by McMillian Engineering Company dated January 21, 1963, revised July 26, 1968 and recorded in the Richland County Register of Deeds Office in Plat Book "X" at Pages 612 and 612A, and further shown on a plat prepared by Doretha A. Bull by Isaac B. Cox & Son, Inc., dated May 21, 1979 and recorded in the aforesaid R.O.D. Office in Plat Book "Y" at Page 4500, and being bounded as follows: Bounded on the North by Denton Drive, whereon it fronts and measures seventy (70') feet; on the East by Lot 18 of Block L, measuring thereon one hundred thirty (130') feet; on the South by Lot 5 of Block L, and measuring thereon seventy-nine and five-tenths (79.5') feet; and on the West by Lot 20 of Block L, measuring thereon one hundred forty-six (146') feet; be all measurements a little more or less.
Being the same property conveyed to Sterling M. Davis and Louise S. Davis by deed of Elias Mabry and Barber E. K. Mabry, recorded June 13, 1985, in the Richland County Register of Deeds Office in Deed Book D745 at Page 565. Being more recently conveyed to Yvonne Green, Gary Slater, Gregory Slater, Sherri Slater, Andrea Adams, and Ronald Slater by Deed of Distribution in the Matter of Louise Slater Davis, recorded August 17, 2001, in the aforesaid R.O.D. Office in Deed Book R556 at Page 451.
LAW OFFICE OF
H. Ronald Stanley
Attorney for Plaintiff
1418 Park Street
Post Office Box 7722
Columbia, SC 29202
(803) 799-4700
Columbia, South Carolina
April 10, 2006
SUMMONS
STATE OF
SOUTH CAROLINA
COUNTY OF RICHLAND
IN THE FAMILY COURT
FIFTH JUDICIAL CIRCUIT
06DR400338
BETTY W. TREACY,
Petitioner,
vs.
DEIRDRE TREACY, PHILLIP GLYMPH, JR., JOHN DOE and DEPARTMENT OF SOCIAL SERVICES,
Respondents.
IN RE: TODECIA TREACY GLYMPH (MINOR UNDER THE AGE OF EIGHTEEN YEARS)
TO: DEIRDRE TREACY, 1733 Morninglow Lane Columbia, SC 29223; PHILLIP GLYMPH c/o General Counsel's Office, South Carolina Department of Corrections; SOUTH CAROLINA DEPARTMENT OF SOCIAL SERVICES, c/o CELESTE MOORE, ESQUIRE, General Counsel's Office, P.O. Box 1520, Columbia, SC 29202.
YOU ARE HEREBY SUMMONED and required to answer the Petition in this action, a copy of which is hereby served upon you and to serve a copy of your Answer upon the Petitioner's attorney within thirty (30) days after the service hereof upon you, exclusive of the date of such service, and if you fail to answer the said Petition within the time aforesaid, the Petitioner in this action shall apply to the Court for Judgment by Default for the relief requested in the Petition.
James W.Potter
NEXSEN PRUET ADAMS KLEEMEIER, LLC
1441 Main St., Ste 1500 (29201)
PO Drawer 2426
Columbia, SC 29202
803.771.8900
Attorney for Petitioner
January 26, 2006
Columbia, South Carolina
NOTICE
YOU WILL PLEASE TAKE NOTICE that on January 26, 2006 an action was filed in the Family Court of the Fifth Judicial Circuit, Richland County, South Carolina, located at 1701 Main Street, Columbia, South Carolina, seeking the termination of parental rights, adoption and name change of the minor Defendant indicated in the Summons published herewith.
YOU WILL ALSO PLEASE TAKE NOTICE that following the 30th day after completion of service of the Summons published herewith, the Plaintiff will move for a hearing not less than ten (10) days thereafter at which time Plaintiff will move for a judgment hererin.
NEXSEN PRUET ADAMS KLEEMEIER, LLC
1441 Main St., Ste 1500 (29201)
PO Drawer 2426
Columbia, SC 29202
803.771.8900
Attorney for Petitioner
April 4, 2006
Columbia, South Carolina
SUMMONS
STATE OF
SOUTH CAROLINA
COUNTY OF RICHLAND
IN THE FAMILY COURT FOR THE FIFTH
JUDICIAL CIRCUIT
05-DR-40-3828
Wyona Jameelah Muhammad,
Plaintiff,
vs
Yuhanna A. Muhammad, Sr.,
Defendant.
TO: YUHANNA A. MUHAMMAD, SR.,
THE DEFENDANT ABOVE NAMED:
YOU ARE HEREBY SUMMONED and required to answer the Complaint, a copy of which is herewith served upon you, and to serve a copy of your Answer to said Complaint upon the subscriber at his office at 712 Calhoun Street, Suite D, Columbia, South Carolina, 29201 within thirty (30) day after the service thereof, exclusive of the day of such service, and if you fail to answer the Complaint within the time aforesaid. Judgment by Default will be rendered against you for the relief demanded in the Complaint.
Rolland E. Greenburg, III, PA
712 Calhoun Street, Suite D
Columbia, SC 29201
(803) 256-4408
Attorney for Plaintiff
Columbia, South Carolina
November 16, 2005
AMENDED SUMMONS
TO ANSWER
THE AMENDED
COMPLAINT
IN THE COURT OF
COMMON PLEAS
FIFTH JUDICIAL CIRCUIT
2005-CP-40-06785
William English Hopkins, Jr.
Plaintiff,
vs.
Sarah Frances Whyte, also known as Sarah Frances Whyte Boring, William Hope Whyte, and JOHN DOE and RICHARD DOE, as representatives of all heirs at law or devisees of the said Sarah Frances Whyte, also known as Sarah Frances Whyte Boring, and William Hope Whyte if they are deceased, and also as representatives of all other persons who are unknown who may claim or have any right, title, estate, interest in or lien upon the real estate described in the Complaint herein, said real property is shown on Richland County, South Carolina tax map 24600-06-02; any unknown adults as a class designated as JOHN DOE, and any unknown infants or persons under disability or persons in military services as a class designated as RICHARD ROE, Defendants.
TO THE RESPONDENT ABOVE NAMED:
YOU ARE HEREBY summoned and required to answer the Amended Complaint in this action, a copy of which is herewith served upon you, and to serve a copy of your Answer to the said Amended Complaint on the subscriber at her office located at 2512 Devine Street, Columbia, South Carolina, 29205 within thirty (30) days from the date of such service, exclusive of the date of such service; and if you fail to answer the Complaint within the time aforesaid; the Plaintiff herein will apply to the Court for an Order for Judgment by Default thereby granting the relief requested in said Complaint.
NOTICE OF FILING
NOTICE IS HEREBY GIVEN that the Amended Summons to Answer the Amended
Complaint (of which above is a copy), Amended Lis Pendens (of which the below is a copy), and
Amended Complaint in the above action which were filed in the Office of the clerk of Richland
County on March 8, 2006 .
TO MINORS OVER FOURTEEN YEARS OF AGE AND/OR TO MINORS UNDER
FOURTEEN YEARS OF AGE AND THE PERSON WITH WHOM THE MINOR RESIDES
AND/OR TO PERSONS UNDER SOME LEGAL DISABILITY:
YOU ARE FURTHER SUMMONED AND NOTIFIED that Plaintiff has applied for the appointment of Guardian ad Litem Nisi to represent said minors and/or persons under some legal disability.
TO UNKNOWN DEFENDANT OR DEFENDANTS WHO MAY BE IN THE MILITARY SERVICE OF THE UNITED STATE OF AMERICA.
YOU ARE FURTHER SUMMONED AND NOTIFIED that Plaintiff's attorney has applied for the appointment of an attorney to represent you. If you fail to apply for the appointment of an attorney to represent you within thirty (30) days after the service of the Summons and Notice upon you, Plaintiff's appointment will be made absolute with no further action from Plaintiff.
YOU WILL ALSO TAKE NOTICE that should you fail to answer the foregoing Summons, the Plaintiff will move for a general Order of Reference to the Master in Equity for Richland County, which Order shall, pursuant to Rule 53(e) of the South Carolina Rules of Civil Procedure, specifically provide that the Master in Equity is authorized and empowered to enter a final judgment in this action.
LIS PENDENS
NOTICE IS HEREBY GIVEN that an action has been commenced by the Plaintiff against Defendants to locate and establish boundaries, determine ownership and remove cloud from the title to real property in Richland County in which an interest may be claimed by the other partes. The real property is situate in Richland County and described as:
All that certain piece, parcel or lot of land situate, lying and being on the western side of Horrell Hill Road in the Willow Winds/Cross Hill Acre area of Hopkins, South Carolina containing 10 acres, more or less, in Richland County bearing Richland County Tax Map Sheet Number R24600-06-02. Said Property was devised to Sarah F. Whyte by her mother Emma Goodwin Hopkins
Whyte.
NOTICE OF ORDER APPOINTING GUARDIAN AD LITEM NISI
NOTICE IS HEREBY GIVEN that M. Leigh Flynn, Esquire has been appointed as Guardian Ad Litem Nisi by Order of Richland County Clerk of Court dated March 8, 2006, and filed on that same date in the Office of the Clerk of Court for Richland County to represent unknown minors and persons under disability.
MAYS, FOSTER, GUNTER & MURPHY, LLP
Carole H. Gunter
2512 Devine Street
Columbia, SC 29205
(803) 254-7091
Attorneys for the Plaintiff
Columbia, South Carolina
April 5, 2006
SUMMONS AND NOTICES
STATE OF
SOUTH CAROLINA
COUNTY OF RICHLAND
IN THE COURT OF
COMMON PLEAS
(NON-JURY MORTGAGE FORECLOSURE)
2006-CP-40-1489
GMAC Mortgage Corporation,PLAINTIFF,
vs.
Theodore W. Law, III a/k/a Theodore W. Law; and Mary L. Beggs,DEFENDANT(S).
TO THE DEFENDANTS ABOVE NAMED:
YOU ARE HEREBY SUMMONED and required to answer the Complaint herein, a copy of which is herewith served upon you, or to otherwise appear and defend, and to serve a copy of your Answer to said Complaint upon the subscribers at their office, 3955 Faber Place, Suite 200, P.O. Box 71727, North Charleston, South Carolina, 29415, or to otherwise appear and defend the action pursuant to applicable court rules, within thirty (30) days after service hereof, exclusive of the day of such service; except that the United States of America, if named, shall have sixty (60) days to answer after the service hereof, exclusive of such service; and if you fail to answer the Complaint or otherwise appear and defend within the time aforesaid, the Plaintiff in this action will apply to the Court for relief demanded therein, and judgment by default will be rendered against you for the relief demanded in the Complaint.
TO MINOR(S) OVER FOURTEEN YEARS OF AGE, AND/OR TO MINOR(S) UNDER FOURTEEN YEARS OF AGE AND THE PERSON WITH WHOM THE MINOR(S) RESIDE(S) AND/OR TO PERSONS UNDER SOME LEGAL DISABILITY:
YOU ARE FURTHER SUMMONED AND NOTIFIED to apply for the appointment of a guardian ad litem within thirty (30) days after the service of this Summons and Notice upon you. If you fail to do so, application for such appointment will be made by the Plaintiff.
YOU WILL ALSO TAKE NOTICE that pursuant to Rule 53(b) SCRCP, as amended effective September 1, 2002, the Plaintiff will move for a general Order of Reference to Joseph M. Strickland, the Master in Equity for Richland County, which Order shall, pursuant to Rule 53(b) of the South Carolina Rules of Civil Procedure, specifically provide that the said Master in Equity is authorized and empowered to enter a final judgment in this action. If there are counterclaims requiring a jury trial, any party may file a demand under rule 38, SCRCP and the case will be returned to the Circuit Court.
FINKEL & ALTMAN, L.L.C.
Post Office Box 71727
3955 Faber Place, Suite 200
North Charleston, South Carolina 29415
(843) 576-1072
BEVERLY J. FINKEL THOMAS A. SHOOK
ELIZABETH A. SHUFFLER
BRIAN M. ANNINO
SUSAN S. WHITE
RICHARD G. DUERINSKX
NOTICE OF
FILING COMPLAINT
NOTICE IS HEREBY GIVEN that the original Complaint in the above entitled action, together with the Summons, was filed in the Office of the Clerk of Court for Richland County on March 15, 2006.
FINKEL & ALTMAN, L.L.C.
Post Office Box 71727
3955 Faber Place, Suite 200
North Charleston, South Carolina 29415
(843) 576-1072
BEVERLY J. FINKEL THOMAS A. SHOOK
ELIZABETH A. SHUFFLER
BRIAN M. ANNINO
SUSAN S. WHITE
RICHARD G. DUERINSKX
LIS PENDENS
NOTICE IS HEREBY GIVEN that an action has been commenced and is now pending in this court upon Complaint of the above-named Plaintiff against the above-named Defendants for foreclosure of a certain mortgage of real estate given by Theodore W. Law, III to Mortgage Electronic Registration Systems, Inc., as nominee for Amerigroup Mortgage Corporation, in the amount of $149,400.00 dated February 7, 2004, and recorded in the Office of the Register of Deeds for Richland County in Book 904 at Page 473 on February 19, 2004.
The premises covered and affected by the said mortgage as by the foreclosure thereof, were, at the time of the making thereof, and at the time of the filing of this Notice, described as follows:
The following described property in the County of Richland and State of South Carolina, to-wit:
All that certain piece, parcel or tract of land, together with all improvements thereon, situate, lying and being near the Town of Blythewood, in Richland County, South Carolina and being shown on a plat prepared for Pearl E. Shirah Estate by Anderson & Associates, Land Surveyors, dated October 1, 1993 and recorded in Plat Book 1170 at Page 996. Reference to said plat is hereby craved for a more complete and accurate description of subject property.
TMS#: 09900-07-95
Property Address:
1401 Friendly Woods Road, Blythewood, SC
FINKEL & ALTMAN, L.L.C.
Post Office Box 71727
3955 Faber Place, Suite 200
North Charleston, South Carolina 29415
(843) 576-1072
BEVERLY J. FINKEL THOMAS A. SHOOK
ELIZABETH A. SHUFFLER
BRIAN M. ANNINO
SUSAN S. WHITE
RICHARD G. DUERINSKX
Charleston, South Carolina
SUMMONS AND NOTICES
STATE OF
SOUTH CAROLINA
COUNTY OF RICHLAND
IN THE COURT OF
COMMON PLEAS
(NON-JURY MORTGAGE FORECLOSURE)
2006-CP-40-0528
Mortgage Electronic Registration Systems, Inc., as nominee for GMAC Mortgage Corporation,PLAINTIFF,
vs.
Bruce A. Butler, Sr. a/k/a Bruce A. Butler, if not deceased, and if deceased, The Estate of Bruce A. Butler, Sr. a/k/a Bruce A. Butler, and any other Heirs, Personal Representatives, Successors, Assigns, Spouses, Creditors, and all others claiming any right, title or interest in the real estate known as 2829 Screaming Eagle Rd., Elgin, SC, any adults or persons in the Military Service of the United States of America, being a class designated as John Doe, and any minors or persons under legal disability, being a class designated as Richard Roe; Bruce Allen Butler, Jr.; Green Tree Investments, LLC, servicing agent for Green Tree Financial n/k/a Conseco Finance Servicing Corp.; and South Carolina Department of Motor Vehicles,,DEFENDANT(S).
TO THE DEFENDANTS ABOVE NAMED:
YOU ARE HEREBY SUMMONED and required to answer the Complaint herein, a copy of which is herewith served upon you, or to otherwise appear and defend, and to serve a copy of your Answer to said Complaint upon the subscribers at their office, 3955 Faber Place, Suite 105, North Charleston, South Carolina, 29415, within thirty (30) days after service hereof, exclusive of the day of such service; except that the United States of America, if named, shall have sixty (60) days to answer after the service hereof, exclusive of the day of such service; and if you fail to answer the Complaint within the time aforesaid, or otherwise appear and defend, the Plaintiff in this action will apply to the Court for the relief demanded therein, and judgment by default will be rendered against you for the relief demanded in the Complaint.
TO MINOR(S) OVER FOURTEEN YEARS OF ARE, AND/OR TO MINOR(S) UNDER FOURTEEN YEARS OF AGE AND THE PERSON WITH WHOM THE MINOR(S) RESIDES AND/OR TO PERSONS UNDER SOME LEGAL DISABILITY:
YOU ARE FURTHER SUMMOND AND NOTIFIED to apply for the appointment of a guardian ad litem within thirty (30) days after the service of this Summons and Notice upon you. If you fail to do so, application for such appointment will be made by the Plaintiff.
YOU WILL ALSO TAKE NOTICE that should you fail to answer the foregoing Summons, the Plaintiff will move for a general Order of Reference to Joseph M. Strickland, the Master in Equity for Richland, which Order shall, pursuant to Rule 53(b) of the South Carolina Rules of Civil Procedure, specifically provide that the said Master in Equity is authorized and empowered to enter a final judgment in this action.
FINKEL & ALTMAN, L.L.C.
Post Office Box 71727
3955 Faber Place, Suite 200
North Charleston, South Carolina 29415
(843) 576-1072
BEVERLY J. FINKEL THOMAS A. SHOOK
ELIZABETH A. SHUFFLER
BRIAN M. ANNINO
SUSAN S. WHITE
RICHARD G. DUERINSKX
NOTICE OF
FILING COMPLAINT
NOTICE IS HEREBY GIVEN that the original Complaint in the above entitled action, together with the Summons, was filed in the Office of the Clerk of Court for Richland County on January 25, 2006.
FINKEL & ALTMAN, L.L.C.
Post Office Box 71727
3955 Faber Place, Suite 200
North Charleston, South Carolina 29415
(843) 576-1072
BEVERLY J. FINKEL THOMAS A. SHOOK
ELIZABETH A. SHUFFLER
BRIAN M. ANNINO
SUSAN S. WHITE
RICHARD G. DUERINSKX
NOTICE OF
PENDENCY OF ACTION
NOTICE IS HEREBY GIVEN that an action has been commenced and is now pending in this court upon Complaint of the above-named Plaintiff against the above-named Defendants for foreclosure of a certain mortgage of real estate given by Bruce A. Butler, Sr. to The Peoples National Bank, in the amount of $72,000.00 dated May 13, 2002, and recorded in the Office of the Register of Deeds for Richland County in Book 668 at Page 2351 on May 31, 2002.
The premises covered and affected by the said mortgage as by the foreclosure thereof, were, at the time of the making thereof, and at the time of the filing of this Notice, described as follows:
All that certain piece, parcel, tract or lot of land, together with the improvements thereon, situate, lying and being in the County of Richland, State of South Carolina, on the Northern Side of Screaming Eagle Road, and being Shown and designated as 2.56 acres on a plat prepared for Robert C. Sessions by Cox and Dinkins, Inc., dated August 21, 1986 and recorded in the ROD for Richland County in Plat Book 51 at page 1598. Said parcel being located 0.4 miles West of Hwy Number 601 and is bounded as follows: South by the right of way of Screaming Eagle Road for a distance of 595.90 feet; On the West by lands now or formerly of Medlin whereon it measures 407.36 feet; On the East by lands now or formerly of Threadgill and McDuffie whereon it measures 578.78 feet. Be all measurements a little more or less.
TMS #: 35900-01-13
Property Address:
2829 Screaming Eagle Rd., Elgin, SC
FINKEL & ALTMAN, L.L.C.
Post Office Box 71727
3955 Faber Place, Suite 200
North Charleston, South Carolina 29415
(843) 576-1072
BEVERLY J. FINKEL THOMAS A. SHOOK
ELIZABETH A. SHUFFLER
BRIAN M. ANNINO
SUSAN S. WHITE
RICHARD G. DUERINSKX
Charleston, South Carolina
January 25, 2006
ORDER APPOINTING GUARDIAN AD LITEM NISI
It appearing to the satisfaction of the Court, upon reading and filing of the Petition of the Plaintiff for the appointment of Kelley Y. Woody, attorney in Columbia, South Carolina, as Guardian ad Litem Nisi for all unknown minors, and for all persons who may be under a legal disability, it is
ORDERED that Kelley Y. Woody, Attorney at Law, be and she is hereby appointed Guardian ad Litem Nisi on behalf of unknown minors or persons under a legal disability, all of whom may have an interest in or claim to have some interest in the real property known as 2829 Screaming Eagle Rd., Elgin, SC; that she is empowered and directed to appear on behalf of and represent said Defendants, unless the said Defendants, or someone on their behalf, shall within thirty (30) days after service of a copy hereof as directed, procure the appointment of a Guardian ad Litem for the said Defendants;
AND IT IS FURTHER ORDERED that a copy of this Order shall forthwith be served upon the said Defendants by publication thereof in the Columbia Star (f/k/a The Star Reporter), a newspaper of general circulation published in the County of Richland, State of South Carolina, once a week for three consecutive weeks, together with the Amended Summons in the above entitled action.
Barbara A. Scott, Clerk of Court for Richland County
Columbia, South Carolina
April 7, 2006
SUMMONS AND NOTICES
STATE OF
SOUTH CAROLINA
COUNTY OF RICHLAND
IN THE COURT OF
COMMON PLEAS
(NON-JURY MORTGAGE FORECLOSURE)
2006-CP-40-01628
National City Mortgage,
PLAINTIFF,
vs.
Wadesworth Brown; Jackie Stokes-Brown; Manigault-Hurley Funeral Home; The Loan Pros Inc.; Palmetto Health Alliance dba Palmetto Richland Memorial, and Summer Valley Homeowners Association, Inc.,
DEFENDANTS.
TO THE DEFENDANTS ABOVE NAMED:
YOU ARE HEREBY SUMMONED and required to answer the Complaint herein, a copy of which is herewith served upon you, or to otherwise appear and defend, and to serve a copy of your Answer to said Complaint upon the subscribers at their office, 3955 Faber Place, Suite 200, P.O. Box 71727, North Charleston, South Carolina, 29415, or to otherwise appear and defend the action pursuant to applicable court rules, within thirty (30) days after service hereof, exclusive of the day of such service; except that the United States of America, if named, shall have sixty (60) days to answer after the service hereof, exclusive of such service; and if you fail to answer the Complaint or otherwise appear and defend within the time aforesaid, the Plaintiff in this action will apply to the Court for relief demanded therein, and judgment by default will be rendered against you for the relief demanded in the Complaint.
TO MINOR(S) OVER FOURTEEN YEARS OF AGE, AND/OR TO MINOR(S) UNDER FOURTEEN YEARS OF AGE AND THE PERSON WITH WHOM THE MINOR(S) RESIDE(S) AND/OR TO PERSONS UNDER SOME LEGAL DISABILITY:
YOU ARE FURTHER SUMMONED AND NOTIFIED to apply for the appointment of a guardian ad litem within thirty (30) days after the service of this Summons and Notice upon you. If you fail to do so, application for such appointment will be made by the Plaintiff.
YOU WILL ALSO TAKE NOTICE that pursuant to Rule 53(b) SCRCP, as amended effective September 1, 2002, the Plaintiff will move for a general Order of Reference to the Master in Equity for Richland County, which Order shall, pursuant to Rule 53(b) of the South Carolina Rules of Civil Procedure, specifically provide that the said Master in Equity is authorized and empowered to enter a final judgment in this action. If there are counterclaims requiring a jury trial, any party may file a demand under rule 38, SCRCP and the case will be returned to the Circuit Court.
FINKEL & ALTMAN, L.L.C.
Post Office Box 71727
3955 Faber Place, Suite 200
North Charleston, SC 29415
(843) 576-1072
BEVERLY J. FINKEL THOMAS A. SHOOK
ELIZABETH A. SHUFFLER
BRIAN M. ANNINO
SUSAN S. WHITE
RICHARD G. DUERINSKX
NOTICE OF FILING
COMPLAINT
NOTICE IS HEREBY GIVEN that the original Complaint in the above entitled action, together with the Summons, was filed in the Office of the Clerk of Court for Richland County on March 21, 2006 at 3:14 p.m.
FINKEL & ALTMAN, L.L.C.
Post Office Box 71727
3955 Faber Place, Suite 200
North Charleston, SC 29415
(843) 576-1072
BEVERLY J. FINKEL THOMAS A. SHOOK
ELIZABETH A. SHUFFLER
BRIAN M. ANNINO
SUSAN S. WHITE
RICHARD G. DUERINSKX
LIS PENDENS
NOTICE IS HEREBY GIVEN that an action has been commenced and is now pending in this court upon Complaint of the above-named Plaintiff against the above-named Defendants for foreclosure of a certain mortgage of real estate given by Wadesworth Brown and Jackie Stokes-Brown to Beazer Mortgage Corporation, in the amount of $151,659.00 dated June 25, 2004, and recorded in the Office of the Register of Deeds for Richland County in Book 955 at Page 42 on July 9, 2004.
The premises covered and affected by the said mortgage as by the foreclosure thereof, were, at the time of the making thereof, and at the time of the filing of this Notice, described as follows:
All that certain piece, parcel or lot of land, situate, lying and being in the County of Richland, State of South Carolina, and being more particularly shown and delineated as Lot No. 71, Summer Side at Summer Valley Subdivision, Phase II-B, as shown on that certain plat entitled: "Bonded Plat prepared for Summer Valley Subdivision, Phase II-B, a portion of Summer Valley Development Corp., site located in Richland County, South Carolina", dated October 10, 2003, revised December 19, 2003, and recorded in the ROD for Richland County in Plat Book 00887, Page 1595. Said lot having such size, shape, dimensions, buttings and boundings as will by reference to said plat more fully and at large appear.
TMS#: 17216-06-05
Property Address:
336 Summer Bend Rd., Columbia, SC
FINKEL & ALTMAN, L.L.C.
Post Office Box 71727
3955 Faber Place, Suite 200
North Charleston, SC 29415
(843) 576-1072
BEVERLY J. FINKEL THOMAS A. SHOOK
ELIZABETH A. SHUFFLER
BRIAN M. ANNINO
SUSAN S. WHITE
RICHARD G. DUERINSKX
Charleston, South Carolina
March 21, 2006
SUMMONS AND NOTICES
STATE OF
SOUTH CAROLINA
COUNTY OF RICHLAND
IN THE COURT OF
COMMON PLEAS
(NON-JURY MORTGAGE FORECLOSURE)
2006-CP-40-01487
Deutsche Bank National Trust Company, as Trustee for FFMLT Trust 2005-FF8, Mortgage Pass-Though Certificates, Series 2005-FF8,
PLAINTIFF,
vs.
Rebecca G. Hall a/k/a Rebecca Hall,
DEFENDANT.
TO THE DEFENDANTS ABOVE NAMED:
YOU ARE HEREBY SUMMONED and required to answer the Complaint herein, a copy of which is herewith served upon you, or to otherwise appear and defend, and to serve a copy of your Answer to said Complaint upon the subscribers at their office, 3955 Faber Place, Suite 200, P.O. Box 71727, North Charleston, South Carolina, 29415, or to otherwise appear and defend the action pursuant to applicable court rules, within thirty (30) days after service hereof, exclusive of the day of such service; except that the United States of America, if named, shall have sixty (60) days to answer after the service hereof, exclusive of such service; and if you fail to answer the Complaint or otherwise appear and defend within the time aforesaid, the Plaintiff in this action will apply to the Court for relief demanded therein, and judgment by default will be rendered against you for the relief demanded in the Complaint.
TO MINOR(S) OVER FOURTEEN YEARS OF AGE, AND/OR TO MINOR(S) UNDER FOURTEEN YEARS OF AGE AND THE PERSON WITH WHOM THE MINOR(S) RESIDE(S) AND/OR TO PERSONS UNDER SOME LEGAL DISABILITY:
YOU ARE FURTHER SUMMONED AND NOTIFIED to apply for the appointment of a guardian ad litem within thirty (30) days after the service of this Summons and Notice upon you. If you fail to do so, application for such appointment will be made by the Plaintiff.
YOU WILL ALSO TAKE NOTICE that pursuant to Rule 53(b) SCRCP, as amended effective September 1, 2002, the Plaintiff will move for a general Order of Reference to the Master in Equity for Richland County, which Order shall, pursuant to Rule 53(b) of the South Carolina Rules of Civil Procedure, specifically provide that the said Master in Equity is authorized and empowered to enter a final judgment in this action. If there are counterclaims requiring a jury trial, any party may file a demand under rule 38, SCRCP and the case will be returned to the Circuit Court.
FINKEL & ALTMAN, L.L.C.
Post Office Box 71727
3955 Faber Place, Suite 200
North Charleston, SC 29415
(843) 576-1072
BEVERLY J. FINKEL THOMAS A. SHOOK
ELIZABETH A. SHUFFLER
BRIAN M. ANNINO
SUSAN S. WHITE
RICHARD G. DUERINSKX
NOTICE OF
FILING COMPLAINT
NOTICE IS HEREBY GIVEN that the original Complaint in the above entitled action, together with the Summons, was filed in the Office of the Clerk of Court for Richland County on March 15, 2006 at 2:45 p.m.
FINKEL & ALTMAN, L.L.C.
Post Office Box 71727
3955 Faber Place, Suite 200
North Charleston, SC 29415
(843) 576-1072
BEVERLY J. FINKEL THOMAS A. SHOOK
ELIZABETH A. SHUFFLER
BRIAN M. ANNINO
SUSAN S. WHITE
RICHARD G. DUERINSKX
LIS PENDENS
NOTICE IS HEREBY GIVEN that an action has been commenced and is now pending in this court upon Complaint of the above-named Plaintiff against the above-named Defendants for foreclosure of a certain mortgage of real estate given by Rebecca G. Hall to First Franklin a division of Nat. City Bank if IN, in the amount of $98,000.00 dated May 20, 2005, and recorded in the Office of the Register of Deeds for Richland County in Book 1056 at Page 2206 on May 24, 2005.
The premises covered and affected by the said mortgage as by the foreclosure thereof, were, at the time of the making thereof, and at the time of the filing of this Notice, described as follows:
All that certain piece, parcel or lot of land, together with improvements thereon, situate, lying and being near the City of Columbia, in the County of Richland, State of South Carolina, being shown and designated as Lot 52, on a plat of Hunter's Pond-Phase I by Cox and Dinkins, Inc., dated November 3, 1987, and recorded in the Office of the RMC for Richland County in Plat Book 51 at Page 9742. Being more specifically shown and delineated on a plat prepared for Patricia M. Coleman by Cox and Dinkins, Inc. dated September 27, 1999 and recorded in Plat Book 355 at Page 417. Said plats are incorporated herein and reference is craved thereto for a more complete and accurate description of the metes, bounds, courses and distances of the property concerned herein. Be all measurements a little more or less.
TMS#: 07506-01-76
Property Address:
2336 Rolling Hills Road, Columbia, SC
FINKEL & ALTMAN, L.L.C.
Post Office Box 71727
3955 Faber Place, Suite 200
North Charleston, SC 29415
(843) 576-1072
BEVERLY J. FINKEL THOMAS A. SHOOK
ELIZABETH A. SHUFFLER
BRIAN M. ANNINO
SUSAN S. WHITE
RICHARD G. DUERINSKX
North Charleston, South Carolina
March 15, 2006
SUMMONS
STATE OF
SOUTH CAROLINA
COUNTY OF RICHLAND
IN THE COURT OF
COMMON PLEAS
(Non-Jury Foreclosure)
2005-CP-40-05348
Mortgage Electronic Registration Systems, Inc., Plaintiff,
vs.
Eleanor B. Coffin, Defendant.
TO THE DEFENDANTS ABOVE NAMED:
YOU ARE HEREBY SUMMONED and required to answer the Complaint in this action of which a copy is herewith served upon you, and to serve a copy of your Answer on the subscribers at their offices, 1704 Main Street, Post Office Box 58, Columbia, South Carolina 29202, within thirty (30) days after the service hereof, exclusive of the day of such service, and if you fail to answer the Complaint within the time aforesaid, the Plaintiff in this action will apply to the Court for judgment by default for the relief demanded in the Complaint. Your answer must be in writing and signed by you or by your attorney and must state your address or the address of your attorney, if signed by your attorney. This communication is an attempt to collect a debt, and any information will be used for that purpose.
McDONALD, McKENZIE, RUBIN, MILLER AND LYBRAND, L.L.P.
Post Office Box 58
Columbia, SC 29202
(803) 252-0500
Ben N. Miller III
Attorney for the Plaintiff
October 18, 2005
NOTICE
TO THE DEFENDANT ELEANOR B COFFIN:
Notice is hereby given that the Complaint in the foregoing action, together with the Summons, of which the foregoing is a copy, was filed in the Office of the Clerk of Court for Richland County on the 18th day of October, 2005.
McDONALD, McKENZIE, RUBIN, MILLER AND LYBRAND, L.L.P.
Post Office Box 58
Columbia, SC 29202
(803) 252-0500
Ben N. Miller III
Attorney for the Plaintiff
April 12, 2006
XXXXXX
SUMMONS
STATE OF
SOUTH CAROLINA
COUNTY OF RICHLAND
IN THE FAMILY COURT
5th JUDICIAL CIRCUIT
2006-DR-40-1166
Michelle Robinson West
Plaintiff
vs. Jerome Richardson West,
Defendant TO THE DEFENDANT NAMED ABOVE:
YOU ARE HEREBY SUMMONED and required to answer the Complaint in this action of which a copy is hereby served upon you. Serve a copy of your Answer to this action, on the subscriber at his office at 6708 Lake Arcadia Lane, Columbia, South Carolina 29206 within thirty (30) days after date of service, exclusive of the day of such service. If you fail to answer the Complaint within the time prescribed, the Plaintiff will apply to the Court for a judgment by default, and for the relief requested in the Complaint.
RESPECTFULLY
SUBMITTED,
Eric Mohn, Esq.
6708 Lake Arcadia Lane
Columbia SC 29206
803-920-0220
March 22, 2006
SUMMONS
STATE OF
SOUTH CAROLINA
COUNTY OF RICHLAND
FAMILY COURT
06-DR-40-0125
Franklin D. Stephens,
Plaintiff,
vs.
Nayoka K. Stephens,
Defendant.
TO: THE DEFENDANT ABOVE-NAMED:
YOU ARE HEREBY SUMMONED and required to Answer the Complaint in this action, a copy of which is hereby served upon you, and to serve a copy of your Answer to the said Complaint on the attorney for the Plaintiff, at her office, 1012 Woodrow Street, Columbia, South Carolina, 29205, within thirty (30) days after the service hereof, exclusive of the day of such service, and if you fail to Answer the Complaint within the time aforesaid, judgment by default will be rendered against you for the relief demanded in the Complaint.
Mont S. Pincus,
Attorney at Law
1012 Woodrow Street
Columbia, SC 29205
803 576-3755
Attorney for: Plaintiff
January 4, 2006
Columbia, South Carolina
SUMMONS
STATE OF
SOUTH CAROLINA
COUNTY OF RICHLAND
FAMILY COURT
05-DR-40-4070
Anton W. Corley,
Plaintiff,
vs.
Helen W. Corley,
Defendant.
TO: THE DEFENDANT ABOVE-NAMED:
YOU ARE HEREBY SUMMONED and required to Answer the Complaint in this action, a copy of which is hereby served upon you, and to serve a copy of your Answer to the said Complaint on the attorney for the Plaintiff, at her office, 1012 Woodrow Street, Columbia, South Carolina, 29205, within thirty (30) days after the service hereof, exclusive of the day of such service, and if you fail to Answer the Complaint within the time aforesaid, judgment by default will be rendered against you for the relief demanded in the Complaint.
Mont S. Pincus,
Attorney at Law
1012 Woodrow Street
Columbia, SC 29205
803 576-3755
Attorney for: Plaintiff
November 30, 2005
Columbia, South Carolina
SUMMONS AND NOTICES
STATE OF
SOUTH CAROLINA
COUNTY OF RICHLAND
IN THE COURT OF
COMMON PLEAS
2006-CP-40-01114
Citifinancial Mortgage Company, Inc.
Plaintiff,
vs.
Shonda Y. Huggins, John W. Huggins, Richland County Finance Department and The National Bank of South Carolina,
Defendant(s).
(FSC) 10208
TO THE DEFENDANT(S): JOHN W. HUGGINS
YOU ARE HEREBY SUMMONED and required to appear and defend by answering the Complaint in this action, a copy of which is hereby served upon you, and to serve a copy of your Answer on the subscribers at their offices, 140 Stoneridge Drive, Suite 450, Columbia, South Carolina 29210, within thirty (30) days after the service hereof, exclusive of the day of such service; except that the United States of America, if named, shall have sixty (60) days to answer after the service hereof, exclusive of the day of such service; and if you fail to do so, judgment by default will be rendered against you for the relief demanded in the complaint.
TO MINOR(S) OVER FOURTEEN YEARS OF AGE, AND/OR TO MINOR(S) UNDER FOURTEEN YEARS OF AGE AND THE PERSON WITH WHOM THE MINOR(S) RESIDES, AND/OR TO PERSONS UNDER SOME LEGAL DISABILITY:
YOU ARE FURTHER SUMMONED AND NOTIFIED to apply for the appointment of a guardian ad litem within thirty (30) days after the service of this Summons and Notice upon you. If you fail to do so, application for such appointment will be made by Plaintiff.
YOU WILL ALSO TAKE NOTICE that under the provisions of South Carolina Code 29-3-100, effective June 16, 1993, any collateral assignment of rents contained in the attached mortgage is perfected and Plaintiff hereby gives notice that all rents shall be payable directly to it by delivery to its undersigned attorneys from the date of default. In the alternative, Plaintiff will move before a judge of this Circuit on the 10th day after service hereof, or as soon thereafter as counsel may be heard, for an Order enforcing the assignment of rents, if any, and compelling payment of all rents covered by such assignment directly to the Plaintiff, which motion is to be based upon the original note and mortgage and the Complaint attached hereto.
Sandra L. Burr,
SC Bar No. 1045
PERRIE & COLE OF SC, LLC
140 Stoneridge Dr.,Suite 450
Columbia, SC 29210
(803) 255-1856
Attorneys for Plaintiff
March 20, 2006
Columbia, South Carolina
NOTICE
TO THE DEFENDANT JOHN W. HUGGINS:
YOU WILL TAKE NOTICE that the Cover Sheet for Civil Actions, Certificate of Exemption/Withdrawal from Arbitration and Mediation, Summons and Notices, and Complaint, of which the foregoing is a copy of the Summons, were filed with the Clerk of Court for Richland County, South Carolina on February 24, 2006. Sandra L. Burr,
SC Bar No. 1045
PERRIE & COLE OF SC, LLC
140 Stoneridge Dr., Suite 450
Columbia, SC 29210
(803) 255-1856
Attorneys for Plaintiff
SUMMONS AND NOTICE OF FILING
OF COMPLAINT
STATE OF
SOUTH CAROLINA
COUNTY OF RICHLAND
IN THE COURT OF
COMMON PLEAS
(NON-JURY MORTGAGE FORECLOSURE)
2006-CP-40-1596
DEFICIENCY WAIVED
Wells Fargo Bank N.A., s/b/m from Wells Fargo Home Mortgage, Inc.,
PLAINTIFF,
vs.
Jimmy Orange and Mrs. Earl Peak,
DEFENDANTS.
F26-01805
TO THE DEFENDANTS, ABOVE NAMED:
YOU ARE HEREBY SUMMONED and required to answer the Complaint in the above entitled action, a copy of which is herewith served upon you, and to serve a copy of your answer upon the undersigned at their office, 1300 Pickens Street, Columbia, South Carolina, within thirty (30) days after service hereof upon you, exclusive of the day of such service, and if you fail to answer the Complaint within the time aforesaid or otherwise appear and defend, the Plaintiff, in this action will apply to the Court for the relief demanded in the Complaint, and judgment by default will be rendered against you for the relief demanded in the Complaint.
NOTICE IS HEREBY GIVEN that the original Complaint in the above entitled action was filed in the Office of the Clerk of Court for Richland County on March 20, 2006.
KORN LAW FIRM, P.A.
P.O. Box 11264
1300 Pickens Street
Columbia, South Carolina 29211-1264
JOHN S. KAY
Attorney for Plaintiff
Columbia, South Carolina
April 4, 2006
LIS PENDENS
STATE OF
SOUTH CAROLINA
COUNTY OF RICHLAND
IN THE COURT OF
COMMON PLEAS
(NON-JURY MORTGAGE FORECLOSURE)
2006-CP-40-1596
DEFICIENCY WAIVED
Wells Fargo Bank N.A., s/b/m from Wells Fargo Home Mortgage, Inc.,
PLAINTIFF,
vs.
Jimmy Orange and Mrs. Earl Peak,
DEFENDANTS.
F26-01805
NOTICE IS HEREBY GIVEN that an action has been commenced and is now pending in this court upon Complaint of the above-named Plaintiff against the above-named Defendant for foreclosure of a certain mortgage of real estate given by Mary Jo Davidson to BarclaysAmerican/Mortgage Corporation in the amount of Forty-Three Thousand Seven Hundred Forty-One And 00/100 ($43,741.00) Dollars, dated November 7, 1985, and recorded in the Office of the Clerk of Court for Richland County in Book M-889 Page 870. Thereafter, by virtue of an assignment dated July 15, 1996, recorded July 18, 1996, in Mortgage Book M2000 at page 74, Barclays American / Mortgage Corporation assigned said mortgage unto Norwest Mortgage, Inc. Thereafter, by virtue of a corporate merger, Norwest Mortgage, Inc. merged with Wells Fargo Home Mortgage, Inc. Thereafter, by virtue of a corporate merger, Wells Fargo Home Mortgage, Inc. merged with Wells Fargo Bank, N.A. Wells Fargo Bank, N.A. is present lien holder and Plaintiff herein.
The premises covered and affected by the said mortgage as by the foreclosure thereof, were, at the time of the making thereof, and at the time of the filing of this Notice, described as follows:
LEGAL DESCRIPTION AND PROPERTY ADDRESS:
All that certain piece, parcel or lot of land, together with the improvements thereon, situate, lying and being in the City of Columbia, County of Richland, State of South Carolina, the same being shown as Lot No. 2 on a plat of Subdivision of Property of Mrs. Laura M. Dent by Barber, Keels & Associates, dated April 26, 1950, recorded in the Office of the RMC for Richland County in Plat Book N at page 184; and being more particularly shown on a plat prepared for Mary Jo Davidson by Donald G. Platt, R.L.S., dated November 6, 1985, to be recorded, and according to said latter plat having the following boundaries and measurements, to-wit: on the northwest by Lot No. 3, whereon it measures 125.5 feet; on the northeast by Druid Hills Subdivision, whereon it measures 60.6 feet; on the southeast by Lot No. 1, whereon it measures 135.0 feet; and on the southwest by Bu-Don Court, whereon it measures 60.0 feet; be all the said measurements a little more or less.
This being the same property conveyed to Mary Jo Davidson by Deed of William Porter Price, III dated November 7, 1985 and recorded November 12, 1985 in Book D-767 at page 723 in the Office of the Register of Deeds for Richland County, South Carolina. Thereafter, the property was conveyed to Mrs. Earl Peak by Deed of Mary Jo Davidson dated May 22, 1987 and recorded June 8, 1987 in Book D-844 at page 264 in said Register of Deeds Office. Thereafter, the property was conveyed to Jimmy Orange by Deed of Mrs. Earl Peak dated November 13, 1989 and recorded November 14, 1989 in Book D-957 at page 292 in said Register of Deeds Office.
1706 Budon Court,
Columbia, SC 29204
TMS #: 14001-04-19
KORN LAW FIRM, P.A.
1300 Pickens Street.
P.O. Box 11264
Columbia, SC 29211-1264
J. SCOTT WALLS
H. GUYTON MURRELL
Attorney for Plaintiff
Columbia, South Carolina
March 17, 2006
SUMMONS AND NOTICE OF FILING OF COMPLAINT
STATE OF
SOUTH CAROLINA
COUNTY OF RICHLAND
IN THE COURT OF
COMMON PLEAS
CASE # 2005-CP-40-1621Glimcher Properties Limited Partnership,
Plaintiff,vs. The Box Office, Inc., d/b/a The Box Office and Jamie R. Rosen, individually, d/b/a The Box Office
Defendants.TO THE ABOVE-NAMED DEFENDANTS:
YOU ARE HEREBY SUMMONED and required to answer the Complaint in the above-titled action, a copy of which is filed with the Clerk of Court of Richland County, 1701 Main Street, Post Office Box 2766, Columbia, South Carolina 29201, and to serve a copy of your answer upon the undersigned at P.O. Box 727, Columbia, SC 29202-0727 within thirty (30) days after the date of the last publication of this notice, exclusive of the day of such publication and if you fail to answer the Complaint in the time aforesaid or otherwise appear and defend, the Plaintiff will apply to the Court for the relief demanded in the Complaint and judgment by default will be rendered against you for such relief demanded.
NOTICE IS HEREBY GIVEN that the original Complaint in the above-titled action was filed in the office of the Clerk of Court for Richland County on April 8, 2005.
GREGORY G. WILLIAMS, ATTORNEY, LLC
Michael W. Smith
Attorneys for Plaintiff
April 4, 2006
SUMMONS
STATE OF
SOUTH CAROLINA
COUNTY OF RICHLAND
IN THE COURT OF
COMMON PLEAS
(Non-Jury)
Quiet Title Action
2006-CP-40-00519
Chesterfield Express, LLC,
Plaintiff,
vs.
WW and Associates; and
Stephen Craig White, Sr.,
Defendants.
TO: THE DEFENDANTS ABOVE-NAMED:
YOU ARE HEREBY SUMMONED and required to answer the Complaint herein, a copy of which is herewith served upon you, and to serve a copy of your answer to said Complaint upon the subscriber, at his office at Post Office Box 2285, Columbia, South Carolina 29202, within thirty (30) days after the service hereof, exclusive of the day of such service, and if you fail to answer the Complaint within the time aforesaid, judgment by default will be rendered against you for the relief demanded in the Complaint.
Columbia, South Carolina
January 25, 2006
NOTICE OF FILING
NOTICE IS HEREBY GIVEN that the original Summons and Complaint in this action
were filed in the Office of the Clerk of Court for Richland County on January 25, 2006 at 2:44 p.m.
Michael K. Hatch
Attorney for Plaintiff
ELLIS, LAWHORNE & SIMS, P.A.
1501 Main Street, Fifth Floor
Post Office Box 2285
Columbia, SC 29202
(803) 254-4190
mhatch@ellislawhorne.com
Columbia, South Carolina
March 31, 2006.
XXXXXXX
SUMMONS AND NOTICES
STATE OF
SOUTH CAROLINA
COUNTY OF RICHLAND
IN THE COURT OF
COMMON PLEAS
2006-CP-40-00013
Citifinancial Mortgage Company, Inc.,
Plaintiff,
vs.
Yvonne Lyles, Kimberly A. Hampton, East Richland County Public Service District, Homes of Polo Homeowner's Association, Inc., GE Capital Financial, Inc., William Miller Lumber Company and Randolph Hallman,
Defendant(s).
(FSC) 10118
TO THE DEFENDANT(S): KIMBERLY A. HAMPTON
YOU ARE HEREBY SUMMONED and required to appear and defend by answering the Complaint in this action, a copy of which is hereby served upon you, and to serve a copy of your Answer on the subscribers at their offices, 140 Stoneridge Drive, Suite 450, Columbia, South Carolina 29210, within thirty (30) days after the service hereof, exclusive of the day of such service; except that the United States of America, if named, shall have sixty (60) days to answer after the service hereof, exclusive of the day of such service; and if you fail to do so, judgment by default will be rendered against you for the relief demanded in the complaint.
TO MINOR(S) OVER FOURTEEN YEARS OF AGE, AND/OR TO MINOR(S) UNDER FOURTEEN YEARS OF AGE AND THE PERSON WITH WHOM THE MINOR(S) RESIDES, AND/OR TO PERSONS UNDER SOME LEGAL DISABILITY:
YOU ARE FURTHER SUMMONED AND NOTIFIED to apply for the appointment of a guardian ad litem within thirty (30) days after the service of this Summons and Notice upon you. If you fail to do so, application for such appointment will be made by Plaintiff.
YOU WILL ALSO TAKE NOTICE that under the provisions of South Carolina Code 29-3-100, effective June 16, 1993, any collateral assignment of rents contained in the attached mortgage is perfected and Plaintiff hereby gives notice that all rents shall be payable directly to it by delivery to its undersigned attorneys from the date of default. In the alternative, Plaintiff will move before a judge of this Circuit on the 10th day after service hereof, or as soon thereafter as counsel may be heard, for an Order enforcing the assignment of rents, if any, and compelling payment of all rents covered by such assignment directly to the Plaintiff, which motion is to be based upon the original note and mortgage and the Complaint attached hereto.
Sandra L. Burr, SC Bar#1045
PERRIE & COLE OF SC, LLC
140 Stoneridge Dr., Ste. 450
Columbia, SC29210
(803) 255-1856
Attorneys for Plaintiff
March 15, 2006
Columbia, South Carolina
NOTICE
TO THE DEFENDANT:
KIMBERLY A. HAMPTON:
YOU WILL TAKE NOTICE that the Cover Sheet for Civil Actions, Certificate of Exemption/Withdrawal from Arbitration and Mediation, Summons and Notices, and Complaint, of which the foregoing is a copy of the Summons, were filed with the Clerk of Court for Richland County, South Carolina on January 3, 2006. Sandra L. Burr, SC Bar#1045
PERRIE & COLE OF SC, LLC
140 Stoneridge Dr., Ste. 450
Columbia, SC29210
(803) 255-1856
Attorneys for Plaintiff
SUMMONS
and
NOTICE OF FILING OF
LIS PENDENS AND
COMPLAINT
STATE OF
SOUTH CAROLINA
COUNTY OF RICHLAND
IN THE COURT OF
COMMON PLEAS
05-CP-40-0814
Homes of Polo Homeowner's Association, Inc.
Plaintiff,
vs.
Yvonne Lyles, Kimberly Hampton, East Richland
County Public Service District, and CitiFinancial
Mortgage Company, Inc.
Defendants.
TO DEFENDANT YVONNE LYLES AND KIMBERLY HAMPTON:
YOU ARE HEREBY SUMMONED and required to answer the Complaint in the above entitled action, a copy of which is filed with the Clerk of Court of Richland County, 1701 Main Street, Post Office Box 2766, Columbia, South Carolina 29201, and to serve a copy of your answer upon the undersigned at Post Office Box 61110, Columbia, South Carolina 29260-1110, within thirty (30) days after the date of the last publication of this notice, exclusive of the day of such publication and if you fail to answer the Complaint in the time aforesaid or otherwise appear and defend, the Plaintiff will apply to the Court for the relief demanded in the Complaint and judgment by default will be rendered against you for such relief demanded.
NOTICE IS HEREBY GIVEN that the original Lis Pendens and Complaint in the above titled action were filed in the office of the Clerk of Court for Richland County on December 1, 2005.
BRUNER, POWELL, ROBBINS, WALL & MULLINS, LLC
Christopher B. Kirk
Attorneys for the Plaintiff
Columbia, SC
March 24, 2006
SUMMONS AND NOTICES
STATE OF
SOUTH CAROLINA
COUNTY OF RICHLAND
IN THE COURT OF
COMMON PLEAS
2005-CP-40-0199
Green Tree Servicing, LLC as successor in interest to Conseco Finance Servicing Corp.,
Plaintiff,
vs.
The Personal Representative, if any, whose name is unknown, of the Estate of Benjamin O. Gates, Jr. a/k/a Benjamin O. Gates a/k/a Benjamin Ollie Gates, Ariel Gates, and any other Heirs-at-Law or Devisees of Benjamin O. Gates, Jr. a/k/a Benjamin O. Gates a/k/a Benjamin Ollie Gates, Deceased, their heirs, Personal Representatives, Administrators, Successors and Assigns, and all other persons entitled to claim through them; all unknown persons with any right, title or interest in the real estate described herein; also any persons who may be in the military service of the United States of America, being a class designated as John Doe; and any unknown minors or persons under a disability being a class designated as Richard Roe; The South Carolina Department of Revenue; and Holbrooks Jewel Box, Defendant(s).
( 771.030378)
TO THE DEFENDANT(S) ALL UNKNOWN PERSONS WITH ANY RIGHT, TITLE OR INTEREST IN THE REAL ESTATE DESCRIBED HEREIN; ALSO ANY PERSONS WHO MAY BE IN THE MILITARY SERVICE OF THE UNITED STATES OF AMERICA, BEING A CLASS DESIGNATED AS JOHN DOE; AND ANY UNKNOWN MINORS OR PERSONS UNDER A DISABILITY BEING A CLASS DESIGNATED AS RICHARD ROE AND ARIEL GATES:
YOU ARE HEREBY SUMMONED and required to appear and defend by answering the Complaint in this action, of which a copy is herewith served upon you, and to serve a copy of your Answer on the subscribers at their offices, 1804 Bull Street, Post Office Box 12125, Columbia, SC 29211, within thirty (30) days after the service hereof, exclusive of the day of such service; except that the United States of America, if named, shall have sixty (60) days to answer after the service hereof, exclusive of the day of such service; and if you fail to do so, judgment by default will be rendered against you for the relief demanded in the complaint.
TO MINOR(S) OVER FOURTEEN YEARS OF AGE, AND/OR TO MINOR(S) UNDER FOURTEEN YEARS OF AGE AND THE PERSON WITH WHOM THE MINOR(S) RESIDES, AND/OR TO PERSONS UNDER SOME LEGAL DISABILITY:
YOU ARE FURTHER SUMMONED AND NOTIFIED to apply for the appointment of a guardian ad litem within thirty (30) days after the service of this Summons and Notice upon you. If you fail to do so, application for such appointment will be made by the Plaintiff.
YOU WILL ALSO TAKE NOTICE that under the provisions of South Carolina Code 29-3-100, effective June 16, 1993, any collateral assignment of rents contained in the attached mortgage is perfected and Plaintiff hereby gives notice that all rents shall be payable directly to it by delivery to its undersigned attorneys from the date of default. In the alternative, Plaintiff will move before a judge of this Circuit on the 10th day after service hereof, or as soon thereafter as counsel may be heard, for an Order enforcing the assignment of rents, if any, and compelling payment of all rents covered by such assignment directly to the Plaintiff, which motion is to be based upon the original note and mortgage and the Complaint attached hereto.
Pearce W. Fleming,
S.C. Bar No. 2038
D. Randolph Whitt,
S.C. Bar No. 13068
Martha T. Self,
S.C. Bar No. 73661
FLEMING & WHITT, P. A.
1301 Gervais St., Suite 500
Post Office Box 12125
Columbia, SC 29211-2125
(803) 254-4751
Attorneys for Green Tree Servicing, LLC as successor in interest to Conseco Finance Servicing Corp.
Columbia, South Carolina
March 22, 2006
NOTICE
TO THE DEFENDANT(S) ALL UNKNOWN PERSONS WITH ANY RIGHT, TITLE OR INTEREST IN THE REAL ESTATE DESCRIBED HEREIN; ALSO ANY PERSONS WHO MAY BE IN THE MILITARY SERVICE OF THE UNITED STATES OF AMERICA, BEING A CLASS DESIGNATED AS JOHN DOE; AND ANY UNKNOWN MINORS OR PERSONS UNDER A DISABILITY BEING A CLASS DESIGNATED AS RICHARD ROE AND Ariel Gates:
YOU WILL PLEASE TAKE NOTICE that the Cover Sheet for Civil Actions, Certificate of Exemption/Withdrawal from Arbitration and Mediation, Summons and Notices, and Complaint, of which the foregoing is a copy of the Summons, were filed with the Clerk of Court for Richland County, South Carolina on January 11, 2006.
Pearce W. Fleming,
S.C. Bar No. 2038
D. Randolph Whitt,
S.C. Bar No. 13068
Martha T. Self,
S.C. Bar No. 73661
FLEMING & WHITT, P. A.
1301 Gervais Street, Suite 500
Post Office Box 12125
Columbia, SC 29211-2125
(803) 254-4751
Attorneys for Green Tree Servicing, LLC as successor in interest to Conseco Finance Servicing Corp.
NOTICE OF PENDENCY
OF ACTION
NOTICE IS HEREBY GIVEN THAT an action has been or will be commenced and is now or will be pending in this Court upon complaint of the above-named Plaintiff against the above-named Defendant(s) for the foreclosure of a certain mortgage of real estate given by Benjamin O. Gates to Conseco Finance Servicing Corp. dated November 26, 2001, and recorded in the public records of Richland County on September 5, 2002, in Book 700 at Page 1581.
The premises covered and affected by the Plaintiff's mortgage and the foreclosure thereof, were, at the time of the making thereof, and at the time of the filing of this notice, described as follows:
All that certain piece, parcel or lot of land, situate, lying and being in the County of Richland, State of South Carolina, and being shown and delineated on as Lot Twenty-six (26), Block "C", on a plat of Newcastle West Subdivision, made by Johnny T. Johnson & Associates, Inc., R.L.S., dated October 6, 1979, last revised January 11, 1980, and recorded in Office of the RMC for Richland County in Plat Book "Y" at Pages 6553 and 6553A, and said lot having the following boundaries and measurements, to wit: On the Northeast by lands undesignated on said plat, whereon it measures 75.01 feet; on the Southeast by Lot 25, Block "C", whereon it measures 129.62 feet; on the Southwest by Sunnydale Drive, whereon it fronts and measure 75.06 feet; and on the Northwest by Lot 27, Block "C", whereon it measures 129.63; be all measurements a little more or less.
Together with all and singular the rights, members, hereditaments and appurtenances to said premises belonging or in anywise incident or appertaining.
This being the same property conveyed to Benjamin O. Gates by deed of Joseph B. Giles and Sherah D. Giles dated November 26, 2001, and recorded September 5, 2002, in Deed Book 700 at Page 1579. Benjamin O. Gates, Jr. a/k/a Benjamin O. Gates a/k/a Benjamin Ollie Gates died on September 15, 2005, and his interest in the subject property passed to his heir-at-law or devisee, namely, Ariel Gates.
TMS #. 14207-07-15
Property Address:
215 Sunnydale Drive, Columbia, SC 29223-4649
Pearce W. Fleming,
S.C. Bar No. 2038
D. Randolph Whitt,
S.C. Bar No. 13068
Martha T. Self,
S.C. Bar No. 73661
FLEMING & WHITT, P. A.
1301 Gervais Street, Suite 500
Post Office Box 12125
Columbia, SC 29211-2125
(803) 254-4751
Attorneys for Green Tree Servicing, LLC as successor in interest to Conseco Finance Servicing Corp.
March 22, 2006
Columbia, South Carolina
SUMMONS AND NOTICES
STATE OF
SOUTH CAROLINA
COUNTY OF RICHLAND
IN THE COURT OF
COMMON PLEAS
2006-CP-40-1480
Deutsche Bank National Trust Company, as Trustee of Ameriquest Mortgage Securities Inc., Asset Backed Pass-Through Certificates, Series 2004-R4 under the Pooling and Servicing Agreement dated as of May 1, 2004, Without Recourse,
Plaintiff,
vs.
Butch Johnson also sometimes f/k/a Butch Johnson Richard; South Carolina Federal Credit Union,
Defendant(s).
( 784.060156)
TO THE DEFENDANT(S) Butch Johnson:
YOU ARE HEREBY SUMMONED and required to appear and defend by answering the Complaint in this action, of which a copy is herewith served upon you, and to serve a copy of your Answer on the subscribers at their offices, 1804 Bull Street, Post Office Box 12125, Columbia, SC 29211, within thirty (30) days after the service hereof, exclusive of the day of such service; except that the United States of America, if named, shall have sixty (60) days to answer after the service hereof, exclusive of the day of such service; and if you fail to do so, judgment by default will be rendered against you for the relief demanded in the complaint.
TO MINOR(S) OVER FOURTEEN YEARS OF AGE, AND/OR TO MINOR(S) UNDER FOURTEEN YEARS OF AGE AND THE PERSON WITH WHOM THE MINOR(S) RESIDES, AND/OR TO PERSONS UNDER SOME LEGAL DISABILITY:
YOU ARE FURTHER SUMMONED AND NOTIFIED to apply for the appointment of a guardian ad litem within thirty (30) days after the service of this Summons and Notice upon you. If you fail to do so, application for such appointment will be made by the Plaintiff.
YOU WILL ALSO TAKE NOTICE that under the provisions of South Carolina Code 29-3-100, effective June 16, 1993, any collateral assignment of rents contained in the attached mortgage is perfected and Plaintiff hereby gives notice that all rents shall be payable directly to it by delivery to its undersigned attorneys from the date of default. In the alternative, Plaintiff will move before a judge of this Circuit on the 10th day after service hereof, or as soon thereafter as counsel may be heard, for an Order enforcing the assignment of rents, if any, and compelling payment of all rents covered by such assignment directly to the Plaintiff, which motion is to be based upon the original note and mortgage and the Complaint attached hereto.
Pearce W. Fleming,
S.C. Bar No. 2038
D. Randolph Whitt,
S.C. Bar No. 13068
Martha T. Self,
S.C. Bar No. 73661
FLEMING & WHITT, P. A.
1301 Gervais Street, Suite 500
Post Office Box 12125
Columbia, SC 29211-2125
(803) 254-4751
Attorneys for Deutsche Bank National Trust Company, as Trustee of Ameriquest Mortgage Securities Inc., Asset Backed Pass-Through Certificates, Series 2004-R4 under the Pooling and Servicing Agreement dated as of May 1, 2004, Without Recourse
NOTICE
TO THE DEFENDANT(S) Butch Johnson:
YOU WILL PLEASE TAKE NOTICE that the Cover Sheet for Civil Actions, Certificate of Exemption/Withdrawal from Arbitration and Mediation, Summons and Notices, and Complaint, of which the foregoing is a copy of the Summons, were filed with the Clerk of Court for Richland County, South Carolina on March 15, 2006.
Pearce W. Fleming,
S.C. Bar No. 2038
D. Randolph Whitt,
S.C. Bar No. 13068
Martha T. Self,
S.C. Bar No. 73661
FLEMING & WHITT, P. A.
1301 Gervais Street, Suite 500
Post Office Box 12125
Columbia, SC 29211-2125
(803) 254-4751
Attorneys for Deutsche Bank National Trust Company, as Trustee of Ameriquest Mortgage Securities Inc., Asset Backed Pass-Through Certificates, Series 2004-R4 under the Pooling and Servicing Agreement dated as of May 1, 2004, Without Recourse
NOTICE OF PENDENCY
OF ACTION
NOTICE IS HEREBY GIVEN THAT an action has been or will be commenced and is now or will be pending in this Court upon complaint of the above-named Plaintiff against the above-named Defendant(s) for the foreclosure of a certain mortgage of real estate given by Butch Johnson to Ameriquest Mortgage Company dated March 24, 2004, and recorded in the public records of Richland County on April 9, 2004, in Book 922 at Page 1769. The Mortgage was thereafter assigned to the Plaintiff by assignment dated March 6, 2006 and recorded March 17, 2006 in Book 1163 at Page 244.
The premises covered and affected by the Plaintiff's mortgage and the foreclosure thereof, were, at the time of the making thereof, and at the time of the filing of this notice, described as follows:
All that certain piece, parcel or lot of land with any improvements thereon, situate in or near the Columbia, County of Richland, State of South Carolina, shown as Lot 1 Block AE on a plat of Wildwood Section 5 prepared by Enwright Surveying dated July 15, 1985 and recorded in the ROD Office in Plat Book 50 at page 4249 and upon a plat for Corey J. Miller by Cox and Dinkins Inc., dated May 15, 1996 to be recorded and having the measurements and boundaries as will be more fully shown thereon.
Source of Title: Book R0830 page 2046 (recorded 8-1-2003).
This being the same property conveyed to Butch Johnson Richard by deed of Carolina First Bank recorded on August 1, 2003 in the ROD Office for Richland County in Deed Book 830 at Page 2046. Thereafter a Corrective Deed was filed to correct the error in the name of the Deed previously filed, executed by Butch Johnson Richard, conveying property to Butch Johnson recorded March 11, 2004 in Book 911 at Page 2569.
TMS #. 22814-01-24
Property Address:
312 Oakbrook Drive,
Columbia, SC 29223
Pearce W. Fleming,
S.C. Bar No. 2038
D. Randolph Whitt,
S.C. Bar No. 13068
Martha T. Self,
S.C. Bar No. 73661
FLEMING & WHITT, P. A.
1301 Gervais Street, Suite 500
Post Office Box 12125
Columbia, SC 29211-2125
(803) 254-4751
Attorneys for Deutsche Bank National Trust Company, as Trustee of Ameriquest Mortgage Securities Inc., Asset Backed Pass-Through Certificates, Series 2004-R4 under the Pooling and Servicing Agreement dated as of May 1, 2004, Without Recourse
SUMMONS AND NOTICES
STATE OF
SOUTH CAROLINA
COUNTY OF RICHLAND
IN THE COURT OF
COMMON PLEAS
(NON-JURY MORTGAGE FORECLOSURE)
2006-CP-40-1040
U.S. Bank, National Association, as Trustee under the Pooling and Servicing Agreement dated as of October 1, 2002, among Credit-Based Asset Servicing and Securitization LLC, PPT ABS LLC, Litton Loan Servicing LP and U.S. Bank, National Association, PPT Asset-Backed Certificates, Series 2002-1, without recourse,PLAINTIFF,
vs.
Robert E. Vaughn a/k/a Robert Vaughn,
DEFENDANT(S).
TO THE DEFENDANTS ABOVE NAMED:
YOU ARE HEREBY SUMMONED and required to answer the Complaint herein, a copy of which is herewith served upon you, or to otherwise appear and defend, and to serve a copy of your Answer to said Complaint upon the subscribers at their office, 3955 Faber Place, Suite 200, P.O. Box 71727, North Charleston, South Carolina, 29415, or to otherwise appear and defend the action pursuant to applicable court rules, within thirty (30) days after service hereof, exclusive of the day of such service; except that the United States of America, if named, shall have sixty (60) days to answer after the service hereof, exclusive of such service; and if you fail to answer the Complaint or otherwise appear and defend within the time aforesaid, the Plaintiff in this action will apply to the Court for relief demanded therein, and judgment by default will be rendered against you for the relief demanded in the Complaint.
TO MINOR(S) OVER FOURTEEN YEARS OF AGE, AND/OR TO MINOR(S) UNDER FOURTEEN YEARS OF AGE AND THE PERSON WITH WHOM THE MINOR(S) RESIDE(S) AND/OR TO PERSONS UNDER SOME LEGAL DISABILITY:
YOU ARE FURTHER SUMMONED AND NOTIFIED to apply for the appointment of a guardian ad litem within thirty (30) days after the service of this Summons and Notice upon you. If you fail to do so, application for such appointment will be made by the Plaintiff.
YOU WILL ALSO TAKE NOTICE that pursuant to Rule 53(b) SCRCP, as amended effective September 1, 2002, the Plaintiff will move for a general Order of Reference to Joseph M. Strickland, the Master in Equity for Richland County, which Order shall, pursuant to Rule 53(b) of the South Carolina Rules of Civil Procedure, specifically provide that the said Master in Equity is authorized and empowered to enter a final judgment in this action. If there are counterclaims requiring a jury trial, any party may file a demand under rule 38, SCRCP and the case will be returned to the Circuit Court.
FINKEL & ALTMAN, L.L.C.
Post Office Box 71727
3955 Faber Place, Suite 200
North Charleston, South Carolina 29415
(843) 576-1072
BEVERLY J. FINKEL THOMAS A. SHOOK
ELIZABETH A. SHUFFLER BRIAN M. ANNINO
SUSAN S. WHITE
RICHARD G. DUERINSKX
NOTICE OF FILING
COMPLAINT
NOTICE IS HEREBY GIVEN that the original Complaint in the above entitled action, together with the Summons, was filed in the Office of the Clerk of Court for Richland County on February 21, 2006.
FINKEL & ALTMAN, L.L.C.
Post Office Box 71727
3955 Faber Place, Suite 200
North Charleston, South Carolina 29415
(843) 576-1072
BEVERLY J. FINKEL THOMAS A. SHOOK
ELIZABETH A. SHUFFLER BRIAN M. ANNINO
SUSAN S. WHITE
RICHARD G. DUERINSKX
LIS PENDENS
NOTICE IS HEREBY GIVEN that an action has been commenced and is now pending in this court upon Complaint of the above-named Plaintiff against the above-named Defendants for foreclosure of a certain mortgage of real estate given by Robert E. Vaughn to Conseco Finance Servicing Corp., in the amount of $62,000.00 dated January 2, 2002, and recorded in the Office of the Register of Deeds for Richland County in Book 612 at Page 1972 on January 10, 2002.
The premises covered and affected by the said mortgage as by the foreclosure thereof, were, at the time of the making thereof, and at the time of the filing of this Notice, described as follows:
All that certain piece, parcel or lot of land, with improvements thereon, lying, being and situate in the State of South Carolina, County of Richland the same being designated as 0.80 acres as shown on a plat prepared for Donnie Deneal, Jr., by William Wingfield dated June 23, 1967, and recorded in the Register of Deeds Office for Richland County in Plat Book 31 at page 386; being more particularly described on a plat prepared for Robert Vaughn and Joella Vaughn by Cox and Dinkins, Inc., dated November 5, 1999, and recorded in the Register of Deeds Office for Richland County in Record Book 362 at page 962; reference being made to said latter plat for a more complete description, all measurements being a little more or less.
Subject to easements and restrictions of record and otherwise affecting the property.
Together with all and singular the Rights, Members, Hereditaments and Appurtenances to the Premises belonging, or in anywise incident or appertaining.
TMS#: 16212-10-04
Property Address:
1716 Winfield Road,
Columbia, SC
FINKEL & ALTMAN, L.L.C.
Post Office Box 71727
3955 Faber Place, Suite 200
North Charleston, South Carolina 29415
(843) 576-1072
BEVERLY J. FINKEL THOMAS A. SHOOK
ELIZABETH A. SHUFFLER BRIAN M. ANNINO
SUSAN S. WHITE
RICHARD G. DUERINSKX
Charleston, South Carolina
ANSWER & CROSSCLAIM OF PATRICIA J. GALVIN
TO AMENDED COMPLAINT
STATE OF
SOUTH CAROLINA
COUNTY OF RICHLAND
IN THE COURT OF
COMMON PLEAS
FIFTH JUDICIAL CIRCUIT
05-CP-40-6858
HSBC Mortgage Services, Inc.,
Plaintiff(s),
vs.
Kurt F. Johnson, individually; D. Scott Heineman, individually, D. Scott Heineman as Trustee to the Galvin Family Trust; Kurt Johnson as Trustee to the Gatvin Family Trust; Patricia J. Galvin,
Defendants(s).
Defendant, Patrida J. Galvin, answering the Complaint of the Plaintiff herein, would respectfully show unto the Court as follows.
1. Each and every allegation of the Complaint not herein specifically admitted, qualified, or explained is denied.
FIRST DEFENSE
2. The allegations contained in the 1st paragraph of the Complaint do not require a response,
3. The allegations contained in the 2nd paragraph of the Complaint cannot be responded to due to lack of knowledge.
4. The allegations contained in the 3rd paragraph of the Complaint cannot be responded to due to lack of knowledge.
5. The allegations contained in the 4th paragraph of the Complaint are admitted.
6. The allegations contained in the 5th paragraph of the Complaint do not require a response.
7. The allegations contained in the 6th and 7th paragraphs of the Complaint are admitted to the extent they allege execution and delivery of a note and mortgage; as to the terms and conditions of same, Defendant craves reference to said instruments.
8. The allegations contained in the 8th paragraph of the Complaint are admitted in so far as they allege recording of said instruments; the remaining allegations of said paragraph are denied.
9. The allegations contained in the 9th paragraph of the Complaint are admitted in so far as they allege a lien on the property by vsrtre of the mortgage; the allegations as to the superiority of that lien to all others are denied, the remaining allegations of said paragraph are denied.
10. The allegations contained in the 10th paragraph of the Complaint are denied.
11. The allegations contained in the 11th paragraph of the Complaint are admitted in so far as they allege a conveyance of property; however, as set forth below, the legitimacy of the conveyance is disputed by Defendant Galvin; the remaining allegations of said paragraph are denied.
12. The allegations contained in the 12th paragraph of the Complaint are denied.
13. The allegations contained in the 13th paragraph of the Complaint do not require a response.
14. The allegations contained in the 14th paragraph of the Complaint cannot be responded to due to lack of knowledge.
15 The allegations contained in the 15th paragraph of the Complaint cannot be responded to due to lack of knowledge.
16. The allegations contained in the 16th paragraph of the Complaint do not require a response.
SECOND DEFENSE
17. The allegations contained hereinabove are repeated as if fully alleged herein verbatim, to the extent not inconsistent with the allegations of this defense.
18. The Defendants would show that necessary parties have not been joined in this matter as required by Rule 19, South Carolina Rules of Civil Procedure; this action should therefore be dismissed pursuant to Rule 12(b)(7) of the South Carolina Rules of Civil Procedure.
THIRD DEFENSE
19. The allegations contained hereinabove are repeated as if fully alleged herein verbatim, to the extent not inconsistent with the allegations of this defense.
20. Defendant would show that the Complaint is barred by the equitable doctrines of laches.
FOURTH DEFENSE
21. The allegations contained hereinabove are repeated as if fully alleged herein verbatim, to the extent not inconsistent with the allegations of this
defense.
22. Defendant would show that the rights of Plaintiff to enforce any Contract alleged to exist between the parties has been waived.
FIFTH DEFENSE
23. The allegations contained hereinabove are repeated as if fully alleged herein verbatim, to the extent not inconsistent with the allegations of this defense.
24. Defendant would show that the Complaint is barred by the equitable doctrine of unclean hands.
SIXTH DEFENSE BY WAY OF CROSS-CLAIM AGAINST THE GALVIN FAMILY TRUST. AND KURT F. JOHNSON & D. SCOTT HE1NEMAN (AS TRUSTEES TO THE GALVIN FAMILY TRUST ONLY)
(Cancellation of Fraudulent Deed and to Quiet Title)
25. Defendant Galvin (Galvin) would show that in or around early 2004, Kurt F. Johnson and/or D. Scott Heineman or their agents, representing themselves as "the Dorian Group" conducted a seminar at a hotel at which Galvin was employed.
26. Said individuals held themselves out to Galvin as estate planners, and falsely represented that it was in Galvin's best interests to create a living trust document to "protect her assets for the benefit of her heirs."
27. Based on the representations made in the seminar, Galvin paid said individuals the approximate sum of $3,000.00 to create a living trust for her and signed such documents as presented to her for execution; unbeknownst to Galvin, said Defendants were involved in a scheme to earn high fees and fraudulently gain control of her real property.
28 Upon information and belief, among the documents that Galvin executed was a quitclaim deed purporting to convey her real property to an entity known as "The Gaivin Family Trust," a legal entity over which Galvin in fact exercised little or no control, but which was controlied by its trustees, Kurt P. Johnson and/or D. Scott Heineman.
29. Galvin is informed and believes that, based on the foregoing wrongful and deceptive acts, she is entitled to a decree of this court voiding, invalidating, and/or setting aside the deed to the Galvin Family Trust, quieting her title to the parcel of land, adjudging that she is the owner of the parcel of land, and every part of it; and that Defendants Galvin Family Trust, and its trustees, Kurt F. Johnson and/or D. Scott Heineman have no estate, right, title, or interest whatever in or to the land or premises, or any part of it, and; that the alleged deed be ordered delivered up and canceled by this court.
Wherefore, Defendant Galvin prays that the Complaint of the Plaintiff be dismissed, with costs, and that the court grant her relief on her Cross-Claim as requested above.
TROTTER & MAXFIELD, ATTORNEYS
Dave Maxfield, Esquire
1701 Richland Street
Columbia, South Carolina
(803) 799-6000
Columbia, South Carolina
DATED: March 20, 2006
SUMMONS
STATE OF
SOUTH CAROLINA
COUNTY OF RICHLAND
IN THE COURT OF
COMMON PLEAS
2006-CP-40-1444
Cordell Bush,
Plaintiff,
vs.
Clorie Hodge Baker, Harry Baker, a/k/a Harry W. Baker, deceased, Constance R. Williams, William R.B. Williams, and any and all persons claiming any right, title, estate or interest in real estate described in the Complaint, any unknown adults being as a. class designated as John Doe, and any unknown infants or persons under disability being as a class designated as Richard Roe, and Richland County Treasurer,
Defendants.
TO THE DEFENDANT(S), CLORIE HODGE BAKER, CONSTANCE R. WILLIAMS, WILLIAM R.B. WILLIAMS AND JOHN DOE AND RICHARD ROE:
YOU ARE HEREBY SUMMONED and required to answer the Complaint in this action, and to serve a copy of your Answer on the subscribers at their offices, 1122 Lady Street, 5th Floor, Post Office Box 394, Columbia, South Carolina 29202, within thirty (30) days after service hereof, exclusive of the day of such service; except that theJJnifed States of America, if named, shall have sixty (60) days to answer after the service hereof, exclusive of the day of such service; and if you fail to answer the Complaint within the time aforesaid, the Plaintiff in this action will apply to the Court for a judgment by default granting the relief demanded in the Complaint.
NOTICE OF FILING
COMPLAINT
YOU WILL PLEASE TAKE NOTICE that the Summons and Complaint in the above-captioned action were filed on March 13, 2006, in the Office of the Cleik of Court for Richland County, South Carolina. Leonard R. Jordan Jr.
BERRY, QUACKENBUSH & STUART, P.A.
1122 Lady Stree, 5th Floor
Post Office Box 394
Columbia, SC 29202
Phone: (803)779-2650
Columbia, South Carolina
March 28, 2006
Attorneys for Plaintiff
LIS PENDENS
NOTICE IS HEREBY GIVEN that an action has been commenced and is now pending in this Court upon the Complaint of the above-named Plaintiff for an action to quiet title after tax sales. The premises covered and affected by the said action, were, at the time of making thereof and at the time of the filing of the Lis Pendens, as described on the attached Exhibit "A".
EXHIBIT "A"
All that certain parcel of land, with any improvements thereon, containing Four (4) acres, more or less, situate, lying and being on the southern side of Glenn Avenue at Ryan Street, in the City of Columbia, County of Richland, State of South Carolina, said parcel being bounded on the North by
property formerly of Wilds and measuring thereon three hundred twelve (312') feet, more or less; on the East by property now or formerly of Lyles and measuring thereon two hundred forty three (243') feet, more or less, the said eastern boundary line being the western line of Mildred Street, if extended in a northerly direction; on the South by Lots Nos. One (1) through Twenty-two (22) in Block 1 as shown on a plat of Clairview Terrace made by Buford Jackson, surveyor, dated January 30, 1947, recorded in the Office of the Register of Deeds for Richland County in Plat Book "L" at page 148, and measuring along the rear of said line 1550 feet, more or less; on the Northwest by Lots Nos. One (1) and Five (5) through Thirteen (13) in Block 14 as shown on a plat of property of Columbia Builders, Inc. made by Wingfield & Rudsill, Reg. Surveyors, dated February 20, 1950, recorded in the Office of the Register of Deeds for Richland County in Plat Book '"N" at page 164-5, and measuring along said lots 815' feet, more or less; on the West by Lot No. Thirteen (13) in Block 14 as shown on said last mentioned plat and measuring thereon 190' feet; and on the North by the right-of-way of Glenn Avenue and the northern side of the right-of-way of South Carolina Electric & Gas Company, and measuring thereon 100' feet; said parcel being subject, however, to the right- of-way of the S.C. Electric & Gas 100' feet wide along the northern edge of said parcel.
This being the same property conveyed to George Bush or Cordell Bush by Tax Deed dated May 30, 1989, and recorded :inthe Office of theRegister of Deeds for Richland County on June 6, 1989, in Deed Book D-938 at page 85. See also Quitclaim Deed to Cordell Bush fiom Reginald Bush and Jocynthia McCoy, dated January 30, 2006, and recorded in the Office of the Register of Deeds on March 7, 2006, in Book 1159 at page 2208. TMS#: 09207-09-13
NOTICE OF ORDER APPOINTING GUARDIAN AD L1TEM NISI AND NOTICE OF HAVE A GUARDIAN AD LITEM APPOINTED
PLEASE TAKE NOTICE THAT an action involving the above-described real property, in which you may have an interest, has been commenced in the Court of Common Pleas for Richland County, South Carolina and that, by Order of the Clerk of Court, S. R. Anderson has been appointed Guardian ad Litem Nisi for all unknown minors and persons under legal disability as a class designated as Richard Roe.
PLEASE TAKE NOTICE THAT, unless you or someone on your behalf apply to the Court for appointment of a suitable person to act as Guardian ad Litem herein, within thirty (30) days after service by publication of this Notice, the appointment of S.R. Anderson, as Guardian ad Litem shall be made absolute.
Leonard R. Jordan Jr.
BERRY, QUACKENBUSH & STUART, P.A.
1122 Lady Street, 5th Floor
Post Office Box 394
Columbia, SC 29202
