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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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

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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, 25, Jan. 1, 8

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SUMMONS AND NOTICE

OF ADOPTION PROCEEDINGS.

STATE OF SOUTH CAROLINA

COUNTY OF PICKENS

IN THE FAMILY COURT

OF THE THIRTEENTH JUDICIAL CIRCUIT

CASE NO: 2019-DR-39-0728

STANLEY JOHNSON AND ABIGAIL WAGES-JOHNSON, Plaintiffs, versus KELLY AARON AND JASON MARGENGILL; AND BABY BOY LIAM, A MINOR UNDER THE AGE OF SEVEN (7) YEARS OF AGE, 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 subscribers at their offices, Building Families LLC, 1122 Lady Street, Suite 1103, 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, the Plaintiffs in this action will apply to the Court for the relief demanded in the Complaint. Additionally, this Summons serves to give you Notice of Adoption Proceedings pursuant to S.C. Code Ann. Section 63-9-730. If Notice to Contest, Intervene, or otherwise Respond to these adoption proceedings if filed by you with the Court within thirty (30) days of receipt of this Notice of Adoption Proceedings, you will be given the opportunity to appear and be heard on the merits of the adoption. To file Notice to Contest, Intervene, or otherwise Respond in this action, you must notify the above-named Court at the Pickens County Courthouse, 214 East Main Street, Pickens, South Carolina 29671 in writing of your intention to Contest, Intervene, or otherwise Respond. The above-named Court must be informed of your current address and any changes of your address during the adoption proceedings. You are on notice that your failure to respond within thirty (30) days of receipt of this Notice of Adoption Proceedings constitutes your consent to adoption and forfeiture of all your rights and obligations to the above-named child. This notice is given pursuant to S.C. Code Ann. Section 63-9-730(E).

NOTICE IS HEREBY GIVEN that the original Summons and Complaint in the above entitled action was filed in the office of the Clerk of Court for Pickens County on August 19, 2019 at 3:43 p.m.

S\Allison Bullard McNair, Esquire,

Building Families LLC,

1122 Lady Street, Suite

1103, Columbia, South Carolina

29201, 803-862-0207 (t)

888-838-5157 (f),

allie@buildingfamiliessc.com.

Dec. 25, Jan. 1, 8

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SUMMONS AND NOTICE

OF ADOPTION PROCEEDINGS.

STATE OF SOUTH CAROLINA

COUNTY OF CHARLESTON

IN THE FAMILY COURT

OF THE NINTH JUDICIAL CIRCUIT

CASE NO: 2019-DR-10-2939

JANE AND JOHN DOE, Plaintiffs, versus KELLY AARON, STANLEY JOHNSON, ABIGAIL WAGES-JOHNSON; AND BABY GIRL MCKENZIE, A MINOR UNDER THE AGE OF SEVEN (7) YEARS OF AGE, 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 subscribers at their offices, Building Families LLC, 1122 Lady Street, Suite 1103, 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, the Plaintiffs in this action will apply to the Court for the relief demanded in the Complaint. Additionally, this Summons serves to give you Notice of Adoption Proceedings pursuant to S.C. Code Ann. Section 63-9-730. If Notice to Contest, Intervene, or otherwise Respond to these adoption proceedings if filed by you with the Court within thirty (30) days of receipt of this Notice of Adoption Proceedings, you will be given the opportunity to appear and be heard on the merits of the adoption. To file Notice to Contest, Intervene, or otherwise Respond in this action, you must notify the above-named Court at the Charleston County Courthouse, 100 Broad Street, #143, Charleston, South Carolina 29401 in writing of your intention to Contest, Intervene, or otherwise Respond. The above-named Court must be informed of your current address and any changes of your address during the adoption proceedings. You are on notice that your failure to respond within thirty (30) days of receipt of this Notice of Adoption Proceedings constitutes your consent to adoption and forfeiture of all your rights and obligations to the above-named child. This notice is given pursuant to S.C. Code Ann. Section 63-9-730(E).

REDACTED COMPLAINT: THE PLAINTIFFS WOULD RESPECTFULLY SHOW UNTO THE COURT: The Plaintiffs are XXX and XXX. They reside at XXX. Both Plaintiffs are citizens and residents of Charleston County, State of South Carolina. The Plaintiffs are husband and wife having been married on December 5, 2009. XXX is forty-two (42) years of age having been born on March 30, 1977 in Savannah, Georgia; XXX forty (40) years of age having been born in Provo, Utah. The Defendants Stanley Johnson and Abigail Wages-Johnson are the maternal aunt and uncle of the minor child. They have legal custody of the minor child pursuant to an Order for Removal dated October 5, 2016 under Docket Number 16-DR-39-608. Defendants Stanley Johnson and Abigail Wages-Johnson are residents of Pickens County, State of South Carolina. The Defendant Kelly Aaron is the biological mother of the minor child Baby Girl Mckenzie. Defendant Kelly Aaron’s whereabouts are unknown. The biological father of the minor child, Baby Girl Mckenzie, is unknown and no man is listed on her birth certificate. The minor child is a Caucasian, female child who was born on February 4, 2014 in Easley, State of South Carolina. For the purposes of this action, she is known as Baby Girl Mckenzie. Plaintiffs desire to change the minor child’s name to McKenzie Leigh XXX, and request that they be permitted to use this name pending the final adoption. The Court has both personal and subject matter jurisdiction over these parties and this action. Venue is proper in Charleston County pursuant to S.C. Code Ann. Section 63-9-40. Defendants Stanley Johnson and Abigail Wages-Johnson sought an adoptive placement for the minor child because they are no longer able to care for the minor child. Defendants Stanley Johnson and Abigail Wages-Johnson felt good about the Plaintiffs and the home they could provide for the minor child. Defendants Stanley Johnson and Abigail Wages-Johnson asked the Plaintiffs to take custody of the minor child for the purpose of adoption. Defendants Stanley Johnson and Abigail Wages-Johnson signed a Durable Power of Attorney document on August 1, 2019 allowing Plaintiffs to care for the minor child and placed the child in their physical custody at that time. Upon information and belief, as the current legal custodians of the minor child, Defendants Stanley Johnson and Abigail Wages-Johnson consent to the placement of the minor child with Plaintiffs for the purpose of custody and adoption. Upon information and belief, Defendant Kelly Aaron’s parental rights should be terminated pursuant to S.C. Code Ann. Section 63-7-2570 (3), (4), and (7). Defendant Kelly Aaron’s parental rights should be terminated pursuant to S.C. Code Ann. Section 63-7-2570(3) due to the fact the minor child has lived outside of her home for a period in excess of six (6) months and she has willfully failed to visit the child. Defendant Kelly Aaron’s parental rights should be terminated pursuant to S.C. Code Ann. Section 63-7-2570(4) in that the minor child has lived outside of her home for a period in excess of six (6) months and she has willfully failed to support the child. Finally, Defendant Kelly Aaron’s parental rights should be terminated pursuant to S.C. Code Ann. Section 63-7-2570(7) because she has abandoned the child. Since paternity of the minor child has not been conclusively determined, 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) has not maintained substantial and continuous or repeated contact with the minor Defendant in that he has not paid support for the minor Defendant, has not visited the minor Defendant or had regular communication with the minor Defendant. Plaintiffs allege the consent of John Doe is not required pursuant to S.C. Code Ann. Section 63-9-310. Further, the parental rights of John Doe should be terminated pursuant to S.C. Code Ann. Section 63-7-2570(7). The required pre-placement report has been filed with these pleadings. A post placement investigation report will be submitted to the Court prior to the final hearing. That to the best of the knowledge of the Plaintiffs, the minor Defendant owns no real property of any value either real or personal, in the State of South Carolina or elsewhere. That the Plaintiffs, XXX and XXX, desire to establish the relationship of parents and daughter with the minor Defendant and that the Plaintiffs are fit and proper persons, fully capable to care for the child and to provide for the child’s welfare in that they are biologically related to the minor child. The appointment of a Guardian ad Litem, by this Court, to protect the interests of the minor child. WHEREFORE, the Plaintiffs pray for: The termination of parental rights of the biological parents; The adoption of the minor child by the Plaintiffs XXX and XXX to be approved by the Court and for the State Registrar to issue a birth certificate showing the parents of the minor child to be the Plaintiffs; The records of these proceedings be sealed; After the passage of at least three (3) months following the filing of this Complaint, and the filing of a post placement report and accounting, for an Order of this Court directing that a birth certificate be issued in the name of MCKENZIE LEIGH XXX showing the Plaintiffs as the parents of the minor Defendant; and Such other and further relief as the Court may deem just and proper.

NOTICE IS HEREBY GIVEN that the original Summons and Complaint in the above entitled action was filed in the office of the Clerk of Court for Charleston County on August 21, 2019 at 4:55 p.m.

S\Allison Bullard McNair, Esquire,

Building Families LLC,

1122 Lady Street, Suite 1103,

Columbia, South Carolina 29201,

803-862-0207 (t)

888-838-5157 (f),

allie@buildingfamiliessc.com.

Dec. 25, Jan. 1, 8

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LEGAL NOTICE

The Pickens County Planning Commission will meet in regular session and conduct a public hearing on Monday, January 13, 2020 at 6:30 p.m. in the Main Conference Room at the Pickens County Administration Facility, 222 McDaniel Avenue, Pickens, SC.

Prior to the regular meeting and public hearing, the Planning Commission will meet in a worksession at 6:00 p.m. in the same location.

The Planning Commission will hold public hearings on the following items:

1. SD-19-0008 Subdivision Land Use for a 49 lot, single-family residential development, Hinton Farms (re-designed), located on Hinton Road, Easley. The proposed development is located on approximately 36.50 acres. The applicant and property owner of record is Distinguished Design, LLC.

TMS# 5130-16-51-4888

More information for each item is available in the Planning Office in the Department of Community Development and is open for public inspection during regular business hours. If any member of the public requires special assistance please call 864-898-5956.

Dec. 25

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