STATE OF SOUTH CAROLINA
COUNTY OF YORK
IN THE COURT OF COMMON PLEAS
CASE NO.: 2025-CP-46-01622
Nationstar Mortgage LLC, Plaintiff, v. Frank L. McCloskey; Geraldine C. McCloskey; South Carolina Department of Motor Vehicles, Defendant(s).
SUMMONS
Foreclosure Deficiency Judgment Waived
(Non-Jury) Foreclosure of Mortgage
TO THE DEFENDANTS NAMED ABOVE:
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 Complaint upon the persons whose names are subscribed below, at 3550 Engineering Drive, Suite 260, Peachtree Corners, GA 30092, within thirty (30) days (except the United States of America, or any Agency or Department thereof, shall Answer the Complaint in this action within sixty (60) days) after the service hereof, exclusive of the day of such service; and if you fail to answer the Complaint within the time aforesaid, judgment by default will be rendered against you for the relief demanded in the Complaint.
YOU WILL ALSO TAKE NOTICE that the undersigned attorneys, on behalf of the Plaintiff herein, will seek an Order of Reference to the Master in Equity for York County, South Carolina, with final appeal to the South Carolina Supreme Court or the Court of Appeals as provided by the South Carolina Appellate Court Rules, pursuant to Rule 53 of the South Carolina Rules of Civil Procedure.
To minors over fourteen (14) years of age, and/or to minors under fourteen (14) years of age and the person(s) with whom the minors reside, and/or to person(s) 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 upon you. If you fail to do so, application for such appointment will be made by McMichael Taylor Gray, LLC.
YOU WILL ALSO TAKE NOTICE that, under the provisions of Section 29-3-100 of the South Carolina Code of Laws, effective June 16, 1993, any collateral assignments of rents contained in the Mortgage are perfected and the Plaintiff hereby gives notice that all rents shall be payable directly to it by delivery to its undersigned attorneys from the date of default. In the alternative, McMichael Taylor Gray, LLC, will move before a judge of this Circuit on the 10th day of service hereof, or as soon thereafter as counsel may be heard, for an Order enforcing the assignment of rents, if any, and compelling payment of all rents covered by such assignment directly to the Plaintiff, which motion is to be based upon the original Note and Mortgage, and the Complaint attached hereto.
NOTICE OF FILING COMPLAINT
YOU WILL PLEASE TAKE NOTICE that the Lis Pendens, Summons, and Complaint were filed in the Office for the Clerk of Court for York County on April 17, 2025.
McMichael Taylor Gray, LLC
January N. Taylor (SC Bar #80069), jtaylor@mtglaw.com
J. Pamela Price (SC Bar #14336), pprice@mtglaw.com
Shannon Kaufman (SC Bar #102548), skaufman@mtglaw.com
3550 Engineering Drive, Suite 260
Peachtree Corners, GA 30092
Telephone: (404) 474-7149
Facsimile: (404) 745-8121
Attorneys for Plaintiff
IPL0260643
Aug 6,13,20 2025