STATE OF SOUTH CAROLINA ) ) IN THE COURT OF COMMON PLEAS COUNTY OF PICKENS )

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1 STATE OF SOUTH CAROLINA IN THE COURT OF COMMON PLEAS COUNTY OF PICKENS Civil Action Number: 2017-CP-39- Vickie Stewart, individually and as Personal Representative of the Estate of Dickie Ray Stewart Plaintiff, vs. SUMMONS Albert Leon Bowen, deceased Brenda Bowen, Lisa Hudson, the Pickens County Sheriff s Office, an agency of Pickens County, and Pickens County, a political subdivision of the state of South Carolina, Defendants. TO THE DEFENDANTS ABOVE-NAMED: YOU ARE HEREBY SUMMONED and required to answer the Complaint in this action, a copy of which is hereby served upon you, and to serve a copy of your Answer to the said Complaint on the subscribers at their office, located at 1225 S. Church Street, Greenville, South Carolina, 29605, within thirty (30 days after service thereof exclusive of the day of such service, and if 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. 1

2 Greenville, South Carolina May 2, 2017 Respectfully Submitted, MOONEYHAM BERRY, LLC s/ Joe Mooneyham Joe Mooneyham, SC Bar # Todd Nichols, SC Bar # Post Office Box 8359 Greenville, South Carolina Fax joe@mbllc.com todd@mbllc.com Attorneys for Plaintiff 2

3 STATE OF SOUTH CAROLINA IN THE COURT OF COMMON PLEAS COUNTY OF PICKENS Civil Action Number: 2017-CP-39- Vickie Stewart, individually and as Personal Representative of the Estate of Dickie Ray Stewart Plaintiff, vs. COMPLAINT Jury Trial Requested Albert Leon Bowen, deceased Brenda Bowen, Lisa Hudson, the Pickens County Sheriff s Office, an agency of Pickens County, and Pickens County, a political subdivision of the state of South Carolina, Defendants. The plaintiff would respectfully show unto the court that: JURISDICTION AND VENUE 1. The plaintiff, Vickie Stewart, is a citizen and resident of Pickens, South Carolina and is the duly appointed Personal Representative of the Estate of Dickie Ray Stewart, deceased. She is the widow of Dickie Ray Stewart, who died on September 14, She brings this action individually and on behalf of the Estate of Dickie Ray Stewart, for damages individually and those recoverable pursuant to SC Code Ann (1976, as amended, for damages recoverable by the statutory beneficiaries of Dickie Ray Stewart pursuant to SC Code Ann , et. seq. (1976, as amended and pursuant to SC Code Ann , et seq. (2013, as amended. 1

4 2. Defendant Albert Leon Bowen, deceased, was formerly citizen and resident of Pickens County, South Carolina. 3. Defendant Brenda Bowen is, upon information and belief, a citizen and resident of Anderson County, South Carolina. 4. Defendant Lisa Hudson, upon information and belief, is a citizen and resident of Pickens County, South Carolina. 5. The plaintiff is informed and believes that the Defendant Pickens County Sheriff s Office is an agency of Pickens County, a political subdivision of the State of South Carolina, and that the Sheriff s Office is amenable to suit pursuant to S.C. Code, Ann., (2013, as amended. 6. The plaintiff is informed and believes that the Defendant Pickens County is a political subdivision of the State of South Carolina, and is amenable to suit pursuant to S.C. Code, Ann., (2013, as amended. 7. This Court has jurisdiction of the subject matter of the complaint and of the parties in this lawsuit. 8. Venue is proper in Pickens County pursuant to the venue provisions of the South Carolina Tort Claims Act and pursuant to S.C. Code, Ann., (2013, as amended. FACTS 9. At all times relevant to this action, Mr. and Mrs. Stewart resided at 419 Gilliland Road, Pickens, South Carolina. 10. At all times relevant to this action Mr. and Mrs. Bowen resided at 412 Gilliland Road, Pickens, South Carolina. 2

5 11. Upon information and belief, the Bowens moved into their residence in August The Bowens rented the residence from Lisa Hudson. Upon information and belief, Ms. Hudson failed to conduct any background or criminal history check on either of the Bowens before agreeing to rent them the residence. 12. Prior to 2014, Mr. Bowen had a significant criminal history including charges for Murder, Assault and Battery of a High and Aggravated Nature, Assault and Battery and Trespassing. 13. On or about September 13, 2015, William Isaacs, Jr. of 411 Gilliland Rd., Pickens, South Carolina contacted the Pickens County Sheriff s Office by telephone to complain that someone had fired several rounds from a gun into one of his vehicles that was parked in his driveway. At that time, he advised the officer taking the report that he believed that Mr. Bowen was the responsible party. Mr. Isaacs requested that no deputy respond because he had been previously advised by Sheriff s Office personnel that the Bowens only wanted attention. 14. On the morning of September 14, 2015, Mr. Isaacs drove to the Pickens County Sheriff s Office to speak with an officer about the above incident as well as the many other prior incidents that had occurred involving the Bowens dating back to Mid-2014 when the Bowens had moved in across the street from his residence. These prior incidents related to gunshots being fired into vehicles, into the side of his house and into the roof of his house. 15. While Mr. Isaacs was meeting with Deputy Jody Perry in the lobby of the Sheriff s Office, Defendant Brenda Bowen entered the lobby to report some issue unrelated to the Isaacs. 3

6 16. Upon information and belief, Deputy Perry advised Defendant Brenda Bowen of his investigation into the gunshots at Mr. Isaacs residence and further that Mr. Isaacs had alleged that Mr. Bowen had fired shots at the Isaacs residence. 17. According to reports, Defendant Brenda Bowen became upset at the accusation and after she started to get loud, Deputy Perry asked her to step outside to continue their conversation. 18. Once outside, Deputy Perry and Defendant Brenda Bowen were met by Mr. Bowen. 19. During that conversation, Deputy Perry asked Mr. Bowen if he was responsible for shooting at the Isaacs house. Mr. Bowen became angry at the accusation and even more angry when Deputy Perry requested that he take a polygraph. Upon information and belief, Mr. Bowen told Deputy Perry that he could speak to his lawyer. Mr. and Mrs. Bowen then left the Sheriff s Office and returned to their residence. 20. According to Mrs. Bowen s statement to investigators with the Sheriff s Office, Mr. Bowen was very upset when they left the Sheriff s Office. She stated that they argued on the way home and while at the house. Mrs. Bowen stated that after they arrived at their residence Mr. Bowen told her to call his sister, Kathy Ramsey, and meet her for the shopping trip they had previously planned. According to Mrs. Bowen, Mr. Bowen told her to take the dog with her and that he would stay at the house. Mr. Bowen stated that she then left the residence with the dog. 21. After speaking with the Bowens, Deputy Perry returned to the lobby of the Sheriff s Office to continue his conversation with Mr. Isaacs. 22. Ultimately, Deputy Perry followed Mr. Isaacs to his residence to continue his investigation. After arriving at the Isaacs residence, Deputy Perry realized that he had forgotten 4

7 to bring his computer and advised the Isaacs that he needed to return to the Sheriff s Office to retrieve it. 23. While Deputy Perry was at the Isaacs residence, Mr. Isaacs contacted the landlord of the Bowens residence, Ms. Hudson, to request that she come to his house and meet with him, Mrs. Isaacs and Deputy Perry. Ms. Hudson agreed but advised Mr. Isaacs that it would take her approximately minutes to respond. Upon information and belief, both Mr. Stewart and the Isaacs had contacted Ms. Hudson on numerous previous occasions to report the ongoing problems they were having with the Bowens. 24. After Deputy Perry left the Isaacs residence, Mr. Isaacs decided to take his daily walk while he awaited Deputy Perry s return and Ms. Hudson s arrival. 25. Several minutes after Mr. Isaacs left his residence, Mrs. Isaacs heard two gunshots. She called 911 to report the gunshots. 26. After hanging up with 911, and as Mrs. Isaacs was preparing to go check on Mr. Isaacs, she heard several more gunshots and called 911 a second time. 27. At approximately that same time, she looked out her window and witnessed Mr. Bowen walking through the woods towards his residence from the area of North Homestead Rd holding a shotgun. 28. Shortly thereafter, Deputy Perry, having been notified by Pickens County dispatch of the report of gunshots on Gilliland Dr., arrived back at the Isaacs residence. 29. According to Deputy Perry s report, as he was approaching the front door of the Isaacs residence, he saw Mr. Bowen approaching with his arms out in front of him. At that time, Mr. Bowen told Deputy Perry I shot him, I shot him. Deputy Perry asked Mr. Bowen where the person he shot was located to which Mr. Bowen responded it s no use. 5

8 30. After Deputy Perry took Mr. Bowen into custody, Mr. Bowen informed him that the gun he used was in his residence across the street and that the front door was open. Deputy Perry then walked Mr. Bowen over to his residence and partially closed the door before returning to his patrol vehicle. 31. In the meantime, Mrs. Isaacs went to the area of North Homestead Rd. where she had seen Mr. Bowens walking from with the shotgun. As she arrived on North Homestead Rd., she saw Mr. Isaacs lying on the ground with apparent gunshot wounds. She also saw Mr. Dickie Stewart lying on the ground several feet away with apparent gunshot wounds. After screaming for help, she was met at the scene by Deputy Perry and, ultimately, numerous other emergency personnel. 32. Upon information and belief, Mr. Stewart had heard the initial gunshots reported by Mrs. Isaacs and others and had driven to the area to investigate. The plaintiffs are informed and believe that when Mr. Stewart discovered Mr. Isaacs lying on the ground and attempted to render aid, he was also shot multiple times by Mr. Bowen. 33. Mr. Isaacs and Mr. Stewart were pronounced dead at the incident scene. 34. As a direct and proximate result of the defendants actions, Mr. Stewart suffered apprehension of imminent death, conscious pain and suffering prior to death, death and medical and funeral expenses. His estate would therefore have claims arising pursuant to South Carolina s Survival statute, SC Code Ann , for both actual damages and punitive damages. 35. As a direct and proximate cause of the defendants actions, Mr. Stewart s statutory beneficiaries suffered grief, shock, sorrow, wounded feelings and loss of financial support of Mr. Stewart. His statutory beneficiaries would therefore have claims arising pursuant 6

9 to South Carolina s Wrongful Death statute, SC Code Ann , for actual damages and punitive damages. FOR A FIRST CAUSE OF ACTION (Negligence against Defendant Albert Leon Bowen 36. The plaintiff repeats the allegations of the preceding paragraphs of her complaint as if fully repeated here verbatim. 37. As a citizen of the State of South Carolina, Mr. Bowen had a duty to the plaintiffs to maintain and use any weapon that he owned in a safe and proper manner and with due care. 38. Notwithstanding this duty, Mr. Bowen acted with negligence, gross negligence, carelessness and/or recklessness in breaching his duty to the plaintiffs in one or more of the following particulars: a. In handling and loading his firearm while in an elevated stage of anger; b. In possessing a firearm and ammunition in violation of 18 U.S.C. 922 (g(1 which prohibits a person from possessing firearms or ammunition after being convicted of a crime punishable by a prison term exceeding one year; c. In confronting Mr. Isaacs, without prior provocation, while brandishing his firearm; d. In discharging his firearm multiple times in the direction of Mr. Isaacs, striking Mr. Isaacs; e. In failing to render aid to Mr. Isaacs once it became apparent that he had shot Mr. Isaacs; 7

10 f. In leaving the area where Mr. Isaacs was shot and returning to his residence without calling or otherwise seeking assistance for Mr. Isaacs; and g. In such other ways as will become evident through discovery. 39. As a proximate result of Mr. Bowen s negligence, gross negligence, carelessness and/or recklessness, the plaintiff, Mr. Stewart and his statutory beneficiaries suffered the injuries set forth above. 40. The plaintiff is informed and believes that she is entitled to judgment, on behalf of the statutory beneficiaries pursuant to SC Code Ann and on behalf of the estate of her decedent pursuant to SC Code Ann , against this defendant for actual damages and punitive damages. FOR A SECOND CAUSE OF ACTION (Assault and Battery against Albert Leon Bowen 41. The plaintiff repeats the allegations of the preceding paragraphs of her complaint as if fully repeated here verbatim. 42. Mr. Bowen, by pointing a firearm at Mr. Stewart, committed an assault on Mr. Stewart by placing him in reasonable apprehension of immediate harmful or offensive touching. 43. Mr. Bowen s actions were intended to cause to cause this apprehension. 44. Further, by shooting Mr. Stewart multiple times, Mr. Bowen committed a battery on Mr. Stewart. 45. As a proximate result of Mr. Bowen s actions, the plaintiff, Mr. Stewart and his statutory beneficiaries suffered the injuries set forth above. 46. The plaintiff is informed and believes that she is entitled to judgment, on behalf of the statutory beneficiaries pursuant to SC Code Ann and on behalf of the estate of her 8

11 decedent pursuant to SC Code Ann , against this defendant for actual damages and punitive damages. FOR A THIRD CAUSE OF ACTION (Intentional Infliction of Emotional Distress against Albert Leon Bowen 47. The plaintiff repeats the allegations of the preceding paragraphs of the complaint as if fully repeated here verbatim. 48. Mr. Bowen intentionally or recklessly inflicted severe emotional distress on Mrs. Stewart, or was certain or substantially certain that such distress would result from his conduct. 49. Mr. Bowen s conduct was so extreme and outrageous as to exceed all possible bounds of decency and must be regarded as atrocious and utterly intolerable in a civilized community. 50. Mr. Bowen s actions caused Mrs. Stewart emotional distress. 51. The emotional distress suffered by Mrs. Stewart was so severe so that no reasonable person could be expected to endure it. 52. As a direct and proximate result of Mr. Bowen s actions, Mrs. Stewart, in her individual capacity suffered the following injuries and damages: a. Physical pain and discomfort; b. Severe emotional trauma; c. Severe mental anguish; d. Loss of enjoyment of life; and e. Loss of the services and companionship of her husband. 53. The plaintiff is therefore informed and believes that she is entitled to judgment against the Albert Leon Bowen for actual and punitive damages. 9

12 FOR A FOURTH CAUSE OF ACTION (Negligence against Defendant Brenda Bowen 54. The plaintiff repeats the allegations of the preceding paragraphs of her complaint as if fully repeated here verbatim. 55. Given Mrs. Bowen s knowledge of Mr. Bowen s elevated state of anger towards the Stewarts and her previous knowledge of Mr. Bowen s propensity for violence, including that against neighbors, Mrs. Bowen had a duty to the plaintiff and to Mr. Stewart to warn of Mr. Bowen s elevated state of anger and likely action against Mr. Stewart in retaliation for previous disputes involving the Stewarts. 56. Further, under the circumstances, Mrs. Bowen owed a duty to try to de-escalate Mr. Bowen s elevated state of anger in an attempt to calm him down before leaving Mr. Bowen alone at their residence in the presence of multiple firearms. 57. Additionally, Mrs. Bowen, given her previous knowledge of Mr. Bowen s propensity for violence, owed a duty not to incite Mr. Bowen further regarding the situation then existing related to Mr. and Mrs. Stewart. 58. Notwithstanding this duty, Mrs. Bowen acted with negligence, gross negligence, carelessness and/or recklessness in breaching her duty to the Isaacs in one or more of the following particulars: a. In failing to warn that Mr. Bowen intended to act violently; b. In failing to attempt to calm Mr. Bowen before leaving him alone at their residence in the presence of multiple firearms; c. In leaving Mr. Bowen at home in the possession of firearms in his agitated and angry state, especially knowing that Mr. Bowen was prohibited from possessing a firearm or ammunition pursuant to 18 U.S.C. 922(g(1; 10

13 d. In further inciting and agitating Mr. Bowen regarding the situation then existing; and e. In such other ways as will become evident through discovery. 59. As a proximate result of Mrs. Bowen s negligence, gross negligence, carelessness and/or recklessness, the plaintiff, Mr. Stewart and his statutory beneficiaries suffered the injuries set forth above. 60. The plaintiff is informed and believes that she is entitled to judgment, on behalf of the statutory beneficiaries pursuant to SC Code Ann and on behalf of the estate of her decedent pursuant to SC Code Ann , against this defendant for actual damages and punitive damages. FOR A FIFTH CAUSE OF ACTION (Conspiracy against Defendant Brenda Bowen and Albert Leon Bowen 61. The plaintiff repeats the allegations of the preceding paragraphs of her complaint as if fully repeated here verbatim. 62. Mr. and Mrs. Bowen were well aware that the Isaacs and Stewarts had made numerous complaints with the Pickens County Sheriff s Office regarding their conduct towards the Stewarts as well as other neighbors. 63. Mr. and Mrs. Bowen joined in a common plan and scheme to retaliate against the Stewarts for those complaints. 64. Specifically, Mr. and Mrs. Bowen developed a plan to antagonize, scare and harm the Stewarts to deter them from making further complaints to the authorities for any further acts of the Bowens. In furtherance of this plan, Mr. and Mrs. Bowen conspired to allow Mr. Bowen to possess firearms and ammunition knowing that such possession was in violation of 18 U.S.C. 11

14 922 (g(1 which prohibits a person for possessing firearms or ammunition after being convicted of a crime punishable by a prison term exceeding one year. 65. This common plan and scheme was furthered by the unlawful act of Mr. Bowen when he shot Mr. Isaacs and Mr. Stewart. 66. As a direct and proximate result of Mr. and Mrs. Bowen s conspiracy, the Stewarts suffered special damages. 67. The plaintiff, in both her individual capacity and as the Personal Representative of the Estate of Dickie Ray Stewart, is therefore informed and believes that she is entitled to judgment against Defendant Brenda Bowen and Albert Leon Bowen for actual and punitive damages. FOR A SIXTH CAUSE OF ACTION (Negligence against Defendant Hudson 68. The plaintiff repeats the allegations of the preceding paragraphs of her complaint as if fully repeated here verbatim. 69. Defendant Hudson owed a duty to the plaintiff to use due care in renting her residence to the Bowens. 70. Further, Defendant Hudson owed a duty to the plaintiff to respond to the numerous complaints made to her regarding the Bowens harassing, illegal and dangerous conduct. 71. Notwithstanding this duty, Ms. Hudson acted with negligence, gross negligence, carelessness and/or recklessness in breaching her duty to the Stewarts in one or more of the following particulars: a. In failing to conduct any investigation into the Bowens prior to renting to them; 12

15 b. In failing to obtain a formal background check and thereby to learn of Mr. Bowen s criminal history prior to renting to them; c. In failing to respond to numerous complaints from the Stewarts and other neighbors regarding the actions of the Bowens while residing on her property; d. In failing to reprimand either Mr. or Mrs. Bowen for their harassing, illegal and dangerous conduct while residing on her property; and e. In renewing the Bowens lease and/or in failing to evict them; and f. In such other ways as will become evident through discovery. 72. As a proximate result of Ms. Hudson s negligence, gross negligence, carelessness and/or recklessness, the plaintiff, Mr. Stewart and his statutory beneficiaries suffered the injuries set forth above. 73. The plaintiff is informed and believes that she is entitled to judgment, on behalf of Mr. Stewart s statutory beneficiaries pursuant to SC Code Ann and on behalf of the estate of her decedent pursuant to SC Code Ann , against this defendant for actual damages and punitive damages. FOR A SEVENTH CAUSE OF ACTION (South Carolina Tort Claims Act 74. The plaintiff repeats the allegations of the preceding paragraphs of her complaint as if fully repeated here verbatim. 75. To the extent that the employees of the Pickens County Sheriff s Office involved in the incident serving as the basis for this action acted as agents, servants and employees of the Pickens County Sheriff s Office, an agency of Pickens County, in turn a political subdivision of the state of South Carolina, and that the employees acted in the course and scope of their 13

16 employment, the Sheriff s Office and the County are vicariously liable for its employees tortious conduct, in one or more of the following particulars: a. In failing to investigate complaints made prior to September 14, 2015, against Albert Leon Bowen pursuant to their duties under state law and the policies and procedures of the Pickens County Sheriff s Office; b. In increasing the risk of danger to Mr. Isaacs by disclosing Mr. Isaacs complaints to Mr. Bowen without adequately securing him, when they knew or should have known that Mr. Bowen posed an imminent threat of harm to Mr. Isaacs, thereby placing other neighbors, including Mr. Stewart, at risk for imminent harm; c. In increasing the risk of danger to Mr. Isaacs by driving to his home, thereby inciting Mr. Bowen, and then leaving the residence, thereby exposing Mr. Isaacs, and other neighbors, including Mr. Stewart, to the risk of retaliation by Mr. Bowen; d. In failing to detain Mr. Bowen when he came to the Sheriff s Office before the incident in question; and, e. In such other ways as will become evident through discovery. 76. Consistent with the terms and conditions of the South Carolina Tort Claims Act, the plaintiff alleges that the negligent acts and omissions of the employees, as agents and servants of the Pickens County Sheriff s Office and Pickens County, as set forth above, were the proximate cause of Mr. Stewart s injuries and damages, also set forth above. 14

17 77. Further, the plaintiff alleges that the acts and omissions complained of would constitute violations of the South Carolina Tort Claims Act, S.C. Code, Ann., (2013, as amended. 78. As a proximate result of the defendant s negligence and carelessness, the plaintiff, Mr. Stewart and his statutory beneficiaries suffered the injuries set forth above. 79. The plaintiff is informed and believes that she is entitled to judgment, on behalf of the statutory beneficiaries pursuant to SC Code Ann and on behalf of the estate of her decedent pursuant to SC Code Ann , against this defendant for actual damages. FOR AN EIGHTH CAUSE OF ACTION (South Carolina Tort Claims Act 80. The plaintiff repeats the allegations of the preceding paragraphs of her complaint as if fully repeated here verbatim. 81. Notwithstanding any vicarious liability for its employees acts and omissions, the Pickens County Sheriff s Office and Pickens County, through other agents and servants, was negligent in additional particulars, and those negligent acts and omissions proximately caused the plaintiff s injuries and damages. 82. Some one or more of the following negligent acts and omissions by other agents, servants and employees of the Pickens County Sheriff s Office and Pickens County proximately caused the plaintiff s injuries and damages: a. The command and control employees of the Sheriff s Office and Pickens County failed to supervise patrol and investigative employees properly; b. The command and control employees of the Sheriff s Office and Pickens County failed to train patrol and investigative employees properly; 15

18 c. The command and control employees of the Sheriff s Office and Pickens County failed to screen patrol and investigative employees sufficiently when they were hired; d. The command and control employees of the Sheriff s Office and Pickens County failed to assess and monitor patrol and investigative employees performance and conduct; e. The command and control employees of the Sheriff s Office and Pickens County failed to enact or adopt policies and procedures that would have or should have prevented the injuries suffered by the plaintiff; f. The command and control employees of the Sheriff s Office and Pickens County failed to enforce such policies and procedures as would or should have prevented the injuries suffered by the plaintiff; g. The command and control employees of the Sheriff s Office and Pickens County failed in such other and further ways as will become evident through discovery. 83. As a proximate result of this defendant s negligence and carelessness, the plaintiff, Mr. Stewart and his statutory beneficiaries suffered the injuries set forth above. 84. The plaintiff is informed and believes that she is entitled to judgment, on behalf of the statutory beneficiaries pursuant to SC Code Ann and on behalf of the estate of her decedent pursuant to SC Code Ann , against this defendant for actual damages. 85. The plaintiff further alleges that the conduct of all the defendants combined and concurred to bring about the damages complained of, so that the defendants are jointly and severally liable for the damages suffered and alleged. 16

19 WHEREFORE, the plaintiff prays for the following relief: A. For actual damages; B. For punitive damages, where applicable; C. For the costs of this action; D. For prejudgment and postjudgment interest; and E. For such other and further relief as this Honorable Court deems just and proper. Greenville, South Carolina May 2, 2017 Respectfully Submitted: MOONEYHAM BERRY, LLC s/ Joe Mooneyham Joe Mooneyham, SC Bar # Todd Nichols, SC Bar # Post Office Box 8359 Greenville, South Carolina Fax joe@mbllc.com todd@mbllc.com Attorneys for Plaintiff 17

20 STATE OF SOUTH CAROLINA IN THE COURT OF COMMON PLEAS COUNTY OF PICKENS Civil Action Number: 2017-CP-39- Vickie Stewart, individually and as Personal Representative of the Estate of Dickie Ray Stewart Plaintiff, vs. JURY TRIAL DEMAND Albert Leon Bowen, deceased Brenda Bowen, Lisa Hudson, the Pickens County Sheriff s Office, an agency of Pickens County, and Pickens County, a political subdivision of the state of South Carolina, Defendants. Pursuant to Rule 38(b of the South Carolina Rules of Civil Procedure, the plaintiff, by her undersigned attorney, demands a jury trial on all issues set forth in this cause. Respectfully submitted, MOONEYHAM BERRY, LLC s/ Joe Mooneyham Joe Mooneyham, SC Bar # Todd Nichols, SC Bar # Post Office Box 8359 Greenville, South Carolina Fax joe@mbllc.com todd@mbllc.com Attorneys for Plaintiff Greenville, South Carolina May 2,