SUMMONS AND NOTICE OF FILING OF COMPLAINT(NON-JURY MORTGAGE FORECLOSURE)C/A NO: 2025-CP-04-02908DEFICIENCY WAIVED IN THE COURT OF COMMON PLEAS STATE OF SOUTH CAROLINACOUNTY OF ANDERSON Freedom Mortgage Corporation,PLAINTIFF,vs.John Lee AND IF John Lee be deceased then any child and heir at law to the Estate of John Lee distributees and devisees at law to the Estate of John Lee and if any of the same be dead any and all persons entitled to claim under or through them also all other persons unknown claiming any right, title, interest or lien upon the real estate described in the complaint herein; Any unknown adults, any unknown infants or persons under a disability being a class designated as John Doe, and any persons in the military service of the United States of America being a class designated as Richard Roe; Davine E Williams, Individually and as Personal Representative of Estate of John Lee; Cassandra M McDowney, Individually and as Personal Representative of Estate of John Lee; David L Williams II; Alice M Dodd; Solar Mosaic, Inc aka Solar Mosaic, LLC; Bank of America, N.A.; Deja Dodd; J.D., a minor; James A Dodd, Jr AND IF James A Dodd, Jr be deceased then any child and heir at law to the Estate of James A Dodd, Jr distributees and devisees at law to the Estate of James A Dodd, Jr and if any of the same be dead any and all persons entitled to claim under or through them also all other persons unknown claiming any right, title, interest or lien upon the real estate described in the complaint herein; Any unknown adults, any unknown infants or persons under a disability being a class designated as John Doe, and any persons in the military service of the United States of America being a class designated as Richard Roe,DEFENDANT(S)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, or otherwise appear and defend, and to serve a copy of your Answer to said Complaint upon the subscriber at his office, Foundation Legal Group, P.O. Box 8237, Columbia, SC 29202, within thirty (30) days after service hereof, except as to the United States of America, which shall have sixty (60) days, exclusive of the day of such service, and if you fail to answer the Complaint within the time aforesaid, or otherwise appear and defend, the Plaintiff in this action will apply to the Court for the relief demanded therein, and judgment by default will be rendered against you for the relief demanded in the Complaint.TO MINOR(S) OVER FOURTEEN YEARS OF AGE, AND/OR TO MINOR(S) UNDER FOURTEEN YEARS OF AGE AND THE PERSON WITH WHOM THE MINOR(S) RESIDES, AND/OR TO PERSONS 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 and Notice upon you. If you fail to do so, application for such appointment will be made by the Plaintiff immediately and separately and such application will be deemed absolute and total in the absence of your application for such an appointment within thirty (30) days after the service of the Summons and Complaint upon you.YOU WILL ALSO TAKE NOTICE that should you fail to Answer the foregoing Summons, the Plaintiff will move for an Order of Reference of this case to the Master-in-Equity/Special Referee in/for this County, which Order shall, pursuant to Rule 53 of the South Carolina Rules of Civil Procedure, specifically provide that the said Master-in-Equity/Special Referee is authorized and empowered to enter a final judgment in this case with appeal only to the South Carolina Court of Appeals pursuant to Rule 203(d)(1) of the SCACR, effective June 1, 1999.NOTICE OF FILING OF SUMMONS AND COMPLAINTTO THE DEFENDANTS ABOVE NAMED:YOU WILL PLEASE TAKE NOTICE that the foregoing Summons, along with the Complaint, was filed with the Clerk of Court for Anderson County, South Carolina, on December 10, 2025 and the Amended Summons and Complaint were filed on February 10, 2026.NOTICE TO APPOINT ATTORNEY FOR DEFENDANT(S) IN MILITARY SERVICETO UNKNOWN OR KNOWN DEFENDANTS THAT MAY BE IN THE MILITARY SERVICE OF THE UNITED STATES OF AMERICA ALL BEING A CLASS DESIGNATED AS RICHARD ROE:YOU ARE FURTHER SUMMONED AND NOTIFIED that Plaintiff's attorney has applied for the appointment of an attorney to represent you. If you fail to apply for the appointment of an attorney to represent you within thirty (30) days after the service of this Summons and Notice upon you Plaintiff's appointment will be made absolute with no further action from Plaintiff.THIS IS A COMMUNICATION FROM A DEBT COLLECTOR. THE PURPOSE OF THIS COMMUNICATION IS TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE, EXCEPT AS STATED BELOW IN THE INSTANCE OF BANKRUPTCY PROTECTION.IF YOU ARE UNDER THE PROTECTION OF THE BANKRUPTCY COURT OR HAVE BEEN DISCHARGED AS A RESULT OF A BANKRUPTCY PROCEEDING, THIS NOTICE IS GIVEN TO YOU PURSUANT TO STATUTORY REQUIREMENT AND FOR INFORMATIONAL PURPOSES AND IS NOT INTENDED AS AN ATTEMPT TO COLLECT A DEBT OR AS AN ACT TO COLLECT, ASSESS, OR RECOVER ALL OR ANY PORTION OF THE DEBT FROM YOU PERSONALLY.s/ Ashley Z. Stanley April 22, 2026 John S. Kay S.C. Bar #7914Ashley Z. Stanley (S.C. Bar No. 74854)Alan Stewart (S.C. Bar No. 15576)Sarah O. Leonard (S.C. Bar No. 80165)Gregory Wooten (S.C. Bar No. 73586)M. Celeste Bowers (S.C. Bar No. 100981)Attorneys for PlaintiffFoundation Legal Group240 Stoneridge DriveSuite 400Columbia, SC 29210(803) 726-2700john.kay@thefoundationlegalgroup.comashley.stanley@thefoundationlegalgroup.comalan.stewart@thefoundationlegalgroup.comsarah.leonard@thefoundationlegalgroup.comgreg.wooten@thefoundationlegalgroup.comceleste.bowers@thefoundationlegalgroup.comMay 6, 13, 20, 2026
