ELECTRONICALLY FILED - 2025 Mar 20 10:51 AM - RICHLAND - COMMON PLEAS - CASE#2025CP4001807
STATE OF SOUTH CAROLINA IN THE COURT OF COMMON PLEAS
COUNTY OF RICHLAND DOCKET NO.
PennyMac Loan Services, LLC,
Plaintiff, SUMMONS
(NON-JURY)
FORECLOSURE OF REAL ESTATE
MORTGAGE
Deficiency Judgment Waived
v.
Monique Greene Tunstall ; Any Heirs-at-Law or
Devisees of William Lee Greene, Deceased, their
heirs, Personal Representatives, Administrators,
Successors and Assigns, and all other persons
entitled to claim through them; all unknown
persons with any right, title or interest in the real
estate described herein; also any persons who may
be in the military service of the United States of
America, being a class designated as John Doe;
and any unknown minors or persons under a
disability being a class designated as Richard Roe;
Joe Beall; Erin Beall; The Meadows Summer
Pines Homeowners Association, Inc. ;
Defendant(s).
(016487-01662)
TO THE DEFENDANT(S) ABOVE NAMED:
YOU ARE HEREBY SUMMONED and required to appear and defend by answering the
Complaint in this action, of which a copy is herewith served upon you, and to serve a copy of your
Answer on the subscribers at their offices, 1221 Main Street, Post Office Box 100200, Columbia, South
Carolina 29202, within thirty (30) days after the service hereof, exclusive of the day of such service,
except that the United States of America, if named, shall have sixty (60) days to answer after the service
hereof, exclusive of the day of such service; and if you fail to do so, judgment by default will be rendered
against you for the relief demanded in the Complaint.
ELECTRONICALLY FILED - 2025 Mar 20 10:51 AM - RICHLAND - COMMON PLEAS - CASE#2025CP4001807
YOU WILL ALSO TAKE NOTICE that Plaintiff will move for an order of reference or
that the Court may issue a general order of reference of this action to a master in equity/special referee,
pursuant to Rule 53, of the South Carolina Rules of Civil Procedure.
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 PennyMac Loan Services, LLC.
/s/Jeriel A. Thomas
Rogers Townsend, LLC
ATTORNEYS FOR PLAINTIFF
John J. Hearn (SC Bar # 6635), [Link]@[Link]
Brian P. Yoho (SC Bar #73516), [Link]@[Link]
Jeriel A. Thomas (SC Bar #101400) [Link]@[Link]
R. Brooks Wright SC Bar #105195) [Link]@[Link]
1221 Main Street, 14th Floor Post Office Box 100200 (29202)
Columbia, SC 29201 (803) 744-4444
Columbia, South Carolina
ELECTRONICALLY FILED - 2025 Mar 20 10:51 AM - RICHLAND - COMMON PLEAS - CASE#2025CP4001807
STATE OF SOUTH CAROLINA IN THE COURT OF COMMON PLEAS
COUNTY OF RICHLAND DOCKET NO.
PennyMac Loan Services, LLC,
Plaintiff, COMPLAINT
(NON-JURY)
FORECLOSURE OF REAL ESTATE
MORTGAGE
Deficiency Judgment Waived
v.
Monique Greene Tunstall ; Any Heirs-at-Law or
Devisees of William Lee Greene, Deceased, their
heirs, Personal Representatives, Administrators,
Successors and Assigns, and all other persons
entitled to claim through them; all unknown
persons with any right, title or interest in the real
estate described herein; also any persons who may
be in the military service of the United States of
America, being a class designated as John Doe;
and any unknown minors or persons under a
disability being a class designated as Richard Roe;
Joe Beall; Erin Beall; The Meadows Summer
Pines Homeowners Association, Inc. ;
Defendant(s).
(016487-01662)
Plaintiff alleges:
1. This is an action for the foreclosure of a mortgage upon certain real estate in
Richland County, South Carolina.
2. Pursuant to S.C. Code Section 33-15-101(b)(8) Plaintiff is a corporation or other
legal entity collecting debts and / or enforcing mortgages, security interests or other rights in property
securing debts.
3. Plaintiff has the legal right to enforce the negotiable instrument secured by the
Mortgage and is the real party in interest as defined by Rule 17(a) of the South Carolina Rules of Civil
Procedure.
ELECTRONICALLY FILED - 2025 Mar 20 10:51 AM - RICHLAND - COMMON PLEAS - CASE#2025CP4001807
4. Some lien on or interest in the real estate, the subject of this action, may be claimed
by the Defendant(s) herein.
5. The Defendant(s) herein described as judgment creditors have by filing said
judgments designated their attorney entering the judgment as their agent for service of process under the
provisions of South Carolina Code Section 15-35-840.
6. Heretofore, on or about February 27, 2018, William Lee Greene made, executed and
delivered a certain Fixed Rate Note ("Note") in the principal sum of $182,450.00, payable in monthly
installments.
7. In order to secure the payment of the Note according to the terms and conditions
thereof, William Lee Greene made, executed and delivered unto Mortgage Electronic Registration
Systems, Inc., as mortgagee, as nominee for Ameris Bank, its successors and assigns a certain real estate
mortgage ("Mortgage") covering the following described property and any and all improvements to the
property, including but not limited to a mobile/manufactured home:
All that certain piece, parcel, or lot of land, together with improvements thereon, situate, lying and being
in the County of Richland, State of South Carolina, being shown and designated as Lot 151 on a plat of
The Meadows at Summer Pines-Phase V dated October 20, 2015, and recorded on January 14, 2016 in the
Office of the Register of Deeds for Richland County in Record Book 2082 at Page 288. Being more
particularly shown and delineated on a plat prepared for William L. Greene by Belter & Associates, Inc.
dated February 21, 2018, to be recorded simultaneously herewith. Reference is made to said latter plat for
a more complete and accurate description. Be all measurements a little more or less.
This being the same property conveyed to William Lee Greene by deed of Essex Homes Southeast, Inc.,
dated February 27, 2018 and recorded March 1, 2018 in Deed Book R2283 at Page 1721 in the Register
of Deeds Office for Richland County. Subsequently, William Lee Greene died November 8, 2024, leaving
the subject property to his heirs or devisees, namely, Monique Greene Tunstall.
Property Address: 1068 Heart Pine Dr
Blythewood, SC 29016
TMS/PIN# R14814-05-02
8. The Mortgage was signed, witnessed and probated February 27, 2018; thereafter the
Mortgage was recorded in the Office of the RMC/ROD for Richland County on March 1, 2018, in
Mortgage Book R2283 at Page 1725. This mortgage was assigned to PennyMac Loan Services, LLC by
assignment dated December 27, 2024 and recorded December 27, 2024 in Book R2983 at Page 540.
9. The Mortgage evidences and secures the repayment of money advanced by Plaintiff
or its predecessor in interest to, or on behalf of, the mortgagor(s) and constitutes a purchase money first
lien on the mortgaged premises.
ELECTRONICALLY FILED - 2025 Mar 20 10:51 AM - RICHLAND - COMMON PLEAS - CASE#2025CP4001807
10. Subsequently, William Lee Greene died November 8, 2024, leaving the subject
property to his heirs or devisees, namely, Monique Greene Tunstall.
11. After all payments received by the Plaintiff have been credited to the subject loan, the
loan is in default and due for September 1, 2024, and the conditions of the Note and Mortgage have been
broken. Plaintiff elects to and does declare the entire balance of said indebtedness due and payable, and
that there is due on the Note and Mortgage as of September 1, 2024, the principal sum of $155,191.83,
with interest from August 1, 2024, advances, late charges, and also for the costs and disbursements of this
action, including attorney's fees.
12. Plaintiff's right to a personal or deficiency judgment pursuant to South Carolina Code
Sections 29-3-650 and 29-3-660 is expressly waived.
13. Pursuant to the terms of the Mortgage, Plaintiff has employed counsel to prosecute
this action and a reasonable value of services of counsel in this action is the sum as the Court may find
appropriate.
14. Plaintiff may be forced to pay sums for taxes and insurance and costs for securing the
property, which sums, according to the terms of the Mortgage, should be added to the amount of the debt.
15. Pursuant to the terms of the Mortgage and applicable state law, Plaintiff requests the
mortgage be foreclosed and that the property be sold at public auction in accordance with law, subject to
any liens for taxes, special assessments of record against such property, and existing easements or
restrictions of record.
16. The hereinafter named Defendant(s) may have some interest in or lien upon the
premises covered by the Mortgage set forth above, or some part thereof, but that such interests or liens are
junior and subsequent to the lien of Plaintiff's Mortgage or, if specified below, have been paid in full and
either should be satisfied of record or the lien released from the subject real estate. Said liens or interests
are of record in the Office of the RMC or Clerk of Court of the aforesaid county and are described as
follows:
A. Monique Greene Tunstall and any unknown heirs or devisees of the Estate of
William Lee Greene, including any persons who may be in the military service of the United States of
America, being a class designated as John Doe, and any unknown minors or persons under a disability
being a class designated as Richard Roe, by virtue of any interest claimed under the law of intestate
succession (S.C. Code Section 62-2-109) or under decedent's will
B. Erin Beall and Joe Beall, by virtue of an installment land sale contract given
by William Lee Greene dated, March 12, 2020 and recorded October 23, 2020 in Book 2542 at Page
1671.
ELECTRONICALLY FILED - 2025 Mar 20 10:51 AM - RICHLAND - COMMON PLEAS - CASE#2025CP4001807
C. The Meadows Summer Pines Homeowners Association, Inc. by virtue of any
lien enforceable assessments claimed as provided for in the Declaration of Covenants, Conditions, and
Restrictions recorded herein, and any amendments thereto. Also including any other liens they may have.
WHEREFORE, having fully set forth its Complaint, Plaintiff prays that this Honorable
Court inquire into the matters as set forth herein and:
(1) Under the direction of this Court, ascertain and determine the amount
due upon the Note and Mortgage held by Plaintiff together with attorney's fees and costs of this action.
(2) Declare Plaintiff's Mortgage a purchase money first lien and render
judgment of foreclosure for the amount so found to be due and owing thereon, together with any ad
valorem taxes, or insurance premiums, and any other expenses which may be due and have been
advanced by Plaintiff, with reasonable attorney's fees, and for the costs of this action.
(3) Order the reimbursement of all costs for inspecting and securing the
property incurred by the Plaintiff as a result of the delinquency.
(4) Appoint a Receiver to collect the rents, issues, profits or designated
sums from the mortgagor(s), and/or the grantee(s) of the mortgagor(s), and/or tenant(s) occupying or
exercising control over the mortgaged premises and hold the same subject to the further order of this
Court.
(5) Under the direction of this Court, sell the mortgaged premises, bar
any equity of redemption, and apply the proceeds of sale as follows:
First, to the costs and expenses of the within action and sale;
Second, to the payment and discharge of the amount due on Plaintiff's
Note and Mortgage, together with attorney's fees as aforesaid; and
Third, to the distribution of any surplus pursuant to Rule 71, of the South
Carolina Rules of Civil Procedure;
(6) Issue an order directing the Sheriff of Richland County, South
Carolina, to place the successful purchaser at said foreclosure sale in possession of the property should
the same become necessary;
ELECTRONICALLY FILED - 2025 Mar 20 10:51 AM - RICHLAND - COMMON PLEAS - CASE#2025CP4001807
(7) Order such other and further relief as may be just and proper.
/s/Jeriel A. Thomas
Rogers Townsend, LLC
ATTORNEYS FOR PLAINTIFF
John J. Hearn (SC Bar # 6635), [Link]@[Link]
Brian P. Yoho (SC Bar #73516), [Link]@[Link]
Jeriel A. Thomas (SC Bar #101400) [Link]@[Link]
R. Brooks Wright SC Bar #105195) [Link]@[Link]
1221 Main Street, 14th Floor Post Office Box 100200 (29202)
Columbia, SC 29201 (803) 744-4444
Columbia, South Carolina
