STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS 2025-CP-45-00374 COUNTY OF WILLIAMSBURG Harold R. Tucker, Jr., Harold R. Tucker, III, and Quitman Hand, Plaintiffs, AMENDED SUMMONS QUIET TITLE (NON-JURY) Albert Bradshaw, Sheena Easley Green, John Doe and Mary Roe, representing as a class any and all infants, minors, incompetents, persons in prison, or under legal disability, unborn, including persons protected under the Soldiers and Sailors Relief Act, and/or persons or entities whomever or whatsoever claiming any right, title estate, interest in or lien upon the real estate described in the complaint herein, and any unknown persons who are under disability or are minors or who are in the military service. 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 Plaintiffs or their attorney, Jennifer R. Kellahan, Esquire, Jenkinson, Kellahan, Thompson & Reynolds, P.A., l20 West Main Street, Kingstree, South Carolina, 29556, 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 Judgment by default for the relief demanded in the Complaint. YOU WILL ALSO TAKE NOTICE THAT Plaintiff will move for an order of reference or that the Court may issue a general order of reference of this action to a master in equity/special referee, pursuant to Rule 53 of the South Carolina Rules of Civil Procedure. 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 Summons and Notice upon you. If you fail to do so, application for such appointment will be made by the Plaintiffs. AMENDED LIS PENDENS: NOTICE IS HEREBY GIVEN that an action will be commenced or is now pending in this court upon complaint of the Plaintiffs against these Defendants to quiet title to the real property described as follows: All that certain piece, parcel or lot of land situate in Hope Township, County of Williamsburg, State of South Carolina, designated as 11.50 acres, more or less, and bounded as follows: On the North now or formerly by Rev. J. W. Easley Estate, by lands now or formerly of Jessie Smith Estate and now or formerly of Whack Cemetery; on the East by lands now or formerly of Wesley Family Farms, LLC; on the South by Guess Road and Northwest now or formerly of Alice L. Easley. Said tract is more fully shown, described and delineated on a partition plat by Peter G. Gourdin, Surveyor, dated February 10, 1921, recorded in the Office of the Clerk of Court for Williamsburg County in Plat Book 19, at Page 63. This property was devised to Albert Bradshaw under the terms of the Last Will and Testament of Lizzie Bradshaw, whose estate is filed in the Office of the Probate Court for Williamsburg County in Book 80/8.TMS: 45-051-031. DATED at Kingstree, South Carolina, on this 21st day of August, 2025. s/Jennifer R. Kellahan Jennifer R. Kellahan, Esquire, SC Bar 7074 Hannah S. Heathcott, Esquire, SC Bar 105543 JENKINSON KELLAHAN THOMPSON & REYNOLDS, P. A. 120 West Main Street Post Office Drawer 669 Kingstree, SC 29556 Ph. (843) 355-2000 Attorneys for Plaintiffs
