SECOND AMENDED SUMMONS
STATE OF SOUTH CAROLINA
COURT OF COMMON PLEAS FOR
FOURTEENTH JUDICIAL CIRCUIT
COUNTY OF BEAUFORT
CIVIL ACTION NO: 2024-CP-07-1250
Johnnie Brown and Sharon Brown,
Plaintiffs,
vs.
The Heirs of Annie Mae Green Bennett,
The Heirs of Eleanor Bennett Brown, The
Heirs of Tyrone Smith, The Heirs of
Elizabeth Scott Lovell, The Heirs of
Marjie Green a/k/a Margie Green, The
Heirs of Martha Lee Brown, The Heirs of
Annie Mae Gadson, The Heirs of
Catherine J. Green, and all heirs persons
unknown claiming by, under or through
any of the above-named persons, JOHN
DOE and MARY ROE, being fictitious
names designating a class of persons, or a
legal entity, infants, incompetents, persons
in the military service, if any, known or
unknown, who may be an heir, distributee,
devisee, legatee, issue, alienee,
administrator, executor, creditor, successor
or assign having or claiming to have any
right, title, interest, estate in or lien upon
the real estate described in the Second
Amended Complaint herein, Martha Lee
Brown, Shirley Green Menefee, Henry
Green, Joseph Green, Katie Mae Gavins,
Phylis Johnson Green a/k/a Phyliss
Johnson, Jeanette Green Aiken, Sam
Green, Jr., Beaufort County, a political
subdivision of the State of South
Carolina, Bluffton Eagles Community Action
Committee, and BHBL Properties LLC,
Defendants.
TO: THE ABOVE-NAMED DEFENDANTS:
YOU ARE HEREBY SUMMONED and required to answer the Complaint in this action, a copy of which is herewith served upon you, and to appear, defend and serve a copy of your Answer to said Complaint on the subscriber at the office of Going | Ward, LLC, 25 Clark Summit Drive, Suite 102, Bluffton, South Carolina 29910, within thirty (30) days after the service hereof, exclusive of the day of such service; and in case of your failure to do so judgment by default will be rendered against you for the relief demanded in this Complaint.
Respectfully submitted,
GOING | WARD, LLC
s/Jason W. Ward
SC Bar #72928
25 Clark Summit Drive, Suite 102
Bluffton, South Carolina 29910
Jason@goingward.com
Tel: (843) 706-2896
Fax: (843) 706-2894
Attorney for the Plaintiffs
IPL0257997
Jul 29,Aug 4,11 2025