STATE OF SOUTH CAROLINA IN THE COURT OF COMMON PLEAS COUNTY OF GEORGETOWN Trena Johnson, Plaintiff, vs. Roxie Rogers, Defendant. FIFTEENTH JUDICIAL CIRCUIT C.A. NO.: 2025CP2200939 SUMMONS TO: THE DEFENDANTS ABOVE NAMED: YOU ARE HEREBY SUMMONED and required to answer the Complaint herein, a copy of which is herewith served upon you, and to serve a copy of your Answer to the said Complaint on THE DERRICK LAW FIRM, at its office at Post Office Box 28, Conway, South Carolina, 29528, 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 Plaintiff will apply to the Court for the relief demanded in the Complaint and judgment by default will be rendered against you for the relief demanded in the Complaint. DATED this_ 29th day of September, 2025. The Derrick Law Firm s/Michael H. Ellis Michael H. Ellis, Esquire (101524) Attorney for the Plaintiff PO Box 28 Conway, SC 29528 843-248-7486 843-248-7510 mike.ellis@derricklawfirm.com COMPLAINT The plaintiff, Trena Johnson (hereinafter "Plaintiff"), by and through her undersigned counsel, complaining of the above-named Defendant would respectfully show to this Honorable Court as follows: That the plaintiff, Trena Johnson, is a resident of Murrells Inlet, Georgetown County, South Carolina. Plaintiff is informed and believes that the Defendant Roxie Rogers, is a citizen and resident of Murrells Inlet, Georgetown County, South Carolina. This Court has jurisdiction over all parties, matter, and things contained herein. FIRST CAUSE OF ACTION (STRICT LIABILITY, S. C. CODE §47-3-110) Plaintiff Trena Johnson hereby realleges and incorporates by reference the allegations of the above paragraphs as though set forth in full herein to the extent they are not inconsistent herewith. On or about May 24, 2025, Plaintiff Trena Johnson was lawfully on her own property located at 734 Nelson Drive, Murrells Inlet. At all times relevant to the matters alleged herein, Defendant Roxie Rogers resided at 748 Nelson Drive, Murrells Inlet.At all times relevant to the matters alleged herein, a female pit bull (hereinafter "the dog") lived at Defendant Roxie Rogers's residence at 748 Nelson Drive, Murrells Inlet.On May 24, 2025, the dog was in Defendant's care. On May 24, 2025, the dog was in Defendant's keeping.On May 24, 2025, Defendant had control over the dog.On May 24, 2025, Defendant had notice of a hole in her backyard fence.Defendant's other dog escaped through this hole in the backyard fence multiple times before May 24, 2025.On the evening of May 24, 2025, the dog was let out into Defendant's backyard.The dog escaped the backyard.On May 24, 2025 Plaintiff Trena Johnson was lawfully mowing her own yard at 734 Nelson Drive, Murrells Inlet.The dog entered Plaintiff's property.The dog lunged at Plaintiff, attacking Plaintiff.The dog dragged Plaintiff to the ground and bit her multiple times (hereinafter referred to as "the Attack").At the time of the Attack, the dog was in the care, keeping, and control Defendant.At the time of the Attack, the dog was not controlled or restrained by a leash, electric fence, or other means of secure fencing.Plaintiff Trena Johnson did not provoke or harass the dog in any way to cause the Attack. The Attack was not proximately caused by Plaintiff Trena Johnson's provocation or harassment of the dog.As a direct and proximate result of the Attack, Plaintiff Trena Johnson suffered extensive, severe, grievous, and permanent injuries to their person which have necessitated, and will in the future continue to necessitate, their receipt of medical treatment, and have caused and will in the future continue to cause Plaintiff Trena Johnson to incur extensive medical expenses;As a direct and proximate result of the Attack, Trena Johnson has suffered and will continue in the future to suffer extreme pain and suffering, permanent impairment, scarring, mental anguish, trauma, anxiety, distress and inconvenience, amongst other things for which she is entitled to recover damages from Defendant.For those reasons, Defendant is strictly liable for any and all injuries and damages Plaintiff Trena Johnson suffered as a proximate result of the Attack pursuant to the provisions of 1976 Code of Laws of South Carolina, § 47-3-110; that as a result thereof, the Plaintiff Trena Johnson is maintaining this action pursuant to 1976 Code of Laws of South Carolina, § 47-3-110, as amended, et seq.; and Plaintiff Trena Johnson is seeking recovery herein, against Defendant any and all damages sustained as a direct and proximate result of the Attack, plus such other and further relief as is provided by the above-referenced statute. SECOND CAUSE OF ACTION (Negligence/Gross Negligence/Recklessness) Plaintiff Trena Johnson hereby realleges and incorporates by reference the allegations of the above paragraphs as though set forth in full herein to the extent they are not inconsistent herewith.At all times relevant to the matters alleged herein, Defendant was the owner of the residence where the dog lived and was responsible for exercising control of the dog. On or about May 24, 2025, Plaintiff Trena Johnson was lawfully on her own property at 734 Nelson Drive, Murrells Inlet, in Georgetown County, South Carolina when the dog lunged at Plaintiff, attacking Plaintiff and biting her multiple times resulting in serious permanent injuries (hereinafter referred to as "the Attack").Defendant as the person in the possession, custody, care, keeping, and control of the dog at the time of the Attack, owed a duty to Plaintiff and to others to exercise reasonable care in controlling, securing, supervising, training, and restraining the dog to prevent the reasonably foreseeable risk of injury by the dog.Defendant knew or should have known that there was a hole in her backyard fence.Notwithstanding the above duties, and their prior actual knowledge of the dog's ability to escape the backyard, the Defendants negligently, gross negligently, carelessly and recklessly breached their duties of care to Plaintiff in each of the following particulars: (a) In allowing the dog wonder the neighborhood without proper supervision, control and/or restraint; (b) In failing to adequately secure, control and/or restrain the dog upon her premises; (c) In failing to institute and enact proper safeguards and/or protections to ensure the safety of others from the vicious and violent dog; (d) In failing to give proper notice to members of the public, and specifically, Plaintiff, warning them of the vicious dog on the premises; and, (e) In otherwise failing to act as a reasonable prudent person would have acted under like circumstances. As a direct and proximate result of Defendant's negligence, gross negligence, willful, wanton and reckless behavior, Plaintiff has sustained painful and permanent injuries to her person, forcing Plaintiff to incur numerous medical expenses.The Attack has caused Plaintiff to endure extreme pain and suffering, mental anguish, anxiety, trauma, and emotional distress, and to incur numerous psychological damages, all to Plaintiff's detriment. WHEREFORE, Plaintiff prays this Court enter judgment against Defendants for actual and punitive damages in an amount to exceed One Hundred Thousand and 00/100 Dollars, and for the costs of this action and for such other and further relief as this Honorable Court deems just, in an amount to be determined by a jury. The Derrick Law Firm s/Michael H. Ellis _______________________ Michael H. Ellis, Esquire 101524 Attorney for the Plaintiff PO Box 28 Conway, SC 29528 843-248-7486 843-248-7510 mike.ellis@derricklawfirm.com September 3, 2025 Conway, South Carolina IPL0277695 Oct 1,8,15 2025