SUMMONS, COMPLAINT AND LIS PENDENS
IN THE COURT OF COMMON PLEAS FOURTH JUDICIAL CIRCUIT
C/A NO: 2023CP1700245
STATE OF SOUTH CAROLINA COUNTY OF DILLON
Vera Bethea, Plaintiff vs. Johnnie M. Vereen, Estate of Woodrow Vereen, Estate of Roland Vereen, Arthur Vereen, Jr., Lillie Mae V. Jones, Eliza V. Lewis; John Doe, representing all persons unknown claiming any legal or equitable interest, in the real property with Dillon County Tax Map Number 104-11-01-011; Jane Roe, representing any known or unknown minors, or persons under a legal disability, or persons serving in the military having or claiming to have any right, title, interest, or lien on or to the lands described herein; also, all other persons unknown, claiming any right, title, estate, interest in or lien upon the real estate described in the Complaint herein, Defendants: SUMMONS AND SUMMARY OF COMPLAINT TO: THE DEFENDANTS Johnnie M. Vereen, Estate of Woodrow Vereen, Estate of Roland Vereen, Arthur Vereen, Jr., Lillie Mae V. Jones, Eliza V. Lewis; John Doe 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 said Complaint on the subscriber at PO Box 1686, 204 North First Avenue, Dillon, SC 29536 within thirty (30) days from the service hereof, exclusive of such service; and in case of failure to do so, judgement by default will be rendered against you for the relief demanded in the Complaint. YOU WILL PLEASE TAKE NOTICE that the original Summons, Complaint and Lis Pendens were filed with the Clerk of court for Dillon County on May 13, 2023 for purposes of quieting title, as described in the Complaint. SUMMARY OF COMPLAINT Plaintiff seeks a declaration that Plaintiff has acquired title to certain property in Dillon County through adverse possession, a declaration quieting title in her favor and related relief. The property is described as follows: All those two certain pieces, parcels or lots of land, with improvements, situate in Dillon County, South Carolina, and designated as Lot, Nos. 19 and 20 on a Map made by Johnson & Roberts, C. E?s., December, 1946, of Andrews Chapel, Latta, South Carolina, owned by R. E. Atkinson, which said Plat is recorded in the office of the Clerk of Court for Dillon County, South Carolina, in Plat . Book 4 at Page 96.This being the same property conveyed by Arthur Vereen to Lena G. Vereen for and during the term of her natural life, and upon her death to the children of Arthur Vereen, namely, Jannie Mae Vereen, Woodrow Vereen, Roland Vereen, Arthur Vereen, Jr., Ellie Mae V. Jones and Eliza V. Lewis by deed dated June 8, 1970 and recorded in the office of the Clerk of Court for Dillon County, in Deed Book 118 at Page 577A. Tax Map No.: 104-11-02-011 s/E. Leary McKenzie,
Attorney for the Plaintiff
McKenzie Law Firm PC
PO Box 1686
204 N. 1st Ave
Dillon, SC 29536
Phone: (843) 627-4235
Fax: (843) 773-2179
Email: leary@
mckenzielawfirmpc.com
February 13, 2024
Dillon, South Carolina