SUMMONS AND

NOTICE OF FILING COMPLAINT

STATE OF SOUTH CAROLINA

COUNTY OF PICKENS

IN THE COURT OF COMMON PLEAS

CA No. 2025-CP-39-00263

Stephen Tradd Cotter and Irene Dubin, Plaintiffs, vs. John T. Morgan; Barbara J. Morgan, if not deceased; if deceased, then Barbara J. Morgan’s and any other deceased parties’, Heirs, Devisees Personal Representatives, Successors, Assigns, Spouses, and Creditors, and all others claiming through her or them any right, title,  estate, interest in or lien upon the real estate described in the Complaint herein, including any unknown adults, minors, or persons under legal disability, being a class designated as John Doe, and including any unknown persons in the Military service of the United States of America, being a class designated as Mary Doe; also all other persons unknown, claiming any right, title, estate, interest in or lien upon the real estate described in the Complaint herein, including any unknown adults, minors, or persons under legal disability, being a class designated as John Roe, including any unknown persons in the Military Service of the United States of America, being a class designated as Mary Roe; Synovus Bank, successor by merger to The National Bank of South Carolina; The Cliffs at Keowee Vineyards Community Association, Inc.; the Pickens County Delinquent Tax Collector, and the Pickens County Treasurer, Defendants.

TO THE DEFENDANT(S):

Barbara J. Morgan

Unknown parties and/or heirs, and all others claiming any right, title or interest in the subject real property, above, being as a class designated as John Doe, Mary Doe, John Roe, and Mary Roe;

YOU ARE HEREBY SUMMONED and required to answer the Complaint herein, a copy of which is herewith served upon you, and to serve a copy of your answer to said Complaint upon the subscriber, at his office at 133 Straight Drive, Anderson, South Carolina 29625, 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, Plaintiff(s) will apply to the Court for judgment by default for the relief demanded in the Complaint.

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, application for such appointment will be made by the Plaintiff(s) 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 IS HEREBY GIVEN that the original Summons and original Complaint in the above entitled action were filed in the Office of the Clerk of Court for Pickens County on March 3, 2025.

s/Michael S. Chambers

SC Bar No. 1178

Attorney for the Plaintiff(s)

 133 Straight Drive

Anderson, S.C. 29625

(864) 222-0292

Mike@BKRLaw.net

NOTICE OF ORDER

APPOINTING COUNSEL AND

GUARDIAN AD LITEM NISI

TO: THE DEFENDANTS HEREIN, NAMES AND ADDRESSES UNKNOWN, BEING AS A CLASS DESIGNATED AS JOHN DOE, MARY DOE, JOHN ROE, AND MARY ROE, INCLUDING ANY THEREOF WHO MAY BE MINORS, IMPRISONED PERSONS, INCOMPETENT PERSONS, UNDER OTHER LEGAL DISABILITY OR IN THE MILITARY, IF ANY, WHETHER RESIDENTS OR NON-RESIDENTS OF SOUTH CAROLINA AND TO THE NATURAL, GENERAL, TESTAMENTARY GUARDIAN OR COMMITTEE, OR OTHERWISE, AND TO THE PERSON WITH WHOM THEY MAY RESIDE, IF ANY THERE BE:

PLEASE TAKE NOTICE that a Motion for an Order and an Order appointing Kelley Yarborough Woody, Esquire, as Counsel and Guardian ad Litem Nisi, for all persons whomsoever herein collectively designated as John Doe, Mary Doe, John Roe, and/or Mary Roe, Defendants herein, names and addresses unknown, including any thereof who may be minors, imprisoned persons, incompetent persons, in the military service or under other legal disability, whether residents or non-residents of South Carolina, was filed in the Office of the Clerk of Court for Pickens County, South Carolina.

YOU WILL FURTHER TAKE NOTICE that unless the said minors or persons under other legal disability, if any, 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 either of them, a Counsel and/or Guardian ad Litem to represent them for the purposes of this action, the appointment of said Counsel and/or Guardian ad Litem Nisi shall be made absolute.

s/Michael S. Chambers

SC Bar No. 1178

Attorney for the Plaintiff(s)

33 Straight Drive

Anderson, S.C. 29625

Mike@BKRLaw.net

 April 2, 9, 16