FOURTH AMENDED SUMMONS-(Declaratory...
FOURTH AMENDED...
STATE OF SOUTH CAROLINA - COUNTY OF CHARLESTON - IN THE COURT OF COMMON PLEAS - NINTH JUDICIAL CIRCUIT - CASE#: 2021-CP-10-02617 - - ROBERT J. SEIGLER TRUST (ROBERT J. SEIGLER, TRUSTEE), - Plaintiff, - v. - PETER LAURIE AND CINDY FLOYD; NARINE RAMLOGAN AND CARMEL RAMLOGAN; SIMMONS CREEK-JOHNS ISLAND, LLC; FREDERICK HOPE TIMMS, ANTONIO D. NELSON, SR., HAROLD W. NELSON, JR, MARK NELSON, SR., AMBER JOI NELSON, LARRY NELSON, CHERYL D. NELSON, EPHRIAM BUTLER, GEORGE MINUS, JAMES NELSON a/k/a JAMES E. NELSON, JOSHUA BUTLER, KALEB BUTLER, KAVONNA BUTLER, KHALYA BUTLER, LATONYA MINUS, OTIS ALFRED FREEMAN, SHERONDA MINUS, SOLOMON BUTLER, VERNETTE NELSON BROWN, AARON A. LEGARE, BENZINA FLUDD WASHINGTON, BONITA LEGARE, CARL BROWN, CHARLES LEGARE, CLARA FLUDD, DARCELLA LEGARE, EUGENE LEGARE, JR., GEORGETTA LEGARE, HEZKIAH B. FLUDD, JEROME FLUDD, LINCOLN LE GARE, III, LOUISE LEGARE WELLS, MARVEL LE GARE, MARY LOUISE LEGARE HARRIS, METTIE CHAPMAN, MICHAEL FLUDD, NATALIE FRANKLIN, NATHANIEL LEGARE, NICOLE CHAPMAN, PHLLIS DOWDELL, QUEEN ESTER HOLT, ROSALYN DAVIS a/k/a ROSALYN GARRETT, RUBIN LEGARE, RUTH RICE, SEQUOIA CAMPBELL, SHERINA WILBURN, VERMELL DOCTOR, YVONNE LEGARE, ZORELL HEYWARD FLUDD, JOSEPH LEE RICHARDSON if they be alive, JOHN DOE, AND JANE DOE, whose true names are unknown and fictitious names designating the unknown heirs, devisees, distributees, issue, executors, administrators, successors, or assigns of the above named Defendants, if they or any of them be dead; and of EDWARD NELSON, FRED NELSON, FRED NELSON, JR., FRED NELSON III, HAROLD W. NELSON, SR., JAMES S. NELSON, JUNITA LINDA RICHARDSON a/k/a JUANITA NELSON RICHARDSON a/k/a JUANITA LINDA RICHARDSON a/k/a LINDA MINUS RICHARDSON, KAREN NELSON BUTLER, NAOMI LOTTIE FREEMAN NELSON, ROBERT LOWRY, LOUISE COLES LOWRY LEGARE, EDWARD LEGARE, SR., BERNARD FLUDD, MOZELLE FLUDD WILBURN, ROBERT LEGARE, EUGENE S. LEGARE, DAISY BELL WILSON LEGARE, EDWARD LEGARE, JR., MARIE LEGARE, CATHALEEN LEGARE CHAPMAN, LINCOLN LEGARE a/k/a LINCOLN PAUL LE GARE, ASALEE LEGARE, GILBERT LEGARE, CLEMENT LEGARE, SR., CLEMENT LEGARE, JR., CATHERINE LEGARE a/k/a INEZ LEGARE DUKES, WILHELMINA LEGARE a/k/a VIOLA LEGARE, all deceased; and MARY ROE AND RICHARD ROE, whose true names are unknown and fictitious names designating infants, persons under disability, incompetents, imprisoned, or those persons in the military, if any; and also all other persons, known or whose true names are unknown, claiming any right, title, interest in, or lien upon the real estate described in the Fourth Amended Complaint herein, - Defendants. - - FOURTH AMENDED SUMMONS - (Declaratory Judgement) - (Non-Jury) - - TO THE ABOVE-NAMED DEFENDANTS SIMMONS CREEK-JOHNS ISLAND LLC and all of Nelson family heirs: - YOU ARE HEREBY SUMMONED and required to answer the Fourth Amended Cross-Claim herein, a copy of which is herewith served upon you, and to serve a copy of your answer to this complaint on the subscriber, at the address shown below, within thirty (30) days after service hereof if service upon you was in person and thirty-five (35) days after service hereof if service upon you was by U.S. Mail, exclusive of the day of such service; and if you fail to answer the Fourth Amended 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 Fourth Amended Complaint. In addition, your answer should be filed with the court within five (5) days after service thereof. - - 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 Fourth Amended 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 Fourth Amended Summons and Fourth Amended Cross Complaint upon you. - - January 16, 2024 - Charleston, SC - - FIFTH AMENDED SUMMONS - (Declaratory Judgment) - (Non-Jury) - - TO THE ABOVE-NAMED DEFENDANTS SIMMONS CREEK-JOHNS ISLAND LLC by their attorneys: - Ainsley Fisher Tillman and Ian S. Ford, To NELSON FAMILY MEMBERS: LARRY NELSON, by his attorneys Kenneth Allen Davis and Charles J. Boykin: other NELSON family members: ANTONIO D. NELSON, SR., HAROLD W. NELSON, JR, MARK NELSON, SR., AMBER JOI NELSON, CHERYL D. NELSON, EPHRIAM BUTLER, GEORGE MINUS, JAMES NELSON a/k/a JAMES E. NELSON, JOSHUA BUTLER, KALEB BUTLER, ICAVONNA BUTLER, KHALYA BUTLER, LATONYA MINUS, OTIS ALFRED FREEMAN, SHERONDA MINUS, SOLOMON BUTLER, VERNETTE NELSON BROWN and JOSEPH LEE RICHARDSON. In addition, any deceased NELSON family members: EDWARD NELSON, FRED NELSON, FRED NELSON, JR., FRED NELSON III, HAROLD W. NELSON, SR., JAMES S. NELSON, JUNITA LINDA RICHARDSON A/K/A JUANITA NELSON RICHARDSON, KAREN NELSON BUTLER, NAOMI LOITIE FREEMAN NELSON or any unknown heirs by court appointed attorneys: Charles Mac Gibson Jr and Lana Marie Jamrosyk representing for RICHARD ROE, MARY ROE, JANE DOE, AND JOHN DOE. - YOU ARE HEREBY SUMMONED and required to answer the Fourth Amended Cross-Claim herein, a copy of which is herewith served upon you, and to serve a copy of your answer to this complaint on the subscriber, at the address shown below, within thirty (30) days after service hereof if service upon you was in person and thirty-five (35) days after service hereof if service upon you was by U.S. Mail, exclusive of the day of such service; and if you fail to answer the Fourth Amended 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 Fourth Amended Complaint. In addition, your answer should be filed with the court within five (5) days after service thereof. - - 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 Fifth Amended 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 Fifth Amended Summons and Fourth Amended Cross Complaint upon you. - - Vaughan Law Firm, PA s/ W. Barnwell Vaughan - W. Barnwell Vaughan, S.C. Bar No. 6449 - 102 Wappoo Creek Dr, Suite 2 - Charleston, SC 29412 - P: 843-762-7825 - wbv@vaughanlawfirm.net - Attorneys for the Defendants Ramlogans - - January 22, 2024 - Charleston, South Carolina
STATE OF SOUTH CAROLINA - COUNTY OF CHARLESTON - IN THE COURT OF COMMON PLEAS - NINTH JUDICIAL CIRCUIT - CASE#: 2021-CP-10-02617 - - ROBERT J. SEIGLER TRUST (ROBERT J. SEIGLER, TRUSTEE), - Plaintiff, - v. - PETER LAURIE AND CINDY FLOYD; NARINE RAMLOGAN AND CARMEL RAMLOGAN; SIMMONS CREEK-JOHNS ISLAND, LLC; FREDERICK HOPE TIMMS, ANTONIO D. NELSON, SR., HAROLD W. NELSON, JR, MARK NELSON, SR., AMBER JOI NELSON, LARRY NELSON, CHERYL D. NELSON, EPHRIAM BUTLER, GEORGE MINUS, JAMES NELSON a/k/a JAMES E. NELSON, JOSHUA BUTLER, KALEB BUTLER, KAVONNA BUTLER, KHALYA BUTLER, LATONYA MINUS, OTIS ALFRED FREEMAN, SHERONDA MINUS, SOLOMON BUTLER, VERNETTE NELSON BROWN, AARON A. LEGARE, BENZINA FLUDD WASHINGTON, BONITA LEGARE, CARL BROWN, CHARLES LEGARE, CLARA FLUDD, DARCELLA LEGARE, EUGENE LEGARE, JR., GEORGETTA LEGARE, HEZKIAH B. FLUDD, JEROME FLUDD, LINCOLN LE GARE, III, LOUISE LEGARE WELLS, MARVEL LE GARE, MARY LOUISE LEGARE HARRIS, METTIE CHAPMAN, MICHAEL FLUDD, NATALIE FRANKLIN, NATHANIEL LEGARE, NICOLE CHAPMAN, PHLLIS DOWDELL, QUEEN ESTER HOLT, ROSALYN DAVIS a/k/a ROSALYN GARRETT, RUBIN LEGARE, RUTH RICE, SEQUOIA CAMPBELL, SHERINA WILBURN, VERMELL DOCTOR, YVONNE LEGARE, ZORELL HEYWARD FLUDD, JOSEPH LEE RICHARDSON if they be alive, JOHN DOE, AND JANE DOE, whose true names are unknown and fictitious names designating the unknown heirs, devisees, distributees, issue, executors, administrators, successors, or assigns of the above named Defendants, if they or any of them be dead; and of EDWARD NELSON, FRED NELSON, FRED NELSON, JR., FRED NELSON III, HAROLD W. NELSON, SR., JAMES S. NELSON, JUNITA LINDA RICHARDSON a/k/a JUANITA NELSON RICHARDSON a/k/a JUANITA LINDA RICHARDSON a/k/a LINDA MINUS RICHARDSON, KAREN NELSON BUTLER, NAOMI LOTTIE FREEMAN NELSON, ROBERT LOWRY, LOUISE COLES LOWRY LEGARE, EDWARD LEGARE, SR., BERNARD FLUDD, MOZELLE FLUDD WILBURN, ROBERT LEGARE, EUGENE S. LEGARE, DAISY BELL WILSON LEGARE, EDWARD LEGARE, JR., MARIE LEGARE, CATHALEEN LEGARE CHAPMAN, LINCOLN LEGARE a/k/a LINCOLN PAUL LE GARE, ASALEE LEGARE, GILBERT LEGARE, CLEMENT LEGARE, SR., CLEMENT LEGARE, JR., CATHERINE LEGARE a/k/a INEZ LEGARE DUKES, WILHELMINA LEGARE a/k/a VIOLA LEGARE, all deceased; and MARY ROE AND RICHARD ROE, whose true names are unknown and fictitious names designating infants, persons under disability, incompetents, imprisoned, or those persons in the military, if any; and also all other persons, known or whose true names are unknown, claiming any right, title, interest in, or lien upon the real estate described in the Fourth Amended Complaint herein, - Defendants. - - FOURTH AMENDED SUMMONS - (Declaratory Judgement) - (Non-Jury) - - TO THE ABOVE-NAMED DEFENDANTS SIMMONS CREEK-JOHNS ISLAND LLC and all of Nelson family heirs: - YOU ARE HEREBY SUMMONED and required to answer the Fourth Amended Cross-Claim herein, a copy of which is herewith served upon you, and to serve a copy of your answer to this complaint on the subscriber, at the address shown below, within thirty (30) days after service hereof if service upon you was in person and thirty-five (35) days after service hereof if service upon you was by U.S. Mail, exclusive of the day of such service; and if you fail to answer the Fourth Amended 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 Fourth Amended Complaint. In addition, your answer should be filed with the court within five (5) days after service thereof. - - 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 Fourth Amended 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 Fourth Amended Summons and Fourth Amended Cross Complaint upon you. - - January 16, 2024 - Charleston, SC - - FIFTH AMENDED SUMMONS - (Declaratory Judgment) - (Non-Jury) - - TO THE ABOVE-NAMED DEFENDANTS SIMMONS CREEK-JOHNS ISLAND LLC by their attorneys: - Ainsley Fisher Tillman and Ian S. Ford, To NELSON FAMILY MEMBERS: LARRY NELSON, by his attorneys Kenneth Allen Davis and Charles J. Boykin: other NELSON family members: ANTONIO D. NELSON, SR., HAROLD W. NELSON, JR, MARK NELSON, SR., AMBER JOI NELSON, CHERYL D. NELSON, EPHRIAM BUTLER, GEORGE MINUS, JAMES NELSON a/k/a JAMES E. NELSON, JOSHUA BUTLER, KALEB BUTLER, ICAVONNA BUTLER, KHALYA BUTLER, LATONYA MINUS, OTIS ALFRED FREEMAN, SHERONDA MINUS, SOLOMON BUTLER, VERNETTE NELSON BROWN and JOSEPH LEE RICHARDSON. In addition, any deceased NELSON family members: EDWARD NELSON, FRED NELSON, FRED NELSON, JR., FRED NELSON III, HAROLD W. NELSON, SR., JAMES S. NELSON, JUNITA LINDA RICHARDSON A/K/A JUANITA NELSON RICHARDSON, KAREN NELSON BUTLER, NAOMI LOITIE FREEMAN NELSON or any unknown heirs by court appointed attorneys: Charles Mac Gibson Jr and Lana Marie Jamrosyk representing for RICHARD ROE, MARY ROE, JANE DOE, AND JOHN DOE. - YOU ARE HEREBY SUMMONED and required to answer the Fourth Amended Cross-Claim herein, a copy of which is herewith served upon you, and to serve a copy of your answer to this complaint on the subscriber, at the address shown below, within thirty (30) days after service hereof if service upon you was in person and thirty-five (35) days after service hereof if service upon you was by U.S. Mail, exclusive of the day of such service; and if you fail to answer the Fourth Amended 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 Fourth Amended Complaint. In addition, your answer should be filed with the court within five (5) days after service thereof. - - 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 Fifth Amended 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 Fifth Amended Summons and Fourth Amended Cross Complaint upon you. - - Vaughan Law Firm, PA s/ W. Barnwell Vaughan - W. Barnwell Vaughan, S.C. Bar No. 6449 - 102 Wappoo Creek Dr, Suite 2 - Charleston, SC 29412 - P: 843-762-7825 - wbv@vaughanlawfirm.net - Attorneys for the Defendants Ramlogans - - January 22, 2024 - Charleston, South Carolina
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