STATE OF SOUTH CAROLINA
COUNTY OF AIKEN
Case No.:2026-CP-02-00563
IN THE COURT OF COMMON PLEAS
SECOND JUDICIAL CIRCUIT
AMENDED SUMMONS AND NOTICE OF FILING OF AMENDEND COMPLAINT
Joseph Delance Robinson
Plaintiff,
vs.
K. Warren Fulghum, in his official capacity of Aiken, Gisele Golden, Sondra Golden, Clarence Brown aka Clarence Brown, Sr., deceased, Clarence Brown, Jr., as heir at law of Clarence Brown Sr., Mose Brown aka Moses Brown, Sr., deceased, Mabel R. Brown, deceased, Clem Brown, Sr., deceased, Clem Brown, Jr., Barbara Brown, Linda Tillman, Sheila Merriweather aka Doretha Merriweather, Ruby Thomas, Angela Glover, Rachel Drumming, Clifford Brown, John B. Brown, deceased, Rosa B. Mims, Deceased, Teresa Jennings, Viola Brown, Gloria Brown, Roy Brown, Johnny Brown, Stanley Brown, Ronald McKie, Donald McKie, Moses Brown Jr., deceased, Marnivia Brown, deceased, Curtis Brown, Thomas Brown, Leon M. Brown, Oneal Brown, Joan Tyler, Loretta B. Hynes, Lynette B. Boham aka Lynette B. Bonham, Willie L. Brown, John E. Brown, Sammy Lee Brown aka Sammie Brown, Alice Mae Thomas, Helen Leaverette, deceased, Steve Leaveratte, Sonja Leaverette, Ollie Leaverette Jr.,Vickie Leaverette, Dana Leaverette, Brian Leaverette, Sr., Roderic Leaverette, Ernest Brown, deceased, Michael Anthony Brown, Demorris Brown, Terry Brown, Earnest Brown, Dekota Brown, Pamela Brown, Jeffrey Battle, Rhonda Brown, Alonzo Brown, Mozelle Jones, Martha A. Johnson, Jimmy L. Brown, and Bennie Lee Brown, as heirs at law of Mose Brown aka Moses Brown Sr., Their successors, heirs and assigns, and also all other firms and corporations entitled to claim under, by or through thee above named Defendants; and all other persons or entities, title, interest, estate in or lien upon the real estate described herein; and also any unknown adults being as a class designated as John Doe; and also any unknown infants or persons under disability being as a class designated as Richard Roe,
Defendants.
TO THE DEFENDANTS ABOVE-NAMED:
YOU ARE HEREBY SUMMONED AND REQUIRED to answer the Amended 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 undersigned attorney, within thirty (30) days after service hereof, exclusive of the day of such service at 115 D. Library Hill Lane, Lexington, South Carolina, 29072. In the event 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 ARE HEREBY GIVEN FURTHER NOTICE that should you fail to answer the foregoing Amended Summons and Amended Complaint, the Plaintiff will move for a general Order of Reference of this cause of action to The Honorable M. Anderson Griffith, Master in Equity for Aiken County, or to such special referee as this case may be assigned, to hear the within matter, which Order shall, pursuant to Rule 53 of the South Carolina Rules of Civil Procedure, specifically provide that the said Master or special referee, shall be authorized and empowered to enter a final judgment in this cause with appeal, if any, to the South Carolina Supreme Court.
TO THE DEFENDANTS ABOVE NAMED:
YOU WILL PLEASE TAKE NOTICE that the original Amended Summons and Amended Complaint in the above-entitled action were filed in the Office of the Clerk of Court for Aiken County, South Carolina on the 11th day of March 2026 and are now on file in said office.
Notice to minor Defendants and to persons with whom they reside, and to all Defendants laboring under any legal disability, or persons in the military service herein designated by the name Richard Roe and to their General or Testamentary Guardian or Guardians, if any:
Please take notice that you are hereby required to have a Guardian ad Litem appointed to represent your interest in the above-entitled action within thirty (30) days after the service of this Summons and Notice upon you, exclusive of the day of service; and in case you fail to have such Guardian ad Litem appointed within said time, the Plaintiff will apply to the Court for the appointment of such Guardian ad Litem to represent your interest in the suit.
AMENDED LIS PENDENS
Notice is hereby given that an action has been commenced and is now pending in the Court of Common Pleas for Aiken County upon the Complaint of the Plaintiff above named seeking a Declaratory Judgment to quiet title to the property described herein below in the name of the Plaintiff.
All that certain piece, parcel or tract of land lying, being approximately one (1) miles West of Graniteville, in the County of Aiken, State of South Carolina, containing 2.74 acres, more or less, as shown upon a plat prepared by Jones and Murph, PLS, dated December 15, 1984 and recorded in Misc. Book 551 at Page 49 in the Office o the Register of Deeds for Aiken County, South Carolina. Reference is hereby made to said plat for a more complete and accurate description as to metes, bounds, location and distances of the property herein conveyed.
LESS all that certain piece, parcel or tract of land with any improvements thereon, situate, lying and being in the County of Aiken, State of South Carolina, being know and designated as Lot A, containing 0.35 acres, more or less, as shown upon a plat made for Anthony Brown and Walter Bryant by Tripp land Surveying, Inc. dated February 25, 2025 and recorded in Plat Book 67 at Page 44, records of Aiken County, South Carolina. Reference being made to said plat for a more complete and accurate description as to metes, bounds and location of said easement.
TOGETHER WITH and SUBJECT TO a non-exclusive easement for the purpose of ingress, egress, and regress, thirty feet (30') in width, from Old Cherokee Indian Road over Tract A to Tract 3, as shown upon the aforementioned plat.
This being a portion of the property conveyed to Joseph Delance Robinson by deed of Rufort Perry Brown dated December 5, 2019 and recorded December 9, 2019 in the Office of the Register of Deeds for Aiken County in Deed Book 4816 at Page 1089.
TMS # 049-19-06-002
PROPERTY ADDRESS:
201 Old Cherokee Indian Road
Graniteville, SC 29829
s/Nicole Carson
Nicole Carson, Esquire Jonathan D. Moore, Attorney at Law 115 D. Library Hill Lane Lexington, SC 29072 Attorney for Plaintiff
May 14, 2026
Lexington, South Carolina
May 19, 26, June 2 2026
LGSC0520491
