COMPLAINT

STATE OF SOUTH CAROLINA

COUNTY OF GREENVILLE

IN THE COURT OF COMMON PLEAS

COUNTY OF GREENVILLE

C.A. No.: 2019-CP-2306459

Erin Leigh Driggers, Plaintiff, v. Brittnee Sloane Brooks, Defendant.

Plaintiff, by and through her undersigned counsel of record will show unto this Honorable Court the following:

GENERAL ALLEGATIONS

1. Plaintiff Erin Leigh Driggers (hereinafter “Plaintiff”) is a citizen and resident of Pickens County, South Carolina.

2. Defendant Brittnee Sloane Brooks (hereinafter “Defendant”) is, upon information and belief, a citizen and resident of Pickens County, South Carolina.

3. The collision that gives rise to this action occurred in Greenville County, South Carolina.

4. This Honorable Court has jurisdiction of the parties and subject matter of this action, and venue is proper.

5. On or about December 6, 2016 at approximately 4:15 PM, Plaintiff, driving a 2016 Ram Truck, was traveling north on US 25. Defendant, while driving a 2004 Mazda attempted to make a left turn on US 25 from S 1018. Defendant failed to yield the right of way and pulled out directly in front of Plaintiff, causing a collision.

6. As a direct and proximate result of the collision, Plaintiff suffered injuries and damages as set forth hereinbelow.

PLAINTIFF’S CAUSE OF ACTION

(NEGLIGENCE)

7. Plaintiff incorporates herein by reference each and every allegation set forth hereinabove as if repeated verbatim.

8. Defendant, at the time and place in question, was negligent, grossly negligent and reckless in the following particulars, to wit:

(a) In failing to keep a proper lookout;

(b) In driving while distracted;

(c) In failing to stop, swerve, slow down or take other evasive action to avoid the collision;

(d) In failing to yield the right of way;

(e) In failing to act as a ordinary and prudent driver would have acted under the circumstances then and there existing.

9. As a direct and proximate result of the aforementioned acts of negligence, gross negligence and reckless ness on behalf of Defendant, Plaintiff suffered injuries to her person, including injuries to her neck and back that required expensive medical care and treatment.

10. As a further direct and proximate result of the aforementioned acts of negligence, gross negligence and recklessness on behalf of Defendant, Plaintiff endured pain, suffering and loss of enjoyment of life.

WHEREFORE, Plaintiff prays for judgment against Defendant for actual damages and, if warranted by facts learned through discovery, punitive damages in amount to be determined by the court at the trial of this case, for the costs of this action, and for such other and further relief as this honorable Court deems just and proper.

HARRISON WHITE, PC

s/ Wes A. Kissinger

Wes A. Kissinger

S.C. Bar No.: 13949

178 West Main Street (29306)

P. O. Box 3547 (29304)

Spartanburg, South Carolina

(864) 585-5100

Attorneys for Plaintiffs

November 7, 2019

Spartanburg, South Carolina

Dec. 11, 18, 25

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PUBLIC NOTICE

SC Department of Health

and Environmental Control

Bureau of Water

2600 Bull Street

Columbia, South Carolina 29201

Public Notice No. 19-118-N Date: December 18, 2019

NOTICE OF PROPOSED ISSUANCE OF A

NATIONAL POLLUTANT DISCHARGE

ELIMINATION SYSTEM PERMIT

The following applicant has applied for a National Pollutant Discharge Elimination System (NPDES) permit to discharge treated wastewater into waters of the State of South Carolina. The proposed NPDES permit contains effluent limitations on the amounts of pollutants allowed to be discharged, based upon preliminary staff review and application of the Federal Clean Water Act, the SC Pollution Control Act, and other lawful standards and appropriate regulations. The pollutant limitations and other permit conditions are tentative and open to comment from the public.

APPLICANT: LIBERTY ASSETS LLC, FACILITY NAME: LIBERTY ASSETS LLC (PICKENS COUNTY/GREENVILLE EQC OFFICE), NPDES permit #SC0049352, 2541 N PLEASANTBURG DR STE S272, GREENVILLE, SC 29609. The facility is located at 101 Mills Avenue, Liberty, South Carolina, Pickens County. The proposed facility has 1 discharge point: 001-industrial wastewater pond that previously treated process wastewater, sanitary wastewater, cooling water and boiler blowdown and stormwater, discharging to: unnamed tributary to Eighteen Mile Creek. The Standard Industrial Classification (SIC) Code for the facility is 2269. The receiving streams are classified Class FW: freshwaters suitable for primary and secondary contact recreation and as a source for drinking water supply after conventional treatment in accordance with the requirements of the Department. Suitable for fishing and the survival and propagation of a balanced indigenous aquatic community of fauna and flora. Suitable also for industrial and agricultural uses. A fact sheet is available.

The Department has received certification from the Appalachian Council of Governments that this proposed discharge permit is in conformance with the approved Water Quality Management Plan (208 Plan) for their area. The Department has made the preliminary decision, based on this certification, that this discharge complies with Section D.(2), Antidegradation of the State Water Quality Standards in that it is necessary to important economic or social development. This notice provides for additional intergovernmental coordination on this proposed decision.

Persons wishing to comment on or object to permit issuance or to the proposed permit limitations and conditions are invited to submit same in writing within thirty (30) days of the date of this notice to the attention of: Ms. Melanie Townley; SC DHEC; Water Facilities Permitting Division; 2600 Bull Street, Columbia, South Carolina 29201; Telephone: 803-898-4223. The permit number should be placed at the top of the first page of comments. When there is a significant degree of public interest in a proposed permit or group of permits, the Department may hold a public hearing. SC DHEC is not involved in zoning, land use, or property value issues. Please contact your local County or Municipal officials for questions or concerns on these issues.

All comments received within the 30-day period will be considered in the formulation of final determinations regarding the permit. All persons submitting written comments will be notified of the final determinations. Requests for adjudicatory hearings may be filed after the above described determinations have been made. Additional information regarding adjudicatory hearings is available from the Legal Office at the above Department address or by calling 803-898-3350.

Additional information on proposed permit determinations and on hearing procedures is available by writing or calling the Department at the above address or telephone number. Copies of a specific application or draft permit of interest to an individual, organization, or company must be requested in writing. A fee schedule has been established for processing these requests: Reproduction of documents – $0.25 per page. Requests must be mailed to the Freedom of Information Office at 2600 Bull Street, Columbia, SC 29201, phone number: 803-898-3882; or requests may be faxed to the Freedom of Information Office at 803-898-3816. Arrangements can be made to review all the permit information at the Freedom of Information Office on the third floor of the Sims Building across from Peeples Auditorium.

Please bring the foregoing to the attention of persons you know will be interested in this matter.

Dec. 18

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SUMMONS AND NOTICE

STATE OF SOUTH CAROLINA

COUNTY OF PICKENS

IN THE COURT OF COMMON PLEAS

2019-CP-39-01436

Tiger Solutions LLC, Plaintiff, Vs. David Tidwell, Federal Home Loan Mortgage Corporation, Bank of America, N.A., “John Doe”, representing a class made up of all unknown parties who may claim some right, title or interest in the property located at Tax Map # 5019-15-64-9558, hereafter “the subject property”, and “Richard Roe”, representing a class made up of all infants and other disabled persons who may claim some right, title or interest in the subject property, Defendants

YOU ARE HEREBY SUMMONED and required to answer the Complaint in this action, (which Complaint was filed on October 29, 2019) and to serve a copy of your Answer to this Complaint upon subscriber at 11 Whitsett Street, Greenville, South Carolina 29601, within thirty (30) days after the service hereof, exclusive of the date of such service. If you shall fail to answer the Complaint within that time, the Plaintiffs shall proceed in default proceedings against you and shall apply to the Court for the relief demanded in the Complaint.

TO: INFANT(S) OVER FOURTEEN YEARS OF AGE (AN IMPRISONED PERSON)

YOU ARE FURTHER SUMMONED AND NOTIFIED to apply for the appointment of a Guardian ad Litem to represent you in this action within thirty (30) days after the service of this Summons and Notice upon you.

TO: INFANTS(S) UNDER FOURTEEN YEARS OF AGE (INCOMPETENT OR INSANE) AND TO ,(GENERAL TESTAMENTARY GUARDIAN)(COMMITTEE) WITH WHOM S(HE) RESIDE(S):

YOU ARE FURTHER SUMMONED AND NOTIFIED to apply for the appointment of a guardian ad Litem to represent said infant(s) under fourteen years of age (said incompetent or insane person) within thirty (30) days after the service of this Summons and Notice upon you.

YOU WILL FURTHER TAKE NOTICE that Charles W. Crews, Jr., 125 A Woodruff Place, Simpsonville, SC 29681, phone number 864-675-9581, has been appointed Guardian ad Litem for “John Doe” and “Richard Roe”, representing classes made up of all unknown parties (including unknown infants and disabled persons) who may have some right, title or interest in the subject property. In the event you are in one of the categories listed above and have a claim to the real property which is the subject of this action, more particularly described in the Lis Pendens, you should contact the appropriate Guardian ad litem listed above or your attorney. All persons under a disability have the right to have a Guardian ad litem of their choice appointed if the request is timely made to the Court.

LIS PENDENS

NOTICE IS HEREBY GIVEN that an action has been commenced in the Court upon complaint of Plaintiff against Defendants regarding quieting title of property located in Pickens County. The subject property is described as follows: All that piece, parcel or lot of land with improvements thereon situate, lying and being in the County of Pickens and the City of Easley known and designated as Lot 12 of Fairview Heights as shown on a survey for David Tidwell dated November 13, 2006 by Freeland Surveyors and Engineers recorded herewith in Plat Book 566, Page 2 –B, RMC Office for Pickens County, South Carolina. Reference to said plat is craved for the exact metes and bounds description. Tax Map # 5019-15-64-9558

C. Richard Stewart

Attorney for Plaintiff

11 Whitsett Street

Greenville, SC 29601

(864) 235-2019

SC Bar No: 5346

Dec. 18, 25 and Jan. 1

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SUMMONS AND NOTICE

STATE OF SOUTH CAROLINA

COUNTY OF PICKENS

IN THE COURT OF COMMON PLEAS

2019-CP-39-01442

Tiger Solutions LLC, Plaintiff, Vs. All unknown heirs of Lillie Maude Garry,Andrea Lynn Garry Williams, Andra Darryl Garry, “John Doe”, representing a class made up of all unknown parties who may claim some right, title or interest in the property located at Tax Map # 4098-05-28-1794, hereafter “the subject property”, and “Richard Roe”, representing a class made up of all infants and other disabled persons who may claim some right, title or interest in the subject property, Defendants

YOU ARE HEREBY SUMMONED and required to answer the Complaint in this action, (which Complaint was filed on October 30, 2019) and to serve a copy of your Answer to this Complaint upon subscriber at 11 Whitsett Street, Greenville, South Carolina 29601, within thirty (30) days after the service hereof, exclusive of the date of such service. If you shall fail to answer the Complaint within that time, the Plaintiffs shall proceed in default proceedings against you and shall apply to the Court for the relief demanded in the Complaint.

TO: INFANT(S) OVER FOURTEEN YEARS OF AGE (AN IMPRISONED PERSON)

YOU ARE FURTHER SUMMONED AND NOTIFIED to apply for the appointment of a Guardian ad Litem to represent you in this action within thirty (30) days after the service of this Summons and Notice upon you.

TO: INFANTS(S) UNDER FOURTEEN YEARS OF AGE (INCOMPETENT OR INSANE) AND TO ,(GENERAL TESTAMENTARY GUARDIAN)(COMMITTEE) WITH WHOM S(HE) RESIDE(S):

YOU ARE FURTHER SUMMONED AND NOTIFIED to apply for the appointment of a guardian ad Litem to represent said infant(s) under fourteen years of age (said incompetent or insane person) within thirty (30) days after the service of this Summons and Notice upon you.

YOU WILL FURTHER TAKE NOTICE that Charles W. Crews, Jr., 125 A Woodruff Place, Simpsonville, SC 29681, phone number 864-675-9581, has been appointed Guardian ad Litem for the unknown heirs of Lillie Maude Garry, and for “John Doe” and “Richard Roe”, representing classes made up of all unknown parties (including unknown infants and disabled persons) who may have some right, title or interest in the subject property. In the event you are in one of the categories listed above and have a claim to the real property which is the subject of this action, more particularly described in the Lis Pendens, you should contact the appropriate Guardian ad litem listed above or your attorney. All persons under a disability have the right to have a Guardian ad litem of their choice appointed if the request is timely made to the Court.

LIS PENDENS

NOTICE IS HEREBY GIVEN that an action has been commenced in the Court upon complaint of Plaintiff against Defendants regarding quieting title of property located in Pickens County. The subject property is described as follows: All that certain piece, parcel or lot of land lying, situate and being in the State of South Carolina, County of Pickens, being shown and designated as Lot No. 108 on that certain plat prepared by Ray Dunn, dated March 30, 2000 and recorded in the RMC Office for Pickens County, South Carolina in Plat Book 383 at Page 14, and having the same courses and distances as will appear by reference to said plat. Tax Map # 4098-05-28-1794

C. Richard Stewart, SC Bar #5346

Attorney for Plaintiff

11 Whitsett Street

Greenville, SC 29601

(864) 235-2019

dstewart@attorneyrichardstewart.com

Dec. 18, 25 and Jan. 1

_______________________________________

NOTICE

To: The Unknown Owner

The following vehicle has been abandoned at 110 W Lee Street. There is a lien on this vehicle for towing and storage in the amount of $67,820 plus any available rent from the date of this notice. Contact Smith Automotive at (864) 887-3752 to claim this vehicle

After 30 days from the date of this notice, Smith Automotive will apply to sell the vehicle at the Pickens County Magistrate for public sale.

Description:

Year: 2013

Make: Dodge

Model: 1500

Serial Number: 3C6JB6AT406557041

Dec. 18

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