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STATE OF SOUTH CAROLINA COUNTY OF BERKELEY IN THE FAMILY COURT OF THE NINTH JUDICIAL CIRCUIT CASE # 2025-DR-08-1809 BRETT CORNELL and SUSAN CORNELL, Plaintiffs, v. ANGELICA CORNELL, STEVEN CORNELL A/K/A STEVEN PRINCE and SOUTH CAROLINA DEPARTMENT OF HEALTH AND HUMAN SERVICES, Defendants. IN THE INTEREST OF: STEVEN CORNELL, JR., DOB 07/17/2015 SUMMONS TO: THE DEFENDANT, STEVEN CORNELL A/K/A STEVEN PRINCE ABOVE-NAMED OR HIS ATTORNEY: 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 filed Answer to the said Complaint on the Plaintiff or their attorney, ERNIE L. MIXON at his office, 107 South Live Oak Drive, Moncks Corner, South Carolina, 29461, within thirty (30) days after the service thereof, exclusive of the day of such service. COMPLAINT The Plaintiffs would show unto this Honorable Court as follows: (1) That the Plaintiffs are citizens and residents of the County of Berkeley, State of South Carolina and have been so for more than one (1) year. (2) That the Defendant Angelica Cornell is also a resident of the County of Berkeley, State of South Carolina. (3) That upon information and belief the Defendant Steven Cornell A/K/A Steven Prince is a citizen and resident of Utica, Michigan. (4) Upon information and belief the Defendant South Carolina Department of Health and Human Services (SCDHHS) is a state agency located in Columbia, South Carolina. (5) The Plaintiff Brett M. Cornell is seventy-one (71) years of age and Plaintiff Susan J. Cornell is seventy-five (75) years of age. Both parties are in good physical health and are the paternal grandparents of the minor child. (6) The Plaintiffs have been married since May 3, 1983 and the minor child has resided with the Plaintiffs since at least June 7, 2017 when they were given permanent legal and physical custody of the minor child by Judge Monet Pincus by final order dated June 7, 2017, Case # 2017-DR-18-288. (7) That the Defendants were not married and they are the natural parents of the minor child. (8) The Plaintiffs do not have criminal records; have never been investigated by the Department of Social Services or similar agency for abuse of a child or adult, but solely for the placement of this child; have never been entered any registry as a sexual perpetrator, have not been in bankruptcy; have never been treated for alcohol or drug issues and have no mental health history. The Plaintiffs have no physical or mental health issues that would affect their ability to their ability to provide continued care for the minor child. They have never been the victims or perpetrators of domestic violence and have not been denied a passport. They are not on any registry as a suspected terrorist. (9) The minor child, Steven Cornell, Jr., was born on July 17, 2015 in North Charleston, South Carolina and is a white male. He is not known by any other name. (10) That this is an action for termination of parental rights of the Defendants for the following grounds pursuant to Section 63-07-2570, Code of Laws of South Carolina, 1976 as amended. (11) That the Plaintiffs are informed and believe the Defendants have both failed to see or support the minor child for a period in excess of six (6) months having not seen the minor child since July 19, 2017 and has never supported the minor child. (12) That the Plaintiffs are informed and believe the parental rights of the Defendants be terminated due to nonsupport and failure to visit the minor child. (13) It is the sincere desire of the Plaintiffs to establish the relationship of parent and child with the minor child and that the Plaintiffs are fit and proper persons, fully capable to care for the child and to provide for the child and to provide for the child’s welfare. (14) That upon information and belief the minor child is not losing any real or personal property by this adoption. (15) That the Plaintiffs have not paid or promised a fee, compensation, or anything of value as consideration for the consent or relinquishment for the purpose of adoption. (16) That the Plaintiffs are informed and believe a Guardian ad Litem should be appointed for the protection of the minor child. (17) That the Plaintiffs are informed and believe that due to the familial relationship of the Plaintiffs to the minor Defendants that any Preplacement, Postplacement or other reports should be suspended, and further that no other waiting periods or filings be found to be necessary to complete this adoption. (18) That the minor child has the genetic markers for Huntington’s Disease and Plaintiff’s are informed and believe he should have Medicaid coverage for such disease for his lifetime. WHEREFORE, the Plaintiffs would pray this Honorable Court as follows: A) For an Order terminating the parental rights of the Defendants Angelica Cornell and Steven Cornell A/K/A Steven Prince. B) For an Order allowing the adoption of the minor child by the Plaintiffs. C) For an Order directing that the birth certificate be amended showing the Plaintiffs as the Mother and Father of the minor child. D) Waiving any additional reports or waiting periods. E) Appointing a Guardian ad Litem to represent the interests of the minor child of this action. F) That the said Defendant South Carolina Department of Health and Human Services be ordered to provide lifetime Medicaid coverage for the minor child due to the Huntington’s Disease genetic markers. G) For such other and further relief as this Honorable Court deems just and proper. Ernie L. Mixon, SC Bar # 4014 Attorney for Plaintiffs 107 South Live Oak Drive Moncks Corner, SC 29461 (843) 761-6475 erniemixon@hotmail.com October 16, 2025 Moncks Corner, South Carolina Filed on: September 22, 2025 Guardian Ad Litem for the minor child: Percy Beauford, Bar #: 12578 204 N Live Oak Drive Moncks Corner, SC 29461 (843) 899-5555 pblawoffice@yahoo.com