SUMMONS

STATE OF SOUTH CAROLINA

COUNTY OF PICKENS

IN THE COURT OF COMMON PLEAS

THIRTEENTH JUDICIAL CIRCUIT

Pasui Real Estate Holdings, LLC, Plaintiff, vs. The H. Glen Smith cemetery, Pickens County, South Carolina, and all other persons unknown claiming any right, title, estate, interest in or lien upon the real estate described in the Complaint; any unknown adults, being as a class designated as John Doe, and any such unknown infants and/or persons under disability being as a class designated as Richard Roe, and any and all persons having any and all rights to utilize and access the cemetery as described In the Complaint, Defendants.

TO THE DEFENDANTS

NAMED HEREIN:

You are hereby summoned and required to answer the Complaint in this action a copy of which is attached hereto and herewith served upon you; and to serve a copy of your answer to this Complaint upon the subscriber at: Law Offices of Daniel E. Hunt, P.A., 502 North A Street, Post Office Box 887, Easley, SC 29641-0887, within thirty (30) days after the service hereof, exclusive of the day of such service; and if you fail to answer the Complaint within this thirty (30) day period, the Plaintiff will apply to the Court for the relief demanded in the Complaint and judgment will be taken against you by default.

In the event you are an infant over fourteen years of age or 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. If you fail to do so, application for such appointment will be made by the Plaintiff herein.

In the event you are an infant under fourteen years of age or are incompetent or insane, then you and the Guardian or Committee are further summoned and notified to apply for the appointment of a GUARDIAN AD LITEM to represent said infant under fourteen years of age or said incompetent or insane person 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 herein.

By: /s Daniel E. Hunt

Daniel E. Hunt, SC Bar No.: 2821

502 North A Street (zip 29640)

Post Office Box 887

Easley, South Carolina 29641-0887

Office: (864) 859-7127/

Fax: (864)859-2434

dhunt@danhuntlaw.com

February 12, 2020

Easley, South Carolina

April 29, May 6, 15

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 COMPLAINT

STATE OF SOUTH CAROLINA

COUNTY OF PICKENS

IN THE COURT OF COMMON PLEAS

THIRTEENTH JUDICIAL CIRCUIT

Pasui Real Estate Holdings, LLC, Plaintiff, vs. The H. Glen Smith cemetery, Pickens County, South Carolina, and all other persons unknown claiming any right, title, estate, interest in or lien upon the real estate described in the Complaint; any unknown adults, being as a class designated as John Doe, and any such unknown infants and/or persons under disability being as a class designated as Richard Roe, and any and all persons having any and all rights to utilize and access the cemetery as described In the Complaint, Defendants.

Plaintiff, by and through its Member, would respectfully show unto this honorable Court, as follows, to wit:

1. Plaintiff is a Limited Liability Company organized and existing under and by virtue of the laws of the State of South Carolina.

2. Plaintiff is the owner of a tract or parcel of land identified as a One and 60/100 acre (1.6) acre parcel as shown in Plat Book 596, at page 174, in the Office of the Register of Deeds, Pickens County, South Carolina. The parcel is further identified as Pickens County Tax Identification Number 5048-10-46-8468.

3. That Plaintiff purchased the property knowing that there was on the property, or adjacent thereto, a cemetery which is shown on the referenced plat of survey. However, there was prior to the survey by which Plaintiff took title, another survey recorded in Plat Book 57, at page 33, sometimes called page 33A, in the Office of the Register of Deeds, Pickens County, South Carolina which showed the cemetery to be larger.

4. Plaintiff would show that the cemetery as is now delineated on the Plat recorded in Plat Book 596, at page 174 has been set off and fenced in. Additionally, in compliance with the applicable law, Plaintiff has allowed any and all access to the cemetery and Plaintiff does now, and has from the time the property on which the cemetery sits was purchased, continued to maintain the cemetery. Plaintiff intends to continue to maintain the property in the future as well.

5. Plaintiff would show unto this Court, that in the cemetery are the remains of H. Glen Smith who departed this life on January 13, 1890, as well as his wife Martha Smith who passed away on April 28, 1904, as well as 5 of his grandchildren and a son, John A. Smith, the last person buried in the cemetery on December 3, 1918. All of the grandchildren were buried there prior to the December,1918 interment of John A. Smith. Plaintiff would show that property on which the graves were located was sold in 1916. Plaintiff would show that since that time, Plaintiff and its predecessors in title have owned and maintained the property free and clear of any claims of any persons, known and unknown, in the property other than as delineated in the surveys. All of this information was gleaned from a document prepared setting forth the persons interred.

6. Plaintiff would ask that this Court inquire into the matter and issue its Order setting forth the boundaries of the cemetery thereby quieting the title to the real estate and extinguishing any claims to extended boundaries of the cemetery.

7. Plaintiff is informed and believes that the accurate description of the property is as described on several plats of survey, including a survey recorded in Plat Book 470, at page 5-A, in the Office of the Register of Deeds, Pickens County, South Carolina, as well as a survey recorded in Plat Book 593, at page 190, in the Office of the Register of Deeds, Pickens County, South Carolina.

WHEREFORE, having fully set forth its Complaint, Plaintiff herein would request the following relief:

A. That this Court inquire into the matter and issue its Order whereby the lines of the above mentioned cemetery are delineated and set forth in the Plats of Survey recorded in Plat Book 593, at page 190, and plat of Survey recorded in Plat Book 596, at page 174, Office of the Register of Deeds, Pickens County, South Carolina, and that Plaintiff have title to all of the property as shown on the referenced Plats of Survey free and clear of any and all claims of any other persons; and

B. For such other and further relief as this Court deems just and proper.

s/Daniel E. Hunt

Daniel E. Hunt, S.C. Bar No. 2821

502 North A. Street, 29640

Post Office Box 887

Easley, South Carolina 29641-0887

Tel.: (864) 859-7127 /

Fax: (864) 859-2434

Email: dhunt@danhuntlaw.com

February 12, 2020

Easley, South Carolina

April 29, May 6, 15

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ORDER FOR SERVICE BY PUBLICATION

STATE OF SOUTH CAROLINA

COUNTY OF PICKENS

IN THE COURT OF COMMON PLEAS

THIRTEENTH JUDICIAL CIRCUIT

Pasui Real Estate Holdings, LLC, Plaintiff,vs. The H. Glen Smith cemetery, Pickens County, South Carolina, and all other persons unknown claiming any right, title, estate, interest in or lien upon the real estate described in the Complaint; any unknown adults, being as a class designated as John Doe, and any such unknown infants and/or persons under disability being as a class designated as Richard Roe, and any and all persons having any and all rights to utilize and access the cemetery as described In the Complaint, Defendants.

HAVING READ and filed the Petition of Daniel E. Hunt, attorney for the Plaintiff herein, and it appearing that this is an action to quiet title to real property located in Pickens County, South Carolina, and further, that no unknown Defendants have been found, after due diligence, within said County and State.

IT IS ORDERED that service in this matter be made on all unknown Defendants, if any, by publishing copies of the Summons, Notice of Filing of Complaint, and this Order, in a paper of general circulation in Pickens County, South Carolina, once weekly for three (3) consecutive weeks.

Clerk of Court or Circuit Court Judge

Pickens County, South Carolina

_____________, 2020

April 29, May 6, 15

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NOTICE OF HEARING

STATE OF SOUTH CAROLINA

COUNTY OF: PICKENS

IN THE PROBATE COURT

CASE NUMBER: 2020ES3900238

IN THE MATTER OF:

WALTER HAYNE BRAMLETT

(Decedent)

DATE: JUNE 24, 2020

TIME: 9:30 A.M.

PLACE: PICKENS PROBATE COURT,

222 MCDANIEL AVE., B-16,

PICKENS, SC 29671

PURPOSE OF HEARING*:

FORMAL APPOINTMENT

Executed this 29 day of APRIL, 2020.

Signature:

Print Name: J. BAKER CLEVELAND, III

Address: 859 PENDLETON STREET/ PO BOX 9

PICKENS, SC 29671

Telephone (Work):864-878-1184

E-mail: BAKER@ALHFIRM.COM

Relationship to Decedent/Estate:

ATTORNEY FOR THE ESTATE

NOTE: Probate Court recommends that all interested parties be represented by counsel licensed to practice law in South Carolina. If any interested party wishes to represent him/herself, he/she will be required to adhere to the South Carolina Rules of Civil Procedure and South Carolina Rules of Evidence.

*When sending Notice of Hearing to interested parties upon whom pleadings were not required to be served, attach the petition or motion to be held.

April 29, May 6, 15

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SUMMONS

STATE OF SOUTH CAROLINA,

COUNTY OF PICKENS

IN THE PROBATE COURT

CASE NO. 2020ES3900238

IN THE MATTER OF:

WALTER HAYNE BRAMLETT

Evelyn Monzel Anderson Petitioner,Walter Hayne Bramlett, Heirs Known And Unknown Respondents.

TO THE RESPONDENT(S) ABOVE-NAMED:

YOU ARE HEREBY SUMMONED and required to answer the Petition herein, a copy of which is herewith served upon you, and to serve a copy of your Answer to this Petition upon the subscriber, at the address shown below, within thirty (30) days after service hereof, exclusive of the day of such service, and if you fail to answer the Petition, judgment by default will be rendered against you for the relief demanded in the Petition.

Pickens, South Carolina

Dated: 4/13/2020

J. BAKER CLEVELAND, III

Petitioner/Attorney for Petitioner

859 Pendleton Street,

Pickens, SC 29671

April 29, May 6, 15

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PUBLIC NOTICE

Cellco Partnership and its controlled affiliates doing business as Verizon Wireless (Verizon Wireless) proposes to build a 38-foot pole Communications Tower at the approx. vicinity of 899 Old Stone Church Road, Clemson, Pickens County, South Carolina 28262. Public comments regarding potential effects from this site on historic properties may be submitted within 30 days from the date of this publication to: Trileaf Corp, Lauren Schramm l.schramm@trileaf.com, 1395 South Marietta Pkwy, Building 400 Suite 209, Marietta, GA 30067, 678-653-8673.

May 6

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