Public Notices

SUMMONS

AND NOTICES

STATE OF

SOUTH CAROLINA

COUNTY OF

RICHLAND

IN THE COURT OF

COMMON PLEAS

CASE NO.

2022-CP-40-00851 Wells Fargo Bank, N.A. successor by merger to Wells Fargo Bank Minnesota, N.A. as Trustee for Reperforming Loan REMIC Trust 2002-2, PLAINTIFF, VS. Christine DeLoach, individually, and as Heir or Devisee of the Estate of Denese A. Scott, Deceased; Jennifer Scott, individually, and as Heir or Devisee of the Estate of Denese A. Scott, Deceased; Charles Watson, Jr., individually, and as Heir or Devisee of the Estate of Denese A. Scott, Deceased; any Heirs-at- Law or Devisees of the Estate of Denese A. Scott, Deceased, their heirs or devisees, 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; any unknown minors or persons under a disability being a class designated as Richard Roe; The United States of America, acting by and through its agent, The Secretary of Housing and Urban Development (HUD); and Maywood Place Homeowners` Association, Inc., DEFENDANT(S). (220268.00009) TO ALL THE DEFENDANTS ABOVE-NAMED: 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, 2712 Middleburg Drive, Suite 200, Columbia, Post Office Box 2065, Columbia, South Carolina, 29202- 2065, 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. YOU WILL ALSO TAKE NOTICE that should you fail to Answer the foregoing Summons, the Plaintiff will move for a general Order of Reference of this cause to the Master-In- Equity or Special Referee for Richland County, which Order shall, pursuant to Rule 53 (e) of the South Carolina Rules of Civil Procedure, specifically provide that the said Master-In-Equity or Special Master is authorized and empowered to enter a final judgment in this cause. TO MINOR( S) OVER FOURTEEN YEARS OF AGE AND/OR 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, Plaintiff will apply to have the appointment of the Guardian ad Litem Nisi, Kelley Yarborough Woody, made absolute.

NOTICE TO THE ABOVE-NAMED DEFENDANTS: YOU WILL PLEASE TAKE NOTICE that the Summons 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 16, 2022. PLEASE TAKE NOTICE that the order appointing Kelley Yarborough Woody, whose address is PO Box 6432, Columbia, SC 29260, as Guardian Ad Litem Nisi for all persons whomsoever herein collectively designated as Richard Roe, defendants herein whose names and addresses are unknown, including any thereof who may be minors, incapacitated, or under other legal disability, whether residents or non-residents of South Carolina; for all named Defendants, addresses unknown, who may be infants, incapacitated, or under a legal disability; for any unknown heirs-at-law of Denese A. Scott, including their heirs, personal representatives, successors and assigns, and all other persons entitled to claim through them; and for all other unknown persons with any right, title, or interest in and to the real estate that is the subject of this foreclosure action, was filed in the Office of the Clerk of Court for Richland County on the 25th day of February, 2022. YOU WILL FURTHER TAKE NOTICE that unless the said Defendants, or someone in their behalf or in behalf of any of them, shall within thirty (30) days after service of notice of this order upon them by publication, exclusive of the day of such service, procure to be appointed for them, or any of them, a Guardian Ad Litem to represent them or any of them for the purposes of this action, the Plaintiff will apply for an order making the appointment of said Guardian Ad Litem Nisi absolute.

LIS PENDENS NOTICE IS HEREBY GIVEN that an action has been commenced by the Plaintiff above named against the Defendant(s) above named for the foreclosure of a certain mortgage given by Denese A. Scott to Mortgage Electronic Registration Systems, Inc., as nominee for NVR Mortgage Finance Inc., dated November 29, 2000, recorded November 30, 2000, in the office of the Clerk of Court/Register of Deeds for Richland County, in Book 462 at Page 2758; thereafter, said Mortgage was assigned to Wells Fargo Bank, N.A. successor by merger to Wells Fargo Bank Minnesota, N.A. as Trustee for Reperforming Loan REMIC Trust 2002-2 by assignment instrument dated August 2, 2021 and recorded August 9, 2021 in Book 2652 at Page 1258. The description of the premises is as follows: All that certain piece, parcel or lot of land, with the improvements thereon, situate, lying and being in the County of Richland, State of South Carolina, the same being designated as Lot No. 45 on a plat of Maywood Place Phase Two, by Belter & Associates, Inc., dated January 18, 1999, revised March 26, 1999, and recorded in the Office of the Register of Deeds for Richland County in Record Book 294 at Page 2359. Said lot being more particularly described and delineated on a plat prepared for Denese A. Scott by Baxter Land Surveying Co., Inc., dated November 27, 2000, to be recorded, and according to said latter plat having the following boundaries and measurements, to-wit: on the North by Lot 44 whereon it measures 135.31 feet; on the Southeast by Lot 26 whereon it measures 108.02 feet; on the Southwest by right-ofway of Dunoon Court (50` R/ W) whereon it fronts and measures 84.75 feet; on the West by the intersection of Dunoon Court (50` R/W) and May Oak Circle (50` R/W) whereon it measures 24.38 feet; and on the Northwest by right-of-way of May Oak Circle (50` R/W) whereon it measures 42.29 feet; be all measurements a little more or less. This being the same property conveyed to Denese A. Scott by Deed of Michael P. Nieri dated November 29, 2000 and recorded November 20, 2000 in Book 462 at Page 2755 in the Office of the Clerk of Court/Register of Deeds for Richland County, South Carolina. Subsequently, Denese A. Scott died intestate on or about 08/10/2020, leaving the subject property to his/her heirs, namely Christine DeLoach, Jennifer Scott, and Charles Watson, Jr., as shown in Probate Estate Matter Number 2020-ES-40-01628. TMS No. 23102-07-12 Property address: 1 Dunoon Court Columbia, SC 29229 SCOTT AND CORLEY, P.A. By: /s/Angelia J. Grant Ronald C. Scott (rons@scottandcorley.com) , SC Bar #4996 Reginald P. Corley (reggiec@scottandcorley.com), SC Bar #69453 Angelia J. Grant (angig@scottandcorley.co m), SC Bar #78334 Allison E. Heffernan (allisonh@scottandcorley.c om), SC Bar #68530 Matthew E. Rupert (matthewr@scottandcorley.com), SC Bar #100740 Louise M. Johnson (ceasiej@scottandcorley.co m), SC Bar #16586 H. Guyton Murrell (guytonm@scottandcorley.com) , SC Bar #64134 Kevin T. Brown (kevinb@scottandcorley.co m), SC Bar #64236 Jordan D. Beumer (jordanb@scottandcorley.com) , SC Bar #104074 ATTORNEYS FOR THE PLAINTIFF 2712 Middleburg Drive, Suite 200 Columbia, SC 29204 803-252-3340

SUMMONS

FOR DIVORCE

(One Year Continuous

Separation)

STATE OF

SOUTH CAROLINA

COUNTY OF

RICHLAND

IN THE FAMILY

COURT JUDICIAL

CIRCUIT

Docket No.

2021-DR-40-0818 MRS. ARRIANNA HUNT SAMUDIO Plaintiff, vs. MR. GLENN A. SAMUDIO Defendant. To the DEFENDANT Above-Named: Glenn A. Samudio 1920 Kennedy Rd., Irmo, SC 29063 YOU ARE HEREBY NOTIFIED that you have been sued by the Plaintiff for DIVORCE in the Court indicated above. You must respond in writing to the attached Complaint for Divorce and serve a copy of your Answer on the Plaintiff at the address below within thirty (30) days after the service of this Summons upon you, not counting the day of service, or thirty-five (35) days if you were served by certified mail, restricted delivery, return receipt requested. If you wish to retain an attorney to represent you in this matter, it is advisable to do this before submitting your Answer top the Plaintiff. If you do not answer the Complaint within the required thirty (30) days, the Court may grant a DIVORCE and grant the Plaintiff the relief requested in the Complaint. Arrianna Hunt Samudio Plaintiffs Signature 7201 Hunt Club Rd. Lot 27 Columbia, SC 29223 March 31, 2021 Richland, S.C.

SUMMONS AND

NOTICE OF

FILING OF

COMPLAINT AND

NOTICE OF

FORECLOSURE

INTERVENTION AND

CERTIFICATION OF

COMPLIANCE WITH

THE CORONAVIRUS

AID RELIEF AND

ECONOMIC

RECOVERY ACT

STATE OF

SOUTH CAROLINA

COUNTY OF

RICHLAND

IN THE COURT OF

COMMON PLEAS

(NON-JURY

MORTGAGE

FORECLOSURE) DEFICIENCY WAIVED

C/A#2022-CP-40-00864 The Bank of New York Mellon, f/k/a The Bank of New York as successor in interest to JPMorgan Chase Bank, N. A. as Indenture Trustee for NovaStar Mortgage Funding Trust, Series 2006-1, NovaStar Home Equity Loan Asset-Backed Certificates, Series 2006-1, PLAINTIFF, vs. Frances A Ghrigsby; Evelyn P Alexander Lannice M Ghrigsby, Sr and if Evelyn P Alexander and Lannice M Ghrigsby, Sr be deceased then any children and heirs at law to the Estates of Evelyn P Alexander and Lannice M Ghrigsby, Sr, distributees and devisees at law to the Estate of Evelyn P Alexander and Lannice M Ghrigsby, Sr , and if any of the same be dead any and all persons entitled to claim under or through them also all other persons unknown claiming any right, title, interest or lien upon the real estate described in the complaint herein; Any unknown adults, any unknown infants or persons under a disability being a class designated as John Doe, and any persons in the military service of the United States of America being a class designated as Richard Roe; Rebecca C Barnett; Lannice M Ghrigsby, Jr; Vernon L McGee; Christopher T McGee, 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 otherwise appear and defend, and to serve a copy of your Answer to said Complaint upon the subscriber at their office, Hutchens Law Firm LLP, P.O. Box 8237, Columbia, SC 29202, within thirty ( 30) days after service hereof, except as to the United States of America, which shall have sixty (60) days, 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. YOU WILL ALSO TAKE NOTICE that should you fail to Answer the foregoing Summons, the Plaintiff will move for an Order of Reference of this case to the Master-in-Equity/Special Referee for Richland County, which Order shall, pursuant to Rule 53 of the South Carolina Rules of Civil Procedure, specifically provide that the said Master-in-Equity/ Special Referee is authorized and empowered to enter a final judgment in this case with appeal only to the South Carolina Court of Appeals pursuant to Rule 203(d)(1) of the SCACR, effective June 1, 1999. 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 immediately and separately and such application will be deemed absolute and total in the absence of your application for such an appointment within thirty (30) days after the service of the Summons and Complaint upon you. YOU WILL ALSO TAKE NOTICE that should you fail to Answer the foregoing Summons, the Plaintiff will move for an Order of Reference of this case to the Master-in-Equity/Special Referee in/ for this County, which Order shall, pursuant to Rule 53 of the South Carolina Rules of Civil Procedure, specifically provide that the said Master-in-Equity/ Special Referee is authorized and empowered to enter a final judgment in this case with appeal only to the South Carolina Court of Appeals pursuant to Rule 203(d)(1) of the SCACR, effective June 1, 1999.

NOTICE OF FILING

OF SUMMONS AND

COMPLAINT TO THE DEFENDANTS ABOVE NAMED: YOU WILL PLEASE TAKE NOTICE that the foregoing Summons, along with the Complaint, was filed with the Clerk of Court for Richland County, South Carolina, on February 17, 2022.

NOTICE OF

FORECLOSURE

INTERVENTION PLEASE TAKE NOTICE THAT pursuant to the South Carolina Supreme Court Administrative Order 2011-05-02-01, you may have a right to Foreclosure Intervention. To be considered for any available Foreclosure Intervention, you may communicate with and otherwise deal with the Plaintiff through its law firm, Hutchens Law Firm LLP, P. O. Box 8237, Columbia, SC 29202 or call ( 803) 726- 2700. Hutchens Law Firm LLP represents the Plaintiff in this action and does not represent you. Under our ethical rules, we are prohibited from giving you any legal advice. You must submit any requests for Foreclosure Intervention consideration within 30 days from the date of this Notice. IF YOU FAIL, REFUSE, OR VOLUNTARILY ELECT NOT TO PARTICIPATE IN FORECLOSURE INTERVENTION, YOUR MORTGAGE COMPANY/ AGENT MAY PROCEED WITH A FORECLOSURE ACTION. If you have already pursued loss mitigation with the Plaintiff, this Notice does not guarantee the availability of loss mitigation options or further review of your qualifications.

CERTIFICATION OF

COMPLIANCE WITH

THE CORONAVIRUS

AID, RELIEF, AND

ECONOMIC

SECURITY ACT Mynameis:Gregory Wooten I am (check one) ( ) the Plaintiff or (X) an authorized agent of the Plaintiff in the foreclosure case described at the top of this page. I am capable of making this certification. The facts stated in the certification are within my personal knowledge and are true and correct.

1. Verification Pursuant to the South Carolina Supreme Court Administrative Orders 2020-04-30-02 and 2020- 05-06-01 and based upon the information provided by the Plaintiff and/or its authorized servicer as maintained in its case management/ database records, the undersigned makes the following certifications: Plaintiff is seeking to foreclose upon the following property commonly known as: 1133 Shirlington Road, Columbia, SC 29210 I verify that this property and specifically the mortgage loan subject to this action: (X) is NOT a “Federally Backed Mortgage Loan” as defined by § 4022(a)(2) of the federal Coronavirus Aid, Relief, and Economic Security (“CARES”) Act. ( ) is a “Federally Backed Mortgage Loan” as defined by § 4022(a)(2) of the federal Coronavirus Aid, Relief, and Economic Security (“CARES”) Act. Specifically, the foreclosure moratorium cited in Section 4022(c)(2) of the CARES Act has expired as of May 18, 2020, and the property and mortgage are not currently subject to a forbearance plan as solely defined in Sections 4022( b) and ( c) of the CARES Act. I hereby certify that I have reviewed the loan servicing records and case management/ data base records of the Plaintiff or its authorized mortgage servicer, in either digital or printed form, and that this mortgage loan is not currently subject to a forbearance plan as solely defined in Sections 4022( b) and ( c) of the CARES Act. Pursuant thereto, I certify that the facts stated in this Certification are within my personal knowledge, excepting those matters based upon my information and belief as to the said loan servicing records and case management/ data base records of the Plaintiff or mortgage servicer, and to those matters I believe them to be true. See, Rule 11(c), SCRCP; BB&T of South Carolina v. Fleming, 360 S. C. 341, 601 S.E.2d 540 (2004).

2. Declaration I certify that the foregoing statements made by me are true and correct. I am aware that if any of the foregoing statements made by me are willfully false, I am subject to punishment by contempt.

NOTICE OF

APPOINTMENT OF

ATTORNEY FOR

DEFENDANT(S) IN

MILITARY SERVICE TO UNKNOWN OR KNOWN DEFENDANTS THAT MAY BE IN THE MILITARY SERVICE OF THE UNITED STATES OF AMERICA ALL BEING A CLASS DESIGNATED AS RICHARD ROE: 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 this Summons and Notice upon you Plaintiff’s appointment will be made absolute with no further action from Plaintiff. THIS IS A COMMUNICATION FROM A DEBT COLLECTOR. THE PURPOSE OF THIS COMMUNICATION IS TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE, except as stated below in the instance of bankruptcy protection. IF YOU ARE UNDER THE PROTECTION OF THE BANKRUPTCY COURT OR HAVE BEEN DISCHARGED AS A RESULT OF A BANKRUPTCY PROCEEDING, THIS NOTICE IS GIVEN TO YOU PURSUANT TO STATUTORY REQUIREMENT AND FOR INFORMATIONAL PURPOSES AND IS NOT INTENDED AS AN ATTEMPT TO COLLECT A DEBT OR AS AN ACT TO COLLECT, ASSESS, OR RECOVER ALL OR ANY PORTION OF THE DEBT FROM YOU PERSONALLY. Hutchens Law Firm LLP

SUMMONS

STATE OF

SOUTH CAROLINA

COUNTY OF

RICHLAND

COURT OF

COMMON PLEAS

5TH JUDICIAL

CIRCUIT

CASE NO.:

2022-CP-40-0137 South Carolina Federal Credit Union, Plaintiff, vs. CHRISTOPHER OMAR LATHAM A/ K/ A CHRISTOPHER O. LATHAM A/ K/ A CHRISTOPHER LATHAM TO DEFENDANT ABOVE: Defendant., YOU ARE SUMMONED AND REQUIRED to answer the Complaint in the foregoing action, a copy of which is herewith served upon you, and to serve a copy of your said Answer on the undersigned attorney within thirty ( 30) days of the service hereof, exclusive of the date 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.

NOTICE OF FILING

Please take notice that the Summons and Complaint in the above action were filed in the Clerk of Court for Richland County, 1701 Main St. Columbia, SC on 01/10/22. KATHLEEN M. FERRI Attorney for Plaintiff PO Box 31776 Charleston, SC 29417 843-557-9775 kmferri@ferrilaw.net

XXXXXXX

SUMMONS AND

NOTICES

FORECLOSURE

(Non-Jury)

STATE OF

SOUTH CAROLINA

COUNTY OF

RICHLAND

IN THE COURT OF

COMMON PLEAS

C/A#.: 2022CP4000060 American Advisors Group, Plaintiff, vs. Wanda Akins, Jimmie C. Jones, Jr., Any Heirs-at- Law or Devisees of the Estate of Jimmie C. Jones, Sr., Deceased, his heirs or devisees, successors and assigns, and all other persons entitled to claim through him; 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 United States of America, acting by and through its agency, The Secretary of Housing and Urban Development, Defendant(s). 21-005651 TO THE DEFENDANT(S) ABOVE NAMED: Any Heirs-at-Law or Devisees of the Estate of Jimmie C. Jones, Sr., Deceased, his heirs or devisees, successors and assigns, and all other persons entitled to claim through him; 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 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 this subscribers at their offices at 1201 Main Street, Suite 1405, Columbia, SC 29201, 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 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 PERSON UNDER SOME LEGAL DISABILITY: YOU ARE FURTHER SUMMONED AND NOTIFIED to apply for the appointment of a guardian ad litem with thirty (30) days after the service of this Summons and Notice upon you. If you fail to do so, application for such appointment may be made by Attorney for Plaintiff. YOU WILL FURTHER TAKE NOTICE that under the provisions of S.C. Code Ann § 29-3-100, effective June 16, 1993, any collateral assignment of rents contained in the referenced Mortgage is perfected and Attorney for Plaintiff hereby gives notice that all rents shall be payable directly to it by delivery to its undersigned attorneys form 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 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.

NOTICE TO THE DEFENDANTS ABOVE NAMED: Any Heirs-at-Law or Devisees of the Estate of Jimmie C. Jones, Sr., Deceased, his heirs or devisees, successors and assigns, and all other persons entitled to claim through him; 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 YOU WILL PLEASE TAKE NOTICE that the Summons 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 6, 2022. /s/ Peter Kaufman Peter Kaufman, Esq. Attorney, SC Bar No.:100144 Albertelli Law 1201 Main St, Suite 1450 Columbia, SC 29201 Phone: (803) 828-0880 Date: 02/11/2022

SUMMONS

STATE OF

SOUTH CAROLINA

COUNTY OF

RICHLAND

IN THE COURT OF

COMMON PLEAS

2021-CP-40-04979 Tyrek Brown vs. Nigel McFarland and Damien House. TO THE ABOVE NAMED DEFENDANT NIGEL MCFARLAND: 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 to said Complaint on the subscriber at his office of the Goings Law Firm, LLC, 1510 Calhoun Street, Columbia, South Carolina 29201, 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. By Robert F. Goings, Goings Law Firm, LLC, 1510 Calhoun Street, Columbia, SC 29201 Phone: (803) 350- 9230 Fax: (877) 789-6340 Email: rgoings@goingslawfirm.co m Attorney for Plaintiff

NOTICE OF FILING TO: DEFENDANT NIGEL MCFARLAND. YOU WILL PLEASE TAKE NOTICE that the original Complaint in the above entitled action, together with the Summons, were filed in the Office of the Clerk of Court for Richland County, South Carolina, on October 5, 2021, at 11:12 a.m., the object and prayer of which is the recovery of a sum certain due to Plaintiff by Defendant and for such other and further relief as set forth in the Complaint. By Robert F. Goings, Goings Law Firm, LLC, 1510 Calhoun Street, Columbia, SC 29201 Phone: (803) 350-9230 Fax: ( 877) 789- 6340 Email: rgoings@goingslawfirm.co m Attorney for Plaintiff

SUMMONS AND

NOTICE

OF FILING OF

COMPLAINT

STATE OF

SOUTH CAROLINA

COUNTY OF

RICHLAND

IN THE COURT OF

COMMON PLEAS

CASE NO.

2022-CP-40-00552 FirstKey Master Funding 2021-A Collateral Trust, U.S. Bank Trust National Association as Collateral Trust Trustee, PLAINTIFF, VS. Jeff H. Graydon, DEFENDANT(S). (211091.00058) TO THE DEFENDANT(S) JEFF H. GRAYDON ABOVE NAMED: YOU ARE HEREBY SUMMONED and required to answer the Complaint in the above entitled action, copy of which is herewith served upon you, and to serve copy of your answer upon the undersigned at their offices, 2712 Middleburg Drive, Suite 200, P.O. Box 2065, Columbia, South Carolina 29202, 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, 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. YOU WILL ALSO TAKE NOTICE that should you fail to Answer the foregoing Summons, the Plaintiff will move for a general Order of Reference of this cause 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 said Master in Equity is authorized and empowered to enter a final judgment in this cause. TO MINOR( S) OVER FOURTEEN YEARS OF AGE AND/OR 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 to represent said minor(s) 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(s) herein. 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 February 2, 2022.

NOTICE OF MORTGAGOR’S RIGHT

TO FORECLOSURE

INTERVENTION TO THE ABOVE-NAMED MORTGAGOR(S) : PLEASE TAKE NOTICE THAT pursuant to the Supreme Court of South Carolina Administrative Order 2011-05-02-01, you may be eligible for foreclosure intervention programs for the purpose of resolving the above-referenced foreclosure action. If you wish to be considered for a foreclosure intervention program, you must contact Scott and Corley, P.A., 2712 Middleburg Drive, Suite 200, Columbia, South Carolina 29204 or call (803) 252- 3340 within thirty ( 30) days after being served with this notice. Scott and Corley, P.A. represents the Plaintiff in this action. We do not represent you. The South Carolina Rules of Professional Conduct prohibit our firm from giving you any legal advice. IF YOU FAIL, REFUSE, OR VOLUNTARILY ELECT NOT TO PARTICIPATE IN THIS FORECLOSURE INTERVENTION PROCESS, THE FORECLOSURE ACTION MAY PROCEED. NOTICE: THIS IS A COMMUNICATION FROM A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE, EXCEPT AS STATED BELOW IN THE INSTANCE OF BANKRUPTCY PROTECTION. IF YOU ARE UNDER THE PROTECTION OF THE BANKRUPTCY COURT OR HAVE BEEN DISCHARGED AS A RESULT OF A BANKRUPTCY PROCEEDING, THIS NOTICE IS GIVEN TO YOU PURSUANT TO STATUTORY REQUIREMENT AND FOR INFORMATIONAL PURPOSES AND IS NOT INTENDED AS AN ATTEMPT TO COLLECT A DEBT OR AS AN ACT TO COLLECT, ASSESS, OR RECOVER ALL OR ANY PORTION OF THE DEBT FROM YOU PERSONALLY. SCOTT AND CORLEY, P.A. By: /s/Angelia J. Grant Ronald C. Scott (rons@scottandcorley.com) , SC Bar #4996 Reginald P. Corley (reggiec@scottandcorley.com), SC Bar #69453 Angelia J. Grant (angig@scottandcorley.co m), SC Bar #78334 Allison E. Heffernan (allisonh@scottandcorley.c om), SC Bar #68530 Matthew E. Rupert (matthewr@scottandcorley.com), SC Bar #100740 Louise M. Johnson (ceasiej@scottandcorley.co m), SC Bar #16586 H. Guyton Murrell (guytonm@scottandcorley.com) , SC Bar #64134 Kevin T. Brown (kevinb@scottandcorley.co m), SC Bar #64236 Jordan D. Beumer (jordanb@scottandcorley.com) , SC Bar #104074 ATTORNEYS FOR THE PLAINTIFF 2712 Middleburg Drive, Suite 200 Columbia, SC 29204 803-252-3340

SUMMONS AND

NOTICE OF FILING

OF COMPLAINT

(Non-Jury)

Foreclosure

STATE OF

SOUTH CAROLINA

COUNTY OF

RICHLAND

IN THE COURT OF

COMMON PLEAS

FIFTH JUDICIAL

CIRCUIT

C/A#:2022-CP-40-00126 SOUTH CAROLINA STATE HOUSING FINANCE AND DEVELOPMENT AUTHORITY, Plaintiff, vs. CALVIN T. COOK, Defendant. TO THE DEFENDANT ABOVE NAMED: YOU ARE HEREBY SUMMONED and required to answer the Complaint in this action, a copy of which is herewith served upon you, and to serve a copy of your answer to the said Complaint upon the subscribers, at their office, 508 Meeting Street, West Columbia, 29169 Post Office Box 11682, Columbia, South Carolina 29211, within thirty ( 30) days after the service hereof, exclusive of the day of such service; and if you fail to answer the Complaint in the time aforesaid, 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 January 10, 2022. s/Ryan J. Patane S.C. Bar No. 103116 Benjamin E. Grimsley S.C. Bar No. 70335 D’Alberto, Graham & Grimsley, LLC Attorneys for the Plaintiff P.O. Box 11682 Columbia, S.C. 29211 (803) 233-1177 rpatane@dgglegal.com bgrimsley@dgglegal.com February 21, 2022

SUMMONS AND

NOTICE FOR

PUBLICATION

STATE OF

SOUTH CAROLINA

COUNTY OF

RICHLAND

IN THE FAMILY

COURT FIFTH JUDICIAL

CIRCUIT

Case#2021-DR-40-3845 South Carolina Department of Social Services, Plaintiff, vs. Ashley Tucker Nuttry Marcus Nuttry Defendants. IN THE INTERESTS OF: Child 1 DOB: 11/1/07 Child2 DOB: 10/19/09 Child3 DOB: 10/25/10 Minors Under the Age of 18. TO DEFENDANTS: Ashley Tucker Nuttry YOU ARE HEREBY SUMMONED and required to answer the complaint for tennination of your parental rights in and to the minor child in this action, the original of which has been filed in the Office of the Clerk of Court for RICHLAND County, on the 10th day of December, 2021 a copy of which will be delivered to you upon request; and to serve a copy of your answer to the Complaint upon the undersigned attorney for the plaintiff at 2638 Two Notch Road Ste. 200, Columbia, SC 29204, within thirty (30) days following the date of service upon you, exclusive of the day of such service; and if you fail to answer the complaint within the time stated, the plaintiff will apply for judgment by default against the defendant for the relief demanded in the complaint. S. C. DEPARTMENT OF SOCIAL SERVICES Kathryn Walsh, SC Bar# 7002 Attorney for Plaintiff South Carolina Department of Social Services 630 Chesnee Hwy Spartanburg, SC 29303 (803)280-0383 Kathryn.walsh@dss.sc.gov February 4, 2022 Spartanburg, South Carolina

SUMMONS AND

NOTICE FOR

PUBLICATION

STATE OF

SOUTH CAROLINA

COUNTY OF

RICHLAND

IN THE FAMILY

COURT FIFTH JUDICIAL

CIRCUIT

Case#2021-DR-40-3863 South Carolina Department of Social Services, Plaintiff, vs. Kamesha Anderson Coalie Garvin Defendants. IN THE INTERESTS OF: Child 1 DOB: 3/19/2018 Minors Under the Age of 18. TO DEFENDANTS: Kamesha Anderson YOU ARE HEREBY SUMMONED and required to answer the complaint for termination of your parental rights in and to the minor child in this action, the original of which has been filed in the Office of the Clerk of Court for RICHLAND County, on the 21st day of December, 2021 a copy of which will be delivered to you upon request; and to serve a copy of your answer to the Complaint upon the undersigned attorney for the plaintiff at 2638 Two Notch Road Ste. 200, Columbia, SC 29204, within thirty (30) days following the date of service upon you, exclusive of the day of such service; and if you fail to answer the complaint within the time stated, the plaintiff will apply for judgment by default against the defendant for the relief demanded in the complaint. S. C. DEPARTMENT OF SOCIAL SERVICES Kathryn Walsh, SC Bar# 7002 Attorney for Plaintiff South Carolina Department of Social Services 630 Chesnee Hwy Spartanburg, SC 29303 February 16, 2022 Spartanburg, South Carolina 6x

NOTICE OF SALE

Docket No.

2018-CP-40-03098 By virtue of a decree pronouncing the half interest in property described below escheated to the State, heretofore granted in the case of Valdina Hall against the unknown heirs of James Williams and all persons unknown claiming any right, title, estate, interest in or lien upon the half interest in real estate located at 4860 Leesburg Road, Hopkins, the South Carolina Secretary of State will sell on Friday, April 15, 2022 to the highest bidder: All that certain piece, parcel or lot of land, situate, lying and being in Richland County, South Carolina, and being conveyed via quitclaim deed in Richland County, South Carolina. shown and designated recorded in Plat Book 591, Page 439, ROD Office for Richland County, South Carolina. For a more particular description, reference is hereby made to the abovereferred to plat and record thereof. This is the same property conveyed to Lintena Eddy by deed of Valdina Hall, dated February 1, 1996, and, recorded February 1, 1996, in Deed Book 1300, Page 187, ROD Office for Richland County, South Carolina. For a more particular description, reference is hereby made to the above-referred plat and record thereof. TMS No. 31000-02-27 CURRENT ADDRESS OF PROPERTY IS: 4860 Leesburg Road Hopkins, South Carolina 29061 SUBJECT TO ASSESSMENTS, RICHLAND COUNTY TAXES, EXISTING EASEMENTS, EASEMENTS AND RESTRICTIONS OF RECORD, AND OTHER SENIOR ENCUMBRANCES, IF ANY. Purchaser to pay for preparation of the deed, documentary stamps on the deed, and recording of the deed. All interested buyers should inquire with La’- Jessica Stringfellow, attorney for South Carolina Secretary of State via email: lstringfellow@robin- songray.com. 6x

XXXXXXX

SUMMONS AND

NOTICE OF

FILING OF

COMPLAINT

STATE OF

SOUTH CAROLINA

(Non-Jury)

Foreclosure

COUNTY OF

RICHLAND

IN THE COURT OF

COMMON PLEAS

FIFTH JUDICIAL

CIRCUIT

C/A#:2022-CP-40-00131 SOUTH CAROLINA STATE HOUSING FINANCE AND DEVELOPMENT AUTHORITY,

Plaintiff, vs. SHANNON R. CAPUANO, WILLIAM CAPUANO and MIDLAND CREDIT MANAGEMENT, INC., Defendants. TO THE DEFENDANTS SHANNON R. CAPUANO AND WILLIAM CAPUANO ABOVE NAMED: YOU ARE HEREBY SUMMONED and required to answer the Complaint in this action, a copy of which is herewith served upon you, and to serve a copy of your answer to the said Complaint upon the subscribers, at their office, 508 Meeting Street, West Columbia, 29169, Post Office Box 11682, Columbia, South Carolina 29211, within thirty ( 30) days after the service hereof, exclusive of the day of such service; and if you fail to answer the Complaint in the time aforesaid, 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 January 10, 2022. s/Ryan J. Patane S.C. Bar No. 103116 Benjamin E. Grimsley S.C. Bar No. 70335 D’Alberto, Graham & Grimsley, LLC Attorneys for the Plaintiff P.O. Box 11682 Columbia, S.C. 29211 (803) 233-1177 rpatane@dgglegal.com bgrimsley@dgglegal.com February 15, 2022

SUMMONS

(JURY TRIAL

DEMANDED)

STATE OF

SOUTH CAROLINA

COUNTY OF

RICHLAND

IN THE COURT OF

COMMON PLEAS

DOCKET NO.:

2021-CP-40-06277 KELLY WILSON Plaintiff, vs. PEREZ GRISELDA OSORIO Defendant. TO: THE DEFENDANT 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 to the said Complaint on the subscribers at his office, 1722 Main Street, Suite 302 Columbia, South Carolina, 29201 within thirty ( 30) days after the service thereof, exclusive of the date of such service and if you fail to answer, appear, or defend, judgment by default will be rendered against you for the relief demanded in the Complaint. s/Jerry Reardon JERRY REARDON SC Bar #13739 Attorney for Plaintiff Law Office of Jerry Reardon Columbia, South Carolina December 29, 2021

NOTICE FOR

PUBLICATION

RE: KELLY WILSON

-vs- PEREZ GRISELDA

OSORIO

DOCKET NO.:

2021-CP-40-06277 TO: DEFENDANT PEREZ GRISELDA OSORIO YOU WILL PLEASE TAKE NOTICE that the original Summons and Complaint in the aboveentitled action was filed in the Richland County Commons Pleas Court on the 29th day of December 2021, the object and prayer of which is to obtain a monetary judgment against you and other relief as set forth in the Complaint. S/JERRY REARDON JERRY REARDON Attorney for the Plaintiff LAW OFFICE OF JERRY REARDON, LLC 1722 Main Street, Suite 302, Columbia, South Carolina 29201 (803) 602-5242 Columbia, South Carolina February 17, 2022

SUMMONS AND

NOTICE

OF FILING OF

COMPLAINT

STATE OF

SOUTH CAROLINA

COUNTY OF

RICHLAND

IN THE COURT OF

COMMON PLEAS

CASE NO.

2022-CP-40-00352 Lakeview Loan Servicing, LLC, PLAINTIFF, VS. Kakeena Lynndora Burch a/ k/ a Kakeena Austin a/ k/ a Kakeena Agness; Carl Erskine Burch, Jr. a/k/a Carl Erskine Burch; Mortgage Electronic Registration Systems, Inc. as nominee for Open Mortgage, LLC; The Summit Community Homeowners Association Inc., DEFENDANT(S). (220855.00004) TO THE DEFENDANT(S) KAKEENA LYNNDORA BURCH A/ K/ A KAKEENA AUSTIN A/ K/ A KAKEENA AGNESS; AND CARL ERSKINE BURCH, JR. A/ K/ A CARL ERSKINE BURCH ABOVE NAMED: YOU ARE HEREBY SUMMONED and required to answer the Complaint in the above entitled action, copy of which is herewith served upon you, and to serve copy of your answer upon the undersigned at their offices, 2712 Middleburg Drive, Suite 200, P.O. Box 2065, Columbia, South Carolina 29202, 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, 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. YOU WILL ALSO TAKE NOTICE that should you fail to Answer the foregoing Summons, the Plaintiff will move for a general Order of Reference of this cause 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 said Master in Equity is authorized and empowered to enter a final judgment in this cause. TO MINOR( S) OVER FOURTEEN YEARS OF AGE AND/OR 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 to represent said minor(s) 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(s) herein. 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 January 20, 2022.

NOTICE OF MORTGAGOR’S RIGHT

TO FORECLOSURE

INTERVENTION TO THE ABOVE-NAMED MORTGAGOR(S) : PLEASE TAKE NOTICE THAT pursuant to the Supreme Court of South Carolina Administrative Order 2011-05-02-01, you may be eligible for foreclosure intervention programs for the purpose of resolving the above-referenced foreclosure action. If you wish to be considered for a foreclosure intervention program, you must contact Scott and Corley, P.A., 2712 Middleburg Drive, Suite 200, Columbia, South Carolina 29204 or call (803) 252- 3340 within thirty ( 30) days after being served with this notice. Scott and Corley, P.A. represents the Plaintiff in this action. We do not represent you. The South Carolina Rules of Professional Conduct prohibit our firm from giving you any legal advice. IF YOU FAIL, REFUSE, OR VOLUNTARILY ELECT NOT TO PARTICIPATE IN THIS FORECLOSURE INTERVENTION PROCESS, THE FORECLOSURE ACTION MAY PROCEED. NOTICE: THIS IS A COMMUNICATION FROM A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE, EXCEPT AS STATED BELOW IN THE INSTANCE OF BANKRUPTCY PROTECTION. IF YOU ARE UNDER THE PROTECTION OF THE BANKRUPTCY COURT OR HAVE BEEN DISCHARGED AS A RESULT OF A BANKRUPTCY PROCEEDING, THIS NOTICE IS GIVEN TO YOU PURSUANT TO STATUTORY REQUIREMENT AND FOR INFORMATIONAL PURPOSES AND IS NOT INTENDED AS AN ATTEMPT TO COLLECT A DEBT OR AS AN ACT TO COLLECT, ASSESS, OR RECOVER ALL OR ANY PORTION OF THE DEBT FROM YOU PERSONALLY. SCOTT AND CORLEY, P.A. By: /s/Kevin T. Brown Ronald C. Scott (rons@scottandcorley.com) , SC Bar #4996 Reginald P. Corley (reggiec@scottandcorley.com), SC Bar #69453 Angelia J. Grant (angig@scottandcorley.co m), SC Bar #78334 Allison E. Heffernan (allisonh@scottandcorley.c om), SC Bar #68530 Matthew E. Rupert (matthewr@scottandcorley.com), SC Bar #100740 Louise M. Johnson (ceasiej@scottandcorley.co m), SC Bar #16586 H. Guyton Murrell (guytonm@scottandcorley.com) , SC Bar #64134 Kevin T. Brown (kevinb@scottandcorley.co m), SC Bar #64236 Jordan D. Beumer (jordanb@scottandcorley.com) , SC Bar #104074 ATTORNEYS FOR THE PLAINTIFF 2712 Middleburg Drive, Suite 200 Columbia, SC 29204 803-252-3340

SUMMONS

(Non-Jury)

(Mortgage Foreclosure)

(Deficiency Waived)

STATE OF

SOUTH CAROLINA

COUNTY OF

RICHLAND

IN THE COURT OF

COMMON PLEAS

CASE NO.:

2022-CP-40-00370 Ann Thi Le, Plaintiff, vs. Her Highness Q.R. Wells and Southern Touch Property Management LLC, Defendants. TO THE DEFENDANT, HER HIGHNESS Q. R. WELLS: YOU ARE HEREBY SUMMONED and required to answer the Complaint in this action, a copy of which is herewith served upon you, and to serve a copy of your Answer on the subscribers at their offices, 211 Veterans Road, Suite D, Columbia, South Carolina 29209, within thirty ( 30) days after service hereof, exclusive of the day of such service; and if you fail to answer the Complaint within the time aforesaid, the Plaintiff 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 January 21, 2022, in the Office of the Clerk of Court for Richland County, South Carolina.

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 to foreclose the Mortgage from Her Highness Q.R. Wells to Ann Thi Le, dated February 16, 2016, and recorded in the Office of the Register of Deeds for Richland County on February 17, 2016 in Book 2089 at page 1603. The premises covered and affected by the said Mortgage, was, at the time of making thereof and described as 3528 Kay Street, Columbia, SC 29210, and is more completely described as set forth on the attached Exhibit “A.” EXHIBIT “A” All that certain piece, parcel or lot of land, with the improvements thereon, situate, lying and being on the northeastern side of Kay Street, near the City of Columbia, in the County of Richland, State of South Carolina, being shown and designated as Lot No. 3 in Tract 35, on a plat of Subdivision of Tract No. 35, Property of C.V. Hendrix, prepared by Tomlinson Engr. Co., dated July 30, 1947 and recorded in Plat Book 11 at page 39 in the Office of the Register of Deeds for Richland County, and being bounded and measuring as follows: On the Northwest by Lot 2, measuring thereon 160 feet; on the Northeast by Tract 34, measuring thereon 110 feet; on the Southeast by Lot No. 4, measuring thereon 160 feet; and on the Southwest by Kay Street, measuring thereon 110 feet; reference being made to said plat which is incorporated herein for a more complete and accurate description of the boundaries, measurements, courses and distances; all measurements being a little more or less. This being the same property conveyed to Her Highness Q.R. Wells by Deed of Ann Thi Le, dated February 16, 2016, and recorded on February 17, 2016, in the Office of the Register of Deeds for Richland County in Book 2089 at page 1599. TMS # 06105-03-16 Property Address: 3528 Kay Street,

Columbia, SC 29210 Leonard R. Jordan, Jr. JORDAN LAW FIRM 211 Veterans Road, Suite D, Columbia, South Carolina 29209 (803) 726-1950 Tel (803) 726-1951 Fax ljordan@ljordanlaw.com Attorney for Plaintiff Columbia, South Carolina February 17, 2022

SUMMONS

STATE OF

SOUTH CAROLINA

COUNTY OF

RICHLAND

IN THE COURT OF

COMMON PLEAS

C/A#.:2021-CP-40-05112 Progressive Direct Insurance Company and Progressive Universal Insurance Company, Plaintiffs, vs. Shajuana Maxwell, Elijah Curtis, and Serious Rice, 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 this Complaint on the subscriber, at the address shown below, within thirty ( 30) days after the service thereof, exclusive of this day of such service, and if you fail to answer the Complaint, judgment by default will be rendered against you for the relief demanded in said Complaint. MURPHY & GRANTLAND, P.A. s/Susan O. Porter Susan O. Porter, Esquire, Bar #68335 Murphy & Grantland, P.A. P.O. Box 6648 Columbia, South Carolina 29260 (803) 782-4100 Attorneys for Plaintiff Columbia, South Carolina October 12, 2021

DECLARATORY

JUDGMENT

COMPLAINT (Jury Trial Demanded) Progressive Direct Insurance Company and Progressive Universal Insurance Company, Plaintiffs, vs. Shajuana Maxwell, Elijah Curtis, and Serious Rice, Defendants. Plaintiffs, Progressive Direct Insurance Company and Progressive Universal Insurance Company, (hereinafter, collectively, “Progressive”) seeks declaratory relief to determine the rights of the parties, and alleges and shows as follows:

JURISDICTION

& VENUE

1. Progressive is an insurance company organized and existing under the laws of the State of Ohio with its principal place of business in the State of Ohio. Progressive is licensed and authorized to issue policies of automobile liability insurance in the State of South Carolina.

2. Upon information and belief, Defendant Shajuana Maxwell is a citizen and resident of the County of Richland, State of South Carolina.

3. Upon information and belief, Defendant Elijah Curtis is a citizen and resident of the County of Richland, State of South Carolina.

4. Upon information and belief, Defendant Serious Rice is a citizen and resident of the County of Richland, State of South Carolina.

5. This action is brought under the South Carolina Declaratory Judgment Act, South Carolina Code Ann. §§15-53-10, et seq.

6. An actual and justiciable controversy exists between the parties, and by these proceedings Plaintiffs ask this Court to inquire into and declare the rights and obligations of the parties hereto arising out of the facts set forth below. Jurisdiction and venue are proper in this court.

FACTUAL

ALLEGATIONS

I. The Rice Policy

7. Progressive Direct Insurance Company issued a policy of personal automobile insurance to Serious Rice, policy number 926666867, with effective dates of January 8, 2019 to July 8, 2019 (hereinafter the “Rice Policy”).

8. The Rice Policy provides bodily injury liability limits of $25,000 per person and $50,000 per accident, and property damage liability limits of $25,000. A copy of the policy is attached hereto as “Exhibit A.”

9. The Rice Policy lists a 2004 Dodge Intrepid as an insured automobile.

10. Progressive Direct Insurance Company insured Rice for liability arising out of certain risks under the insuring agreement and excluded certain risks through the policy exclusions. Progressive craves reference to the Rice Policy for all of the terms, conditions, and provisions therein and incorporates them by reference herein.

11. The Rice Policy also includes a duty to defend Serious Rice in any civil suit for injuries that are otherwise covered under the policy.

12. The Rice Policy provides in pertinent part:

INSURING

AGREEMENT In return for your payment of the premium, we agree to insure you subject to all the terms, conditions and limitations of this policy. * * *

GENERAL

DEFINITIONS

17. “ You” and “ your” mean: a. A person shown as a named insured on the declarations page; and b. the spouse of a named insured if residing in the same household at the time of the loss. * * *

PART I — LIABILITY

TO OTHERS

INSURING

AGREEMENT If you pay the premium for this coverage, we will pay damages for bodily injury and property damage for which an insured person becomes legally responsible because of an accident. *** We will settle or defend, at our option, any claim for damages covered by this Part I.

ADDITIONAL

DEFINITION When used in this Part I: “Insured person” means: a. you, a relative, or a rated resident with respect to an accident arising out of the ownership, maintenance or use of an auto or a trailer; b. any person with respect to an accident arising out of that person’s use of a covered auto with the permission of you, a relative, or a rated resident; * * * EXCLUSIONS— READ THE FOLLOWING EXCLUSIONS CAREFULLY. IF AN EXCLUSION APPLIES, COVERAGE WILL NOT BE AFFORDED UNDER THIS PART I. Coverage under this Part I, including our duty to defend, will not apply to any insured person for: * * *

9. bodily injury or property damage caused by an intentional act of that insured person, or at the direction of that insured person, even if the actual injury or damage is different than that which was intended or expected. * * *

15. bodily injury or property damage caused by, or reasonably expected to result from, a criminal act or omission of that insured person. This exclusion applies regardless of whether that insured person is actually charged with, or convicted of, a crime. * * *

PART VI—DUTIES

IN CASE OF AN

ACCIDENT OR LOSS For coverage to apply under this policy, you or the person seeking coverage must promptly report each accident or loss even if you or the person seeking coverage is not at fault. You or the person seeking coverage must provide us with all accident or loss information, including time, place, and how the accident or loss happened. You or the person seeking coverage must also obtain and provide us the names and addresses of all persons involved in the accident or loss, the names and addresses of any witnesses, and the license plate numbers of the vehicles involved. * * * A person seeking any coverage must:

1. cooperate with us in any matter concerning a claim or lawsuit; provide any written proof of loss we may reasonably require; ***

3. allow us to take signed and recorded statements, including sworn statements and examinations under oath, which we may conduct outside the presence of you or any other person seeking coverage, and answer all reasonable questions we may ask as often as we may reasonably require;

4. promptly call to notify us about any claim or lawsuit and send us any and all legal papers relating to the claim or suit;

5. attend hearings and trials as we require; ***

7. allow us to have the damages covered auto, or any other damaged vehicle for which coverage is sought, from further loss. inspected and appraised before its repair or disposal; * * *

Part VII — GENERAL

PROVISIONS * * *

FRAUD OR

MISREPRESENTATION * * * We may deny coverage for an accident or loss if you or a person seeking coverage has concealed or misrepresented any material fact or circumstance, or engaged in fraudulent conduct, in connection with the presentation or settlement of a claim. However, this shall not affect coverage under Part I—Liability To Others up to the minimum limit mandated by the motor vehicle financial responsibility law of South Carolina, for any injured person who has not knowingly concealed or misrepresented any material fact or circumstance. * * *

II. The Williams Policy

13. Progressive Universal Insurance Company issued a policy of personal automobile insurance to Shontell Williams and Sondtell A. Williams, policy number 12028262, with effective dates of November 18, 2018 to May 28, 2019 ( hereinafter the “Williams Policy”).

14. The Williams Policy provides bodily injury liability limits of $50,000 per person and $100,000 per accident, and property damage liability limits of $50,000. The Williams Policy also provides uninsured motorist (“UM”) limits of $100,000 per person and $300,000 per accident. A copy of the Williams Policy is attached hereto as “Exhibit B.”

15. The Williams Policy a 2003 Infiniti G35, a 2008 Chrysler Town & Country, and a 2014 Ford Focus as insured vehicles.

16. Progressive Universal Insurance Company provides UIM coverage under the Williams Policy for uninsured motorist liability arising out of certain risks under the insuring agreement and excluded certain risks through the policy exclusions. Progressive craves reference to the policy for all of the terms, conditions, and provisions therein and incorporates them by reference herein.

17. The Williams Policy provides in pertinent part:

WISCONSIN AUTO

POLICY INSURING

AGREEMENT In return for your payment of the premium, we agree to insure you subject to all the terms, conditions and limitations of this policy. * * *

GENERAL

DEFINITIONS

17. “ You” and “ your” mean: a. a person shown as a named insured on the declarations page; and b. the spouse of a named insured if residing in the same household at the time of the loss. * * *

PART III—

UNINSURED/

UNDERINSURED

MOTORIST

COVERAGE

INSURING

AGREEMENT—

UNINSURED

MOTORIST COVERAGE If you pay the premium for this coverage, we will pay damages that an insured person is legally entitled to recover from the owner or operator of an uninsured motor vehicle because of bodily injury:

1. sustained by an insured person;

2. caused by an accident; and

3. arising out of the ownership, maintenance or use of an uninsured moto vehicle. * * *

ADDITIONAL

DEFINITIONS When used in this Part III:

1. “ Insured person” means: a. you, a relative, or a rated resident; b. any person while operating a covered auto with the permission of you, a relative, or a rated resident; * * *

4. “ Uninsured motor vehicle” means a land motor vehicle or trailer of any type: a. to which no bodily injury liability bond or policy applies at the time of the accident and the owner or operator has not furnished proof of financial responsibility for the future; b. to which a bodily injury liability or policy applies at the time of the accident but the bonding or insuring company:

(i) denies coverage; or

(ii) is or becomes insolvent; * * *

PART VI—DUTIES

IN CASE OF AN

ACCIDENT OR LOSS For coverage to apply under this policy, you or the person seeking coverage must promptly report each accident or loss even if you or the person seeking coverage is not at fault. You or the person seeking coverage must provide us with all accident or loss information, including time, place, and how the accident or loss happened. You or the person seeking coverage must also obtain and provide us the names and addresses of all persons involved in the accident or loss, the names and addresses of any witnesses, and the license plate numbers of the vehicles involved. * * * A person seeking any coverage must:

1. cooperate with us in any matter concerning a claim or lawsuit;

2. provide any written proof of loss we may reasonably require;

3. allow us to take signed and recorded statements, including sworn statements and examinations under oath, which we may conduct outside the presence of you or any other person seeking coverage, and answer all reasonable questions we may ask as often as we may reasonably require;

4. promptly call to notify us about any claim or lawsuit and send us any and all legal papers relating to the claim or suit;

5. attend hearings and trials as we require; * * *

PART VII—GENERAL

PROVISIONS * * *

FRAUD OR

MISREPRESENTATION * * * We may deny coverage for an accident or loss if you or a person seeking coverage has concealed or misrepresented any material fact or circumstance, or engaged in fraudulent conduct, in connection with the presentation or settlement of a claim. * * *

18. The Williams Policy was issued in Wisconsin. Therefore, it must be interpreted under Wisconsin law.

III. The Underlying Incident

19. On February 12, 2021, Defendant Shajuana Maxwell filed suit in the Richland County Court of Common Pleas, captioned Shajuana Maxwell v. Serious Rice, with civil action number 2021-CP-40-0671 ( herein “ Maxwell Complaint”).

20. On April 1, 2021, the South Carolina Department of Insurance accepted service of the Summons and Complaint on behalf of Progressive, effectively placing Defendant Maxwell’s Uninsured Motorist Vehicle Carrier on notice of her claims for bodily injury.

21. The Maxwell Complaint alleges that on January 20, 2019, Maxwell was driving and operating a 2003 Infiniti automobile eastbound on Broad River Road in Richland County and Defendant Rice was driving and operating a 2004 Dodge automobile, proceeding in the same direction and lane of travel.

22. The Maxwell Complaint alleges that Maxwell slowed her vehicle and came to a complete stop in traffic near the intersection with Longcreek Road, when Rice’s vehicle struck the back of Maxwell’s vehicle.

23. The Maxwell Complaint assert causes of actions for negligence against Defendant Rice.

24. Upon information and belief, Maxwell was the sole occupant of the 2003 Infiniti G35 4 door sedan at the time of the accident and has asserted claims for bodily injury as a result of the alleged accident.

25. Upon information and belief, Elijah Curtis was a passenger in the 2004 Dodge automobile operated by Defendant Rice at the time of the alleged accident and has or will make claims under the Rice Policy as a result of the alleged collision.

26. Upon information and belief, no collision occurred or, if a collision did occur, the collision was created intentionally by Defendants.

27. Upon information and belief, the Defendants colluded together to create a false claim for insurance proceeds.

28. Upon information and belief, if any collision did occur involving the 2003 Infiniti G35 4 door sedan and 2004 Dodge Intrepid 4 door sedan, the collision was staged as part of the Defendants’ attempt to create false claims for insurance proceeds.

29. Presentation of a fraudulent insurance claim is a violation of South Carolina law.

FOR A FIRST

DECLARATION

30. Plaintiffs repeat and reallege the allegations above as if set forth fully verbatim herein.

31. The Rice and Williams Policies only provide coverage for an accident.

32. Upon information and belief, the injuries and damages asserted in the Maxwell Complaint did not occur, or if they did were not a result of an accident.

33. Therefore, Progressive is entitled to a declaration that the Rice Policy does not provide liability coverage for any of the alleged incident and that Progressive does not have a duty to defend or indemnify Rice for the claims asserted in the Maxwell Complaint.

34. Additionally, Progressive is entitled to a declaration that the Maxwell Policy does not provide UM coverage for any of the alleged incident.

FOR A SECOND

DECLARATION

35. Plaintiffs repeat and reallege the allegations above as if set forth fully verbatim herein.

36. The Rice Policy excludes liability coverage for bodily injury or property damage caused purposefully by or at the direction of the insured.

37. Upon information and belief, the injuries alleged in the Maxwell Complaint, if they occurred at all, are a result of the intentional acts of the Defendants.

38. Therefore, Progressive is entitled to a declaration that the Rice Policy does not provide liability coverage for any of the alleged incident.

FOR A THIRD

DECLARATION

39. Plaintiffs repeat and reallege the allegations above as if set forth fully verbatim herein.

40. The Rice Policy excludes liability coverage for bodily injury or property damage suffered by any person while occupying any auto being used in any criminal activity.

41. Upon information and belief, the Maxwell’s claims arise out of the use of a vehicle in the commission of criminal activity, namely the intent to commit insurance fraud.

42. Therefore, Progressive is entitled to a declaration that the Rice Policy does not provide liability coverage for any of the alleged incident.

FOR A FOURTH

DECLARATION

43. Plaintiffs repeat and reallege the allegations) above as if set forth fully verbatim herein.

44. The Rice and Williams Policies provide that Progressive may deny coverage if an insured conceals or misrepresents any material fact or circumstance or engages in fraudulent conduct in connection with the presentation or settlement of a claim.

45. Upon information and belief, the Defendants have made material misrepresentations and/ or committed fraud in connection with the presentation of their claims.

46. Therefore, Progressive is entitled to a declaration that the Rice Policy does not provide liability coverage for any of the alleged incident and that Progressive does not have a duty to defend or indemnify Rice for the claims asserted in the Maxwell Complaint.

47. Additionally, Progressive is entitled to a declaration that the Maxwell Policy does not provide UM coverage for any of the alleged incident.

FOR A FIFTH

DECLARATION

48. Plaintiffs repeat and reallege the allegations above as if set forth fully verbatim herein.

49. South Carolina public policy prevents a party from profiting by his or her own criminal acts.

50. Upon information and belief, the submission of the above-referenced false claim to Progressive is a criminal act.

51. Therefore, Progressive is entitled to a declaration that the Rice Policy does not provide liability coverage for any of the alleged incident and that Progressive does not have a duty to defend or indemnify Rice for the claims asserted in the Maxwell Complaint.

52. Additionally, Progressive is entitled to a declaration that the Maxwell Policy does not provide UM coverage for any of the alleged incident. WHEREFORE, Plaintiffs Progressive Direct Insurance Company and Progressive Universal Insurance Company request that this honorable Court inquire into these matters and declare that

1. the Rice and Williams Policies do not provide coverage for Defendants Serious Rice and Shajuana Maxwell for the claims and damages allegedly arising out of the abovereferenced incident;

2. Progressive Direct Insurance Company does not owe a duty to defend or indemnify Serious Rice for the claims asserted against him in the Maxwell Complaint and any complaint that may be filed by Defendant Curtis arising out of this alleged accident; and

3. such other and further relief as the court may deem just and proper. Plaintiff demands a jury trial. MURPHY & GRANTLAND, P.A. s/Susan O. Porter Susan O. Porter, Esquire, Bar #68335 Murphy & Grantland, P.A. P.O. Box 6648, Columbia, South Carolina 29260 (803) 782-4100 Attorneys for Plaintiff Columbia, South Carolina October 12, 2021

SUMMONS

STATE OF

SOUTH CAROLINA

COUNTY OF

RICHLAND

IN THE COURT OF

COMMON PLEAS

C/A#2021-CP-40- 5410 Woodcreek Farms, Inc. and Taylor Properties, LLC, Plaintiffs, vs. Ruth E. Mason, deceased, together with any and all heirs, devisees, distributees, and all other persons entitled to claim under or through Ruth E. Mason, deceased, also all other unknown persons claiming any right, title or estate, interest in or lien upon the real estate described in the Complaint herein; 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., Defendants. IN RE: 8475 Old Percival Road, Columbia SC TMS: 22602-01-01 TO: THE DEFENDANT 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 located at 1416 Laurel Street, P.O. Box 456, Columbia, SC 29202-0456, within thirty ( 30) days after the service hereof, exclusive of the day of such service. 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. YOU WILL ALSO TAKE NOTICE, that should you fail to answer the complaint, as required by this summons, within thirty (30) days after the service hereof, the Plaintiff will seek the agreement and stipulation of all parties, not in default and will move for a general order of reference of this cause to the Master-in-Equity or a Special Referee for Richland County, pursuant to Rule 53, South Carolina Rules of Civil Procedure, stipulating that said Master in-Equity or Special Referee to enter a final judgment in this case. TO MINOR( S) OVER THE FOURTEEN YEARS OF AGE, AND/ OR TO MINOR( S) UNDER FOURTEEN YEARS OF AGE AND/OR TO PERSONS UNDER SOME LEGAL DISABILITY AND THE PERSON WITH WHOM THE MINOR(S) AND/OR PERSON WITH LEGAL DISABILITY RESIDE(S): 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, applications for such appointment may be made by the Plaintiff. W. Joseph Moore, Jr. Gertz & Moore, LLP P.O. Box 456 Columbia, SC 29202 (803) 352-1524 Attorneys for the Plaintiffs

NOTICE OF FILING

COMPLAINT TO THE DEFENDANTS ABOVE-NAMED: YOU WILL PLEASE TAKE NOTICE that the original Summons and Complaint in the abovecaptioned action is filed in the office of the Clerk of Court for Richland County, the object and prayer of which is to obtain reformation of the deed given by Ruth E. Mason to Woodcreek Farms, Inc. and Taylor Properties, LLC dated May 28, 2002 and recorded in the Office of the Register of Deeds for Richland County on June 13, 2002 in Book 673 at page 2810, to clear title to real property and for such other relief as set forth in the Complaint.

NOTICE OF

LIS PENDENS NOTICE IS HEREBY GIVEN, that an action has been commenced by the Plaintiff above- named, against the Defendant(s) above-named, for reformation of the deed given by Ruth E. Mason to Woodcreek Farms, Inc. and Taylor Properties, LLC dated May 28, 2002 and recorded in the Office of the Register of Deeds for Richland County on June 13, 2002 in Book 673 at page 2810 to clear title to the real property described herein. The following is a description of the premises subject to said action: All that certain piece, parcel or tract of land shown as Parcels “A”, “B” and “C- 1”, comprising 14.174 Acres, as indicated on a plat prepared for Ruth Mason, Taylor Properties and Margaret W. Cooper by United Design Services dated September 4, 1998, and recorded in the Office of the Register of Deeds for Richland County on in Record Book 672 at page 443. Said property being bounded and measuring as follows, all as is shown on said plat: On the Southeast by Old Percival Road, whereon it fronts and measures a total distance of Seven hundred sixteen and 54/100 (716.54′) feet; on the Southwest by property now or formerly of Columbia Silica Sand Co., whereon it measures Seven hundred sixty-nine and 18/100 (769.18′) feet; on the Northwest by property now or formerly of S.C. Dept. Of Transportation, whereon it measures Nine hundred ninetythree and 26/100 (993.26′) feet; and on the Northeast by Parcel C-2, whereon it measures Seven hundred six and 90/100 (706.90′) feet, All measurements being more or less. Property Address: 8475 Old Percival Road, Columbia SC Richland County Tax Map: 22602-01-01 W. Joseph Moore, Jr. Gertz & Moore, LLP P.O. Box 456 Columbia, SC 29202 (803) 352-1524 Attorneys for Plaintiffs

ORDER APPOINTING GUARDIAN AD LITEM I HEREBY APPOINT Kelley Yarborough Woody as Guardian Ad Litem to represent the interests of any and all unknown persons claiming any right, title or estate, interest in or lien upon the real estate described in the Complaint herein including unknown heirs, devisees, distributees, and all other unknown persons entitled to claim under or through Ruth E. Mason, deceased,; any unknown adults being as a class designated as John Doe; and any unknown infants or persons under disability, or persons in the military service claiming any right, title, estate, interest in, as a beneficiary or otherwise, or lien upon the property of which is the subject of this action, being designated as a class as Richard Roe, in proceedings relating to the above matter. This court has determined representation would be otherwise inadequate for the following reason(s): The parties are either unknown or maybe subject to some disability which would prevent them from adequately representing their interest in this matter. Executed and entered the 8th day of December, 2021. Jeanette McBride Clerk of Court for Richland County

SUMMONS

STATE OF

SOUTH CAROLINA

COUNTY OF

RICHLAND

IN THE COURT OF

COMMON PLEAS

2022-CP-40-00252 Tyler Davis vs. Brandon Terell Brown. TO THE ABOVE NAMED DEFENDANT BRANDON TERELL BROWN: 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 to said Complaint on the subscriber at his office of the Goings Law Firm, LLC, 1510 Calhoun Street, Columbia, South Carolina 29201, 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. By Robert F. Goings, Goings Law Firm, LLC, 1510 Calhoun Street, Columbia, SC 29201 Phone: (803) 350- 9230 Fax: (877) 789-6340 Email: rgoings@goingslawfirm.co m Attorney for Plaintiff

NOTICE OF FILING TO: DEFENDANT BRANDON TERELL BROWN. YOU WILL PLEASE TAKE NOTICE that the original Complaint in the above entitled action, together with the Summons, were filed in the Office of the Clerk of Court for Richland County, South Carolina, on January 18, 2022, at 11:49 a.m., the object and prayer of which is the recovery of a sum certain due to Plaintiff by Defendant and for such other and further relief as set forth in the Complaint. By Robert F. Goings, Goings Law Firm, LLC, 1510 Calhoun Street, Columbia, SC 29201 Phone: (803) 350-9230 Fax: ( 877) 789- 6340 Email: rgoings@goingslawfirm.co m Attorney for Plaintiff

SUMMONS

(Foreclosure)

(Non-Jury)

STATE OF

SOUTH CAROLINA

COUNTY OF

RICHLAND

COURT OF

COMMON PLEAS

C/A NO.:

2022-CP-40-00268 Palmetto Citizens Federal Credit Union, Plaintiff, vs. Jeannie Frazier Harry F/ K/ A Jeannie Frazier- Scott A/ K/ A Jeannie F. Harry and Palmetto Citizens Federal Credit Union, Defendants. (217-946) TO THE DEFENDANT ABOVE-NAMED: YOU ARE HEREBY SUMMONED AND REQUIRED to answer the Complaint in the abovecaptioned action, a copy of which is herewith served upon you, and to serve a copy of your Answer upon the subscribers at their offices located at 1900 Barnwell Street, Post Office Drawer 7788, Columbia, South Carolina 29202, within thirty (30) days after the date of such service, exclusive of the day of such service; and if you fail to answer the said Complaint within the time aforesaid, judgment by default will be rendered against you for the relief demanded in the Complaint. YOU WILL ALSO TAKE NOTICE that Plaintiff will move for an order of reference or that the Court may issue a general order of reference of this action to a master in equity/ special referee, pursuant to Rule 53, of the South Carolina Rules of Civil Procedure. s/ S. Nelson Weston, Jr. S. Nelson Weston, Jr. SC Bar Number 12902 RICHARDSON, PLOWDEN & ROBINSON, P.A. P.O. Drawer 7788 Columbia, South Carolina 29202 (803) 771-4400 ATTORNEYS FOR THE PLAINTIFF

SUMMONS

STATE OF

SOUTH CAROLINA

COUNTY OF

RICHLAND

IN THE COURT OF

COMMON PLEAS

FIFTH JUDICIAL

CIRUIT

Case#2021-CP-40-05616 Lawrence L. Green, Jr. Plaintiff vs. Richard Kennedy; Equity Trust Company CSTN FBO Scott Grunden; E.W. Cromartie, II.; David A. Adams, in his Capacity as Richland County Treasurer/ Tax Collector; all other firms and corporations entitled to claim under, by or through the abovenamed Defendants designated as a class “ Jack Doe”; any and all unknown adults who may have claim to have any right, title, estate, designated) Interest in or lien upon the real property as a class as “Jill Doe”; any persons who may be in the military service of the United States of America designated as a class as “ Joseph Roe”; any unknown infants or persons under disability, including but not limited to minors designated as a class “Mary Roe”, Defendants TO THE ABOVE-NAMED DEFENDANTS: YOU ARE HEREBY SUMMONDED and required to appear and defend by answering the Complaint in this quiet title action on property known as known as 1923 Gervais Street and being shown on Tax Map 11406, Block 14, Parcel 22, a tax map maintained by the Richland County Assessor’s Office; a copy of which is herewithin served upon you, and to serve a copy of your Answer to said Complaint upon Plaintiff’s attorney at: Dwell Legal, LLC, 460 King Street, Suite 200, Charleston, SC 29403, within thirty ( 30) days after service hereof, exclusive of the day of such service; except that the United States of America, if named shall sixty (60) days to answer after the service hereof; exclusive of the day of such service. If you fail to answer within the time aforesaid, the Plaintiff will apply to the Court for the relief requested in the Complaint. TO MINOR( S) OVER FOURTEEN YEARS OF AGE AND 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 to represent said minor(s) within thirty (30) days after the service fo this Summons and Notice upon you. If you fail to do so, application for such appointment will be made by the Plaintiff herein. DWELL LEGAL, LLC. /s/ Charlene A. Green Charlene A. Green, Esq. ATTORNEY FOR THE PLAINTIFF Charleston, South Carolina November 12, 2021

LIS PENDENS

(Quiet Title Actions) NOTICE IS HEREY GIVEN that an action has been commenced in the Court upon complaint of Plaintiff against Defendant to quiet title on property located in Richland County. The subject property described as follows: All that certain piece, parcel or lot of land, with the improvements thereon, situate, lying and being in the County of Richland, State of South Carolina, being shown and delineated as and known as 1923 Gervais Street and being shown on Tax Map 11406, Block 14, Parcel 22, a tax map maintained by the Richland County Assessor’s Office with all measurements being a little more or less. Said tax map being hereto craved for a more complete and accurate description of said plat. TMS: 11406-14-22 DWELL LEGAL, LLC. /s/ Charlene A. Green Charlene A. Green, Esq. SC Bar # 103174 460 King Street, Suite 200 Charleston, SC 29403 Telephone: (803) 920-5677 Facsimile: (843) 800-8422 Email:charlene@dwellinch arleston.com ATTORNEY FOR THE PLAINTIFF Charleston, South Carolina November 12, 2021