STATE OF SOUTH CAROLINA
COUNTY OF LEXINGTON
IN THE FAMILY COURT
ELEVENTH JUDICIAL CIRCUIT
CASE NO. 2019-DR-32-1546
THOMAS M. WANNAMAKER,
Plaintiff,
-vs- SHEILA D. HARSEY,
Defendant.
SUMMONS
TO THE DEFENDANT ABOVE NAMED, SHEILA D. HARSEY:
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 his office at 306 Gamecock Avenue, Charleston, SC 29407, within thirty (30) days from the date of service hereof, exclusive of the day of such service.
YOU ARE HEREBY GIVEN NOTICE, further, that if you fail to Answer or appear and defend the Complaint as required by this Summons within thirty (30) days, judgment by default will be entered against you for the relief demanded in the Complaint.
COMPLAINT
The Plaintiff, Thomas M. Wannamaker, would show unto this Honorable Court as follows:
- The Plaintiff is a citizen and resident of the County of Richland, State of South Carolina, and has been such for a period of more than one year prior to the commencement of this action. The Defendant’s last known address is in Fairfield County, State of South Carolina. The parties last lived together as husband and wife in Lexington County.
- The parties (hereinafter “husband” and “wife”), are husband and wife, having been lawfully married on November 3, 2001.
- No children have been born of this marriage and none are expected.
- The parties separated on August 30, 2002 and have lived separate and apart since that date.
- This Court has subject matter and personal jurisdiction in this case, and venue is proper in this county.
- The parties’ marriage is irretrievably broken. Upon information and belief, Plaintiff Thomas M. Wannamaker is entitled to a divorce a vinculo matrimonii of and from the Defendant on the statutory ground of one year’s continuous separation without resumption of cohabitation.
- Upon information and belief, neither party is entitled to spousal support and/or alimony of any kind, one from the other, and this Court should issue its Order denying such relief to both parties, temporarily and permanently.
- There is no marital property that should be equitably divided between the parties. Each of the parties should be granted the use and possession of all items of property currently found in his or her possession, and be solely responsible for any debts in his or her own name, temporarily and permanently.
- The Plaintiff prays for such other and further relief as this Court may deem necessary in the administration of justice, temporarily and permanently.
WHEREFORE, having fully set forth his Complaint herein, Plaintiff Thomas M. Wannamaker prays for the Order of this Court as follows:
A. Granting him a divorce a vinculo matrimonii of and from the Defendant on the statutory ground of one year’s continuous separation without resumption of cohabitation; and
B. Denying each of the parties spousal support and/or alimony of any kind, one from the other, temporarily and permanently; and
C. Granting each of the use and possession of all items of property currently found in his or her possession, and requiring each to be solely responsible for any debts in his or her own name, temporarily and permanently; and
D. For such other and further relief as this Court shall deem necessary and appropriate.
NOTICE OF FINAL HEARING
YOU WILL PLEASE TAKE NOTICE that the above-referenced matter has been scheduled for a final hearing on the 12th day of December, 2019, at 2:30 PM, at the Lexington County Family Court (205 E. Mail St., #146, Lexington, SC 29072).
J. Michael DeTreville
SC Bar # 73693
DETREVILLE LAW & MEDIATION, LLC
Attorney for Plaintiff
306 Gamecock Avenue
Charleston, South Carolina 29407
Telephone: 843-571-0537
Facsimile: 843-556-7147
[email protected]
Charleston, South Carolina
July 15, 2019
11/27/19, 12/05/19, 12/12/19
