STATE OF SOUTH CAROLINA COUNTY OF KERSHAW IN THE FAMILY COURT, FIFTH JUDICIAL CIRCUIT Albert Eugene Davis, Jr. and Sandra Ellen Davis, Plaintiffs, vs. David S. Banks, Jr. (Father), Defendant. IN RE: Mylez (DOB 11/3/2009), a minor under the age of eighteen (18) years. 2026-DR-28-00190 To Defendant: YOU ARE HEREBY SUMMONED and required to appear and defend the within action (for termination of parental rights and adoption) and to answer the Complaint herein of which a copy is herewith served upon you, and to serve a copy of your answer to said Complaint on the subscriber at their office located at 302 E. Saint John St., Spartanburg, South Carolina, 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, then judgment by default will be rendered against you for the relief demanded in the Complaint. James Fletcher Thompson THOMPSON DOVE LAW GROUP, LLC Post Office Box 1853 Spartanburg, South Carolina 29304 (864) 573-5533 Jim@TDLawGroup.com ATTORNEY FOR PLAINTIFFS Plaintiffs respectfully allege: 1. Plaintiffs' Information: Albert Eugene Davis, Jr. is 76 years of age; Sandra Ellen Davis is 71 years of age. The Plaintiffs live in Kershaw County, South Carolina, residing at 32 Emery Hill Road, Elgin, South Carolina 29045. The Plaintiffs were married on June 30, 1984 in Enterprise, Alabama. 2. Child's Information: The minor Defendant, Myles, is an African-American male child, born on November 3, 2009 in Pineville, North Carolina. 3. Plaintiffs' Relationship to Child: The Plaintiffs are the maternal grandparents of the minor child. 4. Action Seeking Adoption: It is the sincere desire of the Plaintiffs to establish a relationship of parent and child with the minor Defendant and the Plaintiffs are fit and proper persons, fully capable of caring for the child and providing for the child's welfare. 5. Proper Jurisdiction and Venue: This action was properly brought before this Court pursuant to the requirements of South Carolina Code Section 63-9-40, and this Court has jurisdiction over this matter and the parties hereto and venue is proper. 6. Value of Property Owned by Child: To the best of the Plaintiffs' knowledge, Mylez owns no property, either real or personal, in the State of South Carolina or elsewhere except for miscellaneous personal effects which have a nominal value. 7. Biological Mother's Information: The biological mother of the child is Latisha Banks, who currently resides at 13 Katie Springs Court, Elgin, South Carolina 29045. Her date of birth is July 12, 1978. 8. Biological Father's Information: The biological father of the child is David S. Banks, Jr. His last known address is 743 PortPatrick Place, Fort Mill, South Carolina 29708. His date of birth is July 13,1986. 9. Biological mother has consented to the adoption: Plaintiffs allege that the biological mother has voluntarily signed a document in which she has consented to the termination of her parental rights to the child, and this document is filed herewith. The consent document complies with South Carolina Law. In this document the biological mother consents for the minor Defendant to be adopted. She has waived her right to be named as a Defendant to an action to terminate her parental rights and/or an action for adoption of the child. The biological mother's parental rights should be terminated based on her validly executed consent. 10. Grounds for termination of parental rights of the Biological Father: Pursuant to South Carolina Code Sections 63-7-2570, the biological father's parental rights in and to the child should be terminated. The grounds justifying such termination are as follows: a. Pursuant to South Carolina Code Section 63-7-2570(3), the child has lived outside the home of the parent for a period of time exceeding six (6) months, during which time the biological father; (i) has willfully failed to visit the minor child; and (ii) has willfully failed to maintain contact with the minor child. b. Pursuant to South Carolina Code Section 63-7-2570(4), the child has lived outside the home of the parent for a period of over six months and during that time the biological father has willfully failed to support the child. 11. John Doe: Plaintiffs' Counsel will search the South Carolina Responsible Father Registry. If the birth father (John Doe) failed to register, this failure constitutes an implied irrevocable waiver of the father's right to notice of the adoption proceedings. If a birth father has registered, the Plaintiffs will serve him with notice of adoption proceedings. The Plaintiffs allege upon information and belief that John Doe and the biological mother are not married to each other. John Doe has not maintained substantial and continuous or repeated contact with the minor child in that he has not paid a fair and reasonable sum for support, has not visited or had regular communication with the minor child. Plaintiffs allege the consent of John Doe is not required pursuant to South Carolina Code Section 63-9-310(A)(4). Further, the parental rights of John Doe should be terminated pursuant to South Carolina Code Section 63-7-2570(3) failure to visit, Section 63-7-2570(4) failure to support, and Section 63-7-2570(7) abandonment. 12. Prior court orders regarding custody and/or visitation: There is a Final Order, filed October 2, 2018, in Case ID# 2017-DR-46-1483. In this order, visitation for the Defendant father, Davis S. Banks, Jr. remains suspended, as he has not undergone the required psychological evaluation and he did not participate in this matter at all. 13. Adoption Investigations and Reports: The Plaintiffs request that the Court waive the pre-placement and post-placement investigations, medical and social history for the child and the accounting in that the Plaintiffs duly believe that these are not required pursuant to South Carolina Code Section 63-9-1110. 14. Expenses Paid are Legally Authorized: During the last five years, there have been no payments or promises to pay money or anything of value, by or on behalf of the Plaintiffs to any person or organization regarding this proposed adoption other than Plaintiffs' payment of those costs and expenses which may legitimately be paid under South Carolina Code Sections 16-3-1060 and 63-9-310. 15. Special Needs Child: On information and belief, the minor child is a special needs child, as defined in South Carolina Code Section 63-9-30(10). WHEREFORE, the Plaintiffs pray for the following: A. For the parental rights of the biological mother and biological father of the minor Defendant to be terminated; B. That the parental rights of any John Doe birth father, who may now or any time in the future make a claim to the child, to be terminated; C. That the Plaintiffs be permitted to adopt the minor Defendant; for the relationship of parent and child between the Plaintiffs and minor Defendant to be established; and for the records of these proceedings to be sealed; D. For an Order of this Court directing that a birth certificate be issued showing the Plaintiffs as the parents of the minor Defendant; and, E. For such other and further relief as the Court may deem just and proper. James Fletcher Thompson THOMPSON DOVE LAW GROUP, LLC Post Office Box 1853 Spartanburg, South Carolina 29304 (864) 573-5533 Jim@TDLawGroup.com ATTORNEY FOR PLAINTIFFS MARCH 24, 2026 IPL0351383 Jun 21,28,Jul 5 2026