SUMMONS
AND NOTICES
STATE OF
SOUTH CAROLINA
COUNTY OF
RICHLAND
IN THE COURT OF
COMMON PLEAS
CASE NO.
2022-CP-40-01419 MCLP Asset Company, Inc., PLAINTIFF, VS. Stanley Kuhn, Individually, and as Legal Heir or Devisee of the Estate of Frances T. Kuhn, Deceased; Mark Kuhn, Individually, and as Legal Heir or Devisee of the Estate of Frances T. Kuhn, Deceased; Joyce Elliott, Individually, and as Legal Heir or Devisee of the Estate of Frances T. Kuhn, Deceased; Carole Tobias, Individually, and as Legal Heir or Devisee of the Estate of Frances T. Kuhn, Deceased; any other Heirs- at- Law or Devisees of Frances T. Kuhn, 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; and Fairways Villas Homeowners Association, Inc. a/ k/ a Fairway Villas Homeowners Association, DEFENDANT(S). (221136.00016) 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 March 18, 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 Frances T. Kuhn, 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 24th day of May, 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 Robert W. Kuhn and Frances T. Kuhn to Mortgage Electronic Registration Systems, Inc. as nominee for Branch Banking and Trust Company, dated May 23, 2008, recorded June 2, 2008, in the Office of the Clerk of Court/Register of Deeds for Richland County, in Book 1433 at Page 3622; thereafter, said Mortgage was assigned to Community Loan Servicing, LLC by assignment instrument dated May 17, 2021 and recorded June 3, 2021 in Book 2625 at Page 577. The description of the premises is as follows: All that certain piece, parcel or lot of land, together with improvements thereon, if any, situate, lying and being in the community known as Longcreek Plantation, near the Town of Blythewood, in the County of Richland, State of South Carolina, being shown and designated as Lot 2, on a plat entitled “Resubdivision plat prepared for Fairway Villas Homeowners Association” by Civil Engineering of Columbia, dated June 23, 1993, last revised July 12, 1993, and recorded in the Office of the ROD for Richland County in Plat Book 54 at Page 8595. Reference to said plat is made for a more complete and accurate description. This being the same property conveyed to Robert W. Kuhn and Frances T. Kuhn by Deed of Fairways Development General Partnership dated September 27, 1985 and recorded September 30, 1985 in Book D760 at Page 862 in the Office of the Clerk of Court/Register of Deeds for Richland County, South Carolina. This being the same property conveyed to Robert W. Kuhn and Frances T. Kuhn by Deed of Fairways Villas Homeowners Association, Inc., dated October 20, 1990 and recorded October 22, 1993 in Book D1166 at Page 374 in the Office of the Clerk of Court/ Register of Deed for Richland County, South Carolina. Thereafter, Robert W. Kuhn and Frances T. Kuhn conveyed said property to Robert W. Kuhn and Frances T. Kuhn, as joint tenants with rights of survivorship dated May 25, 2011 and recorded June 1, 2011 in Book 1686 at Page 3295 in the Office of the Clerk of Court/Register of Deeds for Richland County, South Carolina. TMS No. R20432-01-03 Property address: 3 Fairway Lane Blythewood, SC 29016 SCOTT AND CORLEY, P.A. By: 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 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
MORTGAGE
FORECLOSURE)
STATE OF
SOUTH CAROLINA
COUNTY OF
RICHLAND
IN THE COURT OF
COMMON PLEAS
DEFICIENCY WAIVED
C/A#2023-CP-40-02876 Guild Mortgage Company LLC, PLAINTIFF, vs. Toby James Freeman, Individually and as Personal Representative for the Estate of Billy Ray Freeman; Kimberly Freeman, 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 his 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 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. 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.
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 June 1, 2023. 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
NOTICE OF HEARING
STATE OF
SOUTH CAROLINA
COUNTY OF
RICHLAND
IN THE PROBATE
COURT
CASE NUMBER:
2023 ES40 01057
IN THE MATTER OF:
Jermaine Eddie Glenn
(Decedent) DATE: August 29, 2023 TIME: 2:00 p.m. PLACE: Richland County Judicial Center 1701 Main Street Courtroom 2-F Columbia, South Carolina, 29201
PURPOSE
OF HEARING THIS HEARING HAS BEEN SCHEDULED TO HEAR AND DECIDE THE SUMMONS AND PETITION TO DISINHERIT, AND THE SUMMONS AND PETITION FOR FORMAL APPOINTMENT BOTH ACTIONS WERE FILED BY ATTORNEY BRIAN BOGER ON BEHALF OF KIMBERLYBRUNSON. You are required to review the entire estate file prior to the hearing. The court will no longer make copies of relevant documents for you to have in the hearing. You are required to bring your copies to the hearing. We encourage you to activate your SMS account to view the estate file online at the below link: http://www.rcgov.us/Onlin eServices/Online- DataServices.aspx Executed this 11th day of July 2023. Lori Elrod, Clerk of Probate P.O. Box 192, Columbia, SC 29202
SUMMONS AND
NOTICE
PUBLICATION
STATE OF
SOUTH CAROLINA,
RICHLAND COUNTY
FAMILY COURT OF
COLUMBIA, SOUTH
CAROLINA
FIFTH JUDICIAL
CIRCUIT
DOCKET
2021-DR-28-40-1109 SCDSS (Plaintiff) vs. Julian Alberto (Defendants) IN THE INTEREST OF Minor Child Born 2006 Minor Child Born 2007 Minor Child Born 2016 Minor Child Born 2017 TO DEFENDANT(S): Julian Alberto YOU ARE HEREBY SUMMONED And required to answer the Complaint In the above referenced concerning the minor Children above and that you have failed to contact the agency in regards to your whereabouts in this action, the original of which has been filed in the Office of the Clerk of Court for Janet C. Hasty, Kershaw County, on April 28, 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 statutory time allotted, the Plaintiff in this action will apply to the Court for the relief demanded in said Complaint. S. C. DEPARTMENT OF SOCIAL SERVICES Kimberly L.B. Simmons, Esquire, 2638 Two Notch Road, Ste. 200, Columbia, SC 29204 (803) 729-6029
XXXXXXX
SUMMONS
STATE OF SOUTH
CAROLINA
COUNTY OF
RICHLAND
IN THE COURT OF
COMMON PLEAS
CASE NO.
2023-CP-40-02373 MAGNOLIA POINTE JV, LLC, Plaintiff, vs. MADD 68 INVESTMENTS, LLC d/ b/ a MADD 68; AND MITCHELL ADDISON, INDIVIDUALLY, Defendants. TO THE DEFENDANTS 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 on the Subscriber at his office at the address below, within thirty (30) days after service hereof, exclusive of the day of such service; and, if you fail to answer the Complaint as required by this Summons within thirty (30) days after the service hereof, exclusive of the date of such service, the Plaintiff in this action will apply to the Court for the relief demanded in the Complaint. s/ Jacob S. Barker Jacob S. Barker (SC Bar #77449) GRAYBILL LANSCHE & VINZANI, LLC 225 Seven Farms Drive, Suite 207 Charleston, South Carolina 29492 Direct Dial: ( 843) 408- 4063 jbarker@glvlawfirm.com Attorneys for Plaintiff
May 2, 2023 Charleston, South Carolina
STATE OF
SOUTH CAROLINA
COUNTY OF
BEAUFORT
IN THE FAMILY
COURT Case No.2023-DR-07-638 DANIEL ALAN CAUSEY Petitioner vs. MARK ALLEN WENTZEL and SIERRA MCKINSEY CAUSEY Respondents. IN RE: Mackenzie Aidan Drake, age 14 TO RESPONDENT MARK ALLEN WENTZEL:
NOTICE OF PENDING
ADOPTION ACTION YOU WILL PLEASE TAKE NOTICE:
1. That an action for the adoption of Mackenzie Aidan Drake has been initiated in the Beaufort County Family Court, P.O. Box 1124, Beaufort, South Carolina 29902- 1124; and
2. Within thirty (30) days of receiving this notice you must respond in writing by filing with the Court in which the adoption is pending notice and reasons to contest, intervene or otherwise respond; and
3. The Court must be informed of your current address and of any changes in your address during the adoption proceeding; and
4. FAILURE TO FILE A RESPONSE WITHIN THIRTY (30) DAYS OF RECEIVING NOTICE CONSTITUTES CONSENT TO ADOPTION OF THE CHILD AND FORFEITURE OF ALL YOUR RIGHTS AND OBLIGATIONS WITH RESPECT TO THE CHILD.
SUMMONS YOU ARE HEREBY SUMMONED and notified that an action has been filed against you in this court. Thirty (30) days after the day you receive this Summons, you must respond in writing to the Petition for Adoption by filing an Answer to the Petition upon the petitioner or petitioner’s attorney at the address shown below. If you fail to answer the Petition, judgment by default could be rendered against you for the relief requested in the Petition for Adoption. Frederick M. Corley Attorneys for Petitioner 1108-B Charles Street Beaufort, SC 29902 843-524-3232 7/24/23
SUMMONS
STATE OF
SOUTH CAROLINA
COUNTY OF
RICHLAND
IN THE FAMILY
COURT
5th JUDICIAL CIRCUIT
2023-DR-40-1398 Jessamy Ann Springs Plaintiff VS. Clarence Springs III 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 May 5, 2023
SUMMONS AND
NOTICE OF FILING
OF COMPLAINT
STATE OF
SOUTH CAROLINA
COUNTY OF
RICHLAND
IN THE COURT OF
COMMON PLEAS
(NON-JURY
MORTGAGE
FORECLOSURE) DEFICIENCY WAIVED
C/A#2023-CP-40-02836 Guild Mortgage Company LLC, PLAINTIFF, vs. Paul R Lewis, Jr; Shannon Lewis; Stonemont Homeowners Association, Inc.; Chris Robinson, 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 his 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 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 on May 31, 2023. 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. 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 (CLAIM & DELIVERY –
NONJURY)
STATE OF
SOUTH CAROLINA
COUNTY OF
RICHLAND
IN THE COURT OF
COMMON PLEAS CIVIL CASE NUMBER:
2023-CP-40-01633 SOUTH CAROLINA FEDERAL CREDIT UNION, Plaintiff, vs. DONTE JAMAR YOUNG, 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 said Complaint on the subscribers at their offices, Moore & Van Allen PLLC, 78 Wentworth Street, Post Office Box 22828, Charleston, South Carolina 29413-2828, or to otherwise appear and defend, within thirty (30) days after the service hereof, exclusive of the day of such service, and if you fail to answer the Complaint, or otherwise to appear and defend, within the time aforesaid, the Plaintiff in this action will obtain a judgment by default against you for the relief demanded in the Complaint. March 29, 2023 CHARLESTON, SC
NOTICE OF FILING
COMPLAINT TO DEFENDANT DONTE JAMAR YOUNG: YOU WILL PLEASE TAKE NOTICE that the original Complaint in the above- entitled action, together with the Civil Action Coversheet, Summons, Exhibits and Verification, were filed in the Office of the Clerk of Court for Richland County, South Carolina, on March 29, 2023, at 1:08 p. m., the object and prayer of which is the claim and delivery of Collateral and recovery a sum certain due Plaintiff by Defendant, DONTE JAMAR YOUNG, and for such other and further relief as set forth in the Complaint. s/Cynthia Jordan Lowery Cynthia Jordan Lowery #12499 MOORE & VAN ALLEN, PLLC 78 Wentworth Street Post Office Box 22828 Charleston, SC 29413- 2828 Telephone: ( 843) 579- 7000 Facsimile: (843) 579- 8714 Email: cynthialowery@mvalaw.co m ATTORNEYS FOR PLAINTIFF July 12, 2023 CHARLESTON, SC
XXXXXXX
SUMMONS
AND NOTICE STATE OF SOUTH CAROLINA COUNTY OF RICHLAND IN THE COURT OF COMMON PLEAS C/A NO. 2023-CP- 40-01737 Credit Suisse First Boston Mortgage Securities Corp., Home Equity Asset Trust 2006- 5, Home Equity Pass- Through Certificates, Series 2006-5, U.S. Bank National Association, as Trustee, Plaintiff vs. Antwion A. Ellison and Levi O. Ellison, Defendants. TO THE DEFENDANT( S) Antwion A. Ellison and Levi O. Ellison: YOU ARE HEREBY SUMMONED and required to answer the Complaint in the above action, a copy which is herewith served upon you, and to serve a copy of your Answer upon the undersigned at their offices, 2838 Devine Street, Columbia, South Carolina 29205, within thirty (30) days after service upon you, 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 relief demanded in the Complaint. NOTICE NOTICE IS HEREBY GIVEN that the original Complaint in this action was filed in the office of the Clerk of Court for Richland County on April 4, 2023. NOTICE NOTICE IS HEREBY GIVEN that pursuant to the South Carolina Supreme Court Administrative Order 2011-05-02- 01, you have a right to be considered for Foreclosure Intervention. NOTICE OF PENDENCY OF ACTION NOTICE IS HEREBY GIVEN THAT an action has been commenced and is now pending or is about to be commenced in the Circuit Court upon the complaint of the above named Plaintiff against the above named Defendant for the purpose of foreclosing a certain mortgage of real estate heretofore given by Levi Ellison, Jr. to Credit Suisse First Boston Mortgage Securities Corp., Home Equity Asset Trust 2006-5, Home Equity Pass-Through Certificates, Series 2006-5, U.S. Bank National Association, as Trustee bearing date of February 17, 2006 and recorded February 22, 2006 in Mortgage Book 1154 at Page 2277 in the Register of Mesne Conveyances/ Register of Deeds/Clerk of Court for Richland County, in the original principal sum of Seventy Four Thousand One Hundred and 00/100 Dollars ($ 74,100.00). Thereafter, by assignment recorded on November 4, 2015 in Book 2068 at Page 3071, the mortgage was assigned to U. S. Bank National Association, as Trustee for Credit Suisse First Boston Mortgage Securities Corp., Home Equity Asset Trust 2006- 5, Home Equity Pass- Through Certificates, Series 2006-5., and that the premises effected by said mortgage and by the foreclosure thereof are situated in the County of Richland, State of South Carolina, and is described as follows: All that certain piece, parcel, or lot of land, with the improvements thereon, situate, lying, and being on Seabury Street, near the City of Columbia, near the County of Richland, and in the State of South Carolina shown and designated as Lot “D”, on plat prepared for James D. Langley, recorded in the Office of the Clerk of Court for Richland County, in Plat Book 18 at Page 475. TMS No. 11715-13-06 Property Address: 5819 Seabury Street, Columbia, SC 29203 Riley Pope & Laney, LLC Post Office Box 11412 Columbia, South Carolina 29211 Telephone (803) 799-9993 Attorneys for Plaintiff 5240
SUMMONS
AND NOTICES
(Non-Jury)
FORECLOSURE
STATE OF
SOUTH CAROLINA
COUNTY OF
RICHLAND
IN THE COURT OF
COMMON PLEAS
C/A#2022CP4006574 Reverse Mortgage Funding LLC, Plaintiff, vs. Hilda Dinkins, Deborah Wilson, Any Heirs-at-Law or Devisees of the Estate of Louise Beard, 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, United States of America Acting through Secretary of Housing and Urban Development, Defendant(s). 22-011967 TO THE DEFENDANT( S): Any Heirs-at-Law or Devisees of the Estate of Louise Beard, 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 1450, 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 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 December 16, 2022. /s/Nicole R. Kuertz Nicole R. Kuertz Attorney, SC Bar No.: 105081 Albertelli Law 1201 Main St, Suite 1450 Columbia, SC 29201 nkuertz@alaw.net Phone: (803) 828-0880 Fax (803) 828-0881 Date: June 30, 2023 Columbia, South Carolina
SUMMONS
AND NOTICES
(Non-Jury)
FORECLOSURE
OF REAL ESTATE
MORTGAGE
STATE OF
SOUTH CAROLINA
COUNTY OF
RICHLAND
IN THE COURT OF
COMMON PLEAS
C/A#2023-CP-40-02393 Truist Bank, Plaintiff, vs. Scott Mitchell; Hawthorne Ridge Community Association, Inc.; The United States of America, acting by and through its agency, The Secretary of Housing and Urban Development, Defendant(s). TO THE DEFENDANT(S) ABOVE NAMED: 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 at 3800 Fernandina Road, Suite 110, Columbia, SC 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 Attorney for Plaintiff. YOU WILL ALSO TAKE NOTICE that Plaintiff will move for an Order of Reference or 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. YOU WILL ALSO 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 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 herein and the Complaint attached hereto.
NOTICE OF FILING
COMPLAINT TO THE DEFENDANTS ABOVE NAMED: YOU WILL PLEASE TAKE NOTICE that the original Complaint, Cover Sheet for Civil Actions and Certificate of Exemption from ADR in the above entitled action was filed in the Office of the Clerk of Court for Richland County on May 9, 2023. A Notice of Foreclosure Intervention was also filed in the Clerk of Court’s Office. Brock & Scott, PLLC 3800 Fernandina Road, Suite 110, Columbia, SC 29210 Phone (803) 454-3540 Fax (803) 454-3541 Attorneys for Plaintiff
SUMMONS
STATE OF
SOUTH CAROLINA
COUNTY OF
RICHLAND
IN THE PROBATE
COURT
2023-ES-40-1057
IN THE MATTER OF
JERMAINE EDDIE
GLENN, Decedent. Kimberly Brunson, Petitioner, Dwight Glenn, Tiffany Miller, the unknown Father of the Decedent known as John Doe and all surviving and unknown heirs of Decedent known as Jane Doe and Richard Roe, Respondents. TO THE RESPONDENTS ABOVE NAMED: YOU ARE HEREBY SUMMONED and required to answer the Petition therein, a copy of which is herewith served upon you, or otherwise appear and defend, and to serve a copy of your Response to said Petition upon the subscriber at his office, 1331 Elmwood Ave., Suite 305, P.O. Box 65 (29202), Columbia, South Carolina 29201, within thirty (30) days after service hereof, exclusive of the day of such service, and if you fail to respond to the Petition within the time aforesaid, or otherwise appear and defend, the Petitioner 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 Petition. Brian L. Boger, SC BAR# 752 BOGER LAW FIRM June 30, 2023
PETITION TO
DISINHERIT FATHER
OF THE DECEDENT
IN THE MATTER OF
JERMAINE EDDIE
GLENN, Decedent. The above-named Decedent’s birth certificate does not contain the father’s name. When the Decedent died in November of 2022, he was fortyeight years old. He had been in a motorcycle accident as an adult and was unable to care for himself for many years. Upon information and belief, the father did not provide support for the Decedent when he was a young man or after the aforementioned accident. The proposed Personal Representative, the Decedent’s sister, through her below counsel, hereby moves to have the unknown father to be disinherited and that any interest in personal or real property of the Decedent revert to the surviving siblings. Brian L. Boger SC BAR# 752 BOGER LAW FIRM Attorney for Petitioner PO Box 65, Columbia, South Carolina 29201 (803) 252-2880 brian@bogerlaw.com June 30, 2023
SUMMONS
STATE OF
SOUTH CAROLINA
COUNTY OF
RICHLAND IN THE
FAMILY COURT
2023-DR-40-1191 PRINCESS WILSON FORD-THOMPSON vs. SKHENDU DAS, 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 this complaint upon the subscriber, Cynthia Mason, at Mason Legal, 723 Laurel St., Columbia, SC, 29201, 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 aboveentitled action was filed in the office of the Clerk of Court for Richland County on April 20, 2023 by Cynthia K. Mason, Attorney for Plaintiff.
SUMMONS AND
NOTICE FOR
PUBLICATION
STATE OF
SOUTH CAROLINA
COUNTY OF
RICHLAND
IN THE FAMILY
COURT FIFTH
JUDICIAL CIRCUIT
Case#2020-DR-40-1322 South Carolina Department of Social Services, Plaintiff, vs. Chrishelle Bush, Samuel Taylor, Brenda Howell Defendant. IN THE INTERESTS OF: Child1 DOB: 12/24/2012 Minor Under the Age of 18. TO DEFENDANTS: Samuel Taylor YOU ARE HEREBY SUMMONED and required to answer the non-emergency complaint for removal 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 22nd day of May 2020 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 630 Chesnee Highway Spartanburg, SC 29303 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 June 8, 2023 Spartanburg, South Carolina
SUMMONS
AND NOTICE OF
FILING OF
COMPLAINT AND
NOTICE OF
FORECLOSURE
INTERVENTION
STATE OF
SOUTH CAROLINA
COUNTY OF
RICHLAND
IN THE COURT OF
COMMON PLEAS
(NON-JURY
MORTGAGE
FORECLOSURE) DEFICIENCY WAIVED
C/A#2023-CP-40-02274 Lakeview Loan Servicing, LLC, PLAINTIFF, vs. Andre Robert Stennett and if Andre Robert Stennett be deceased then any children and heirs at law to the Estate of Andre Robert Stennett, distributees and devisees at law to the Estate of Andre Robert Stennett, 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; South Carolina Department of Revenue; The United States of America, by and through its Agency, the Department of Housing and Urban Development; Midland Funding LLC Assignee of Credit One Bank NA, 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 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. 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.
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/were filed with the Clerk of Court on May 3, 2023.
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.
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 AND
NOTICE OF
FILING OF
COMPLAINT
STATE OF
SOUTH CAROLINA
COUNTY OF
RICHLAND
IN THE COURT OF
COMMON PLEAS
(NON-JURY
MORTGAGE
FORECLOSURE) DEFICIENCY WAIVED
C/A#2023-CP-40-03203 Guild Mortgage Company LLC, PLAINTIFF, vs. Kazario Alexander Council a/k/a Kazario A Council, Individually and as Personal Representative for the Estate of Mattie C Williams a/ k/ a Mattie Council Williams; First- Citizens Bank & Trust Company sbm Community Resource Bank, N.A., 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 his 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 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. 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 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.
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, were filed in the Office of the Clerk of Court on June 20, 2023. 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
FIRST AMENDED
SUMMONS
STATE OF
SOUTH CAROLINA
COUNTY OF
RICHLAND
IN THE FAMILY
COURT FIFTH JUDICIAL
CIRCUIT
2023-DR-40-0943 Lauren Hudspeth and Loren Hudspeth, Plaintiff, vs. Linda Denmark (Mother), a/ k/ a Angela Ferguson, a/k/a Victoria Hudson and South Carolina Department of Social Services, Defendants. In Re: Angela Hudson ( DOB: 09/09/2022), minor under the age of 14 years. To Defendants: YOU ARE HEREBY SUMMONED and required to appear and defend the within action ( for termination of parental rights and adoption) and to answer the Complaint herein of which a copy is herewith served upon you, and to serve a copy of your answer to said Complaint on the subscriber at their office located at 331 E. Main Street, Suite 200, Rock Hill, South Carolina 29730, within thirty (30) days after the service hereof, exclusive of the day of such service, and if you fail to appear and defend the within action within the time aforesaid, then judgment by default will be rendered against you for the relief demanded in the Complaint.
James Fletcher Thompson, SC’Bar#13082 L. Dale Dove, SC Bar# 1735 Thompson Dove Law Group, LLC, 331 E. Main Street, Suite 200/ Post Office Box 907, Rock Hill, South Carolina 29731 803-327-1910 Attorneys for Plaintiffs Date: June 21, 2023
FIRST AMENDED
COMPLAINT
STATE OF
SOUTH CAROLINA
COUNTY OF
RICHLAND
IN THE FAMILY
COURT FIFTH
JUDICIAL
CIRCUIT
2023-DR-40-0943 Lauren Hudspeth and Loren Hudspeth, Plaintiff, vs. Linda Denmark (Mother), a/’k/a Angela Ferguson, a/k/a Victoria Hudson and South Carolina Department of Social Services, Defendants, In Re: Angela Hudson ( DOB: 09/09/2022), minor under the age of 14 years. FIRST AMENDED COMPLAINT: Plaintiffs, herein, Lauren and Loren Hudspeth, brought this action seeking Termination of Parental Rights and Adoption of the child Angela Hudson on March 30, 2023. This Amended Complaint is being filed to include other alias names that the Defendant mother has been known to use. This Amended Complaint is being filed as a matter of course, pursuant to Rule 15(a), SCRCP in that no responsive pleading has been served. Plaintiffs respectfully allege:
1. Action Seeking Termination of Parental Rights and Adoption: In this action, Plaintiffs seek to terminate the parental rights of the biological parents of the minor child, Angela (child), and seek the adoption of the child.
2. Information on Plaintiffs: The Plaintiffs are the foster parents of Angela licensed by DSS. The Plaintiffs reside in South Carolina. The Plaintiffs had no prior relationship with Angela.
3. Child’s Information: Angela is a African- American female child, bom on September 9, 2022 in Columbia, South Carolina. Angela currently resides with Plaintiffs under a foster care arrangement with DSS. a. Value of Property Owned by Child: To the best of the Plaintiffs’ knowledge, Angela owns no property, either real or personal, in the State of South Carolina or elsewhere except for miscellaneous personal effects which have a nominal value. b. Special Needs Child: On information and belief, the minor child is a special needs child, as defined in South Carolina Code Section 63-9-30(10). c. Child is not an Indian Child: On information and belief, the child is not an Indian Child as defined by the Indian Child Welfare Act (ICWA), 25 U.S.C. Section 1901 et seq., and the provisions of ICWA do not apply to this action. d. Child in Legal Custody of DSS: The child is in the legal custody of DSS, having been removed from the biological parents upon grounds of abuse and neglect. On information and belief, the child came into DSS foster care on September 13, 2022. e. Placement with Foster Parents: DSS placed Angela into foster care with Plaintiffs on September 14, 2022 when she was just five (5) days old.
4. Biological Mother’s Information: The biological mother of the child is Linda Denmark, who has also been known as Victoria Hudson and/or Angela Ferguson. On information and belief Ms. Denmark’s last known address was 1911 Augusta Road, West Columbia, South Carolina 29169. Her date of birth is February 24, 1985.
5. Biological Father’s Information: On information and belief, the biological father of the child is unknown.
6. Jurisdiction and Venue: This Court has jurisdiction over the subject matter and the parties. Venue is proper in the Family Court in Richland County, South Carolina, as the child is in the legal custody of Richland County DSS.
FIRST CAUSE OF
ACTION AGAINST
DEFENDANT
BIOLOGICAL MOTHER (For termination of parental rights of
Biological Mother)
7. All the above allegations, not inconsistent herewith, are realleged as if set out verbatim in this cause of action.
8. Grounds for TPR of Biological Mother’s Parental Rights: On information and belief, and pursuant to South Carolina Code Sections 63-7-2570. the biological mother’s parental rights in and to the child should be terminated. The grounds justifying such termination are as follows: a. Pursuant to South Carolina Code Section 63- 7-2570( 1), the child or another child while residing in the parent’s domicile has been harmed as defined in South Carolina Code Section 63-7-20, and because of the severity or repetition of the abuse or neglect, it is not reasonably likely that the home can be made safe within twelve months. b. Pursuant to South Carolina Code Section 63- 7-2570(2), the child has been removed from the parent pursuant to Subarticle 3 of the South Carolina Children’s Code or South Carolina Code Section 63-7-1660 and have been out of the home for a period of six months following the adoption of a placement plan by court order or by agreement between the department and the parent and the parent has not remedied the conditions which caused the removal. c. Pursuant to South Carolina Code Section 63- 7-2570(3), the child has lived outside the home of the parent for a period of time exceeding six ( 6) months, during which time the biological mother; (i) has willfully failed to visit the minor child; and (ii) has willfully failed to maintain contact with the minor child, despite the absence of any restriction or prevention from contact or visitation by court order or by actions of the Plaintiff. d. Pursuant to South Carolina Code Section 63- 7-2570(4), the child has lived outside the home of the parent for a period of over six months and during that time the biological mother has willfully failed to support the child. e. Pursuant to South Carolina Code Section 63- 7-2570(7), the child has been abandoned by the parent, as defined in Section 63-7-20,
9. The child has thrived in the care of Plaintiffs. It is in the best interest of the child for the parental rights of the biological mother to be terminated so that the child may be adopted by Plaintiffs.
10. Wherefore, Plaintiffs seek the termination of the biological mother’s parental rights.
SECOND CAUSE OF
ACTION AGAINST
JOHN DOE
(For Termination of Parental Rights against any unknown Father)
11. All the above allegations, not inconsistent herewith, are realleged as if set out verbatim in this cause of action.
12. Responsible Father Registry: Plaintiffs’ counsel will search the South- Carolina Responsible Father Registry. If the birth father failed to register, this failure constitutes an implied irrevocable waiver of the father’s right to notice of the adoption proceedings. If a birth father has registered, the Plaintiffs will serve him with notice of adoption proceedings. The Plaintiffs allege upon information and belief that this man (John Doe) is not married to the biological mother. John Doe has not maintained substantial and continuous or repeated contact with minor child in that he has not paid support for minor children, has not visited minor children or had regular communication with minor child. Plaintiffs allege the consent of John Doe is not required pursuant to South Carolina Code Section 63- 9- 310(A)(4). Alternatively, if the biological father of the child were to properly file a contest to this adoption, and if it were to be determined that the biological father is a person whose consent is required, on information and belief, the biological father’s parental rights in and to the child should be terminated pursuant to South Carolina Code Section 63-7-2570(3), (4), and (7).
13. The child has thrived in the care of Plaintiffs. It is in the best interest of the child for the parental rights of John Doe to be terminated so that the child may be adopted by Plaintiffs.
14. Wherefore, Plaintiffs seek the termination of any parental rights John Doe may have in and to the child.
THIRD CAUSE OF
ACTION FOR
ADOPTION OF CHILD
BY PLAINTIFFS
15. All the above allegations, not inconsistent herewith, are realleged as if set out verbatim in this cause of action.
16. Plaintiffs Seek to Adopt Child/ Plaintiffs are Fit Parents: Plaintiffs desire to adopt the child, establishing the relationship of parent and child between themselves and the child. Plaintiffs are the fit and proper persons to care for the child and to provide for the child’s welfare.
17. Adoption Investigations: Plaintiffs will be providing an adoptive preplacement investigation, pursuant to South Carolina Code Section 63-9-520. Further, on information and belief, DSS will be providing a background investigation on the child and the child’s biological family. On information and belief, DSS will be providing the investigation reports to the Court.
18. Adoption Expenses Appropriate: No consideration has been paid to the biological parents to allow this adoption, or to any person or organization other than payment of those costs and expenses which may legitimately be paid under South Carolina Code Sections 16-3-1060 and 63-9-310. A verified, itemized statement of all payments of money or anything of value made within the past five (5) years or agreed to be made in the future by or on behalf of the Plaintiffs to any person, agency, or organization connected with the adoption will be filed with the Court prior to or at the final hearing in this matter.
19. New Social Security Number: Plaintiffs request that this Court issue an order finding that it is in the child’s best interest for new Social Security number for the child to be issued.
20. Guardian ad Litem: Plaintiffs move this Court to have a Guardian ad Litem appointed to represent the interests of the child.
21. Other Actions Involving Child: The following action(s) brought by DSS for the removal of the child from the biological parents is/are currently pending in the Richland County Family Court: Case #: 2022-DR-40-3153 (DSS child protection and permanency case). Plaintiffs are not aware of any other pending action which involves the child.
22. Wherefore, Plaintiffs seek to adopt the child and seek the other relief set out above. WHEREFORE, Plaintiffs respectfully pray for an Order providing the relief set forth above, and such other and further relief as this Court shall find just and proper. The relief which Plaintiffs seek includes, but is not limited to, the following:
1. Appoint a Guardian ad Litem to represent the interests of the child;
2. Terminate the parental rights, if any, of the biological mother, biological father, and any “John Doe” father, in and to the child;
3. Allow the adoption of child by Plaintiffs;
4. Change the name of the child from any other names by which the child may have been known, to names which the Plaintiffs will later provide to the Court;
5. Issue its final Decree of Adoption;
6. Find that the issuance of a new Social Security number is in the child’s best interest;
7. Require a Supplementary Certificate of Birth to be issued for the child pursuant to South Carolina Code Section 63- 9- 790; and
8. For such other and further relief as the Court deems just and proper. James Fletcher Thompson, SC Bar#13082 L. Dale Dove, SC Bar#1735 Thompson Dove Law Group, LLC, 331 E. Main Street, Suite 200/ Post Office Box 907, Rock Hill, South Carolina 29731 803-327-1910 Attorneys for Plaintiffs Date: June 21, 2023
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