STATE OF SOUTH CAROLINA COUNTY OF FLORENCE HSBC Bank USA, NA, as indentured trustee for registered noteholders of Renaissance Home Equity Loan Trust 2007-1, PLAINTIFF, against Marceil E Williams and Patricia M Eaddy, and if Marceil E Williams and Patricia M Eaddy be deceased then all the children and legal heirs of the estates of Marceil E Williams and Patricia M Eaddy, distributors and legal legatees of the estates of Marceil E Williams and Patricia M Eaddy, and if any of them is deceased, all persons entitled to claim under or through them also all other unknown persons claiming any right, title, interest or lien in the real property described in the complaint herein; Any unknown adult, unknown infant, or disabled person of a class designated as John Doe, and any person in United States military service of a class designated as Richard Roe; Kay Frances Montgomery, DEFENDANT(S) AT THE COURT OF COMMON PLEAS CITATION AND NOTICE OF COMPLAINT FILING AND NOTICE OF INTERVENTION OF FORECLUSION AND CERTIFICATION OF COMPLIANCE WITH THE CORONAVIRUS ASSISTANCE AND ECONOMIC RECOVERY ACT ( WITHOUT MORTGAGE FORCLOSURE JURY) C/A NO: 2022-CP-21-00144 WAIVER TO THE DEFENDANTS, ABOVE NAMED: TO THE DEFENDANTS, ABOVE NAMED: YOU ARE HEREBY CALLED UP and required to respond to this Complaint, of which a copy is attached to you, or otherwise appear and defend and serve a copy of your response to said Complaint on Subscriber at its office, Hutchens Law Firm LLP, PO Box 8237, Columbia, SC 29202, within thirty ( 30) days after service hereof, except in the case of the United States of America, which shall have sixty (60) days, excluding the day of such service, and if you do not respond to the complaint within the aforementioned time limit, or if you appear and otherwise defend , the plaintiff in this action will apply to the court for the relief claimed therein, and default judgment will be entered against you for the relief sought in the complaint. YOU WILL ALSO BE ADVISED that if you fail to respond to the foregoing subpoena, Plaintiff will seek an order to dismiss this matter from the Master in Equity/Special Arbitrator for Florence County, which order shall, pursuant to Rule 53 of the South Carolina Civil Procedure Rules, specifically provide that said master in equity/special arbitrator is authorized and empowered to enter final judgment in this matter with appeal only to the South Carolina Court of Appeals pursuant to the SCACR Rule 203(d)(1), effective June 1, 1999. TO MINOR(S) OVER FOURTEEN, AND/OR MINOR(S) UNDER FOURTEEN AND THE PERSON WITH WHOM THE MINOR(S) RESIDE, AND/OR TO PERSONS UNDER A CERTAIN LEGAL DISABILITY: YOU ARE ALSO CONVENED AND NOTIFIED to request the appointment of a guardian ad litem within thirty (30 ) days following the service of this summons and notification ation. If you fail to do so, demand for such appointment shall be made by the applicant forthwith and separately and such demand shall be deemed absolute and complete absent your demand for such appointment within thirty (30) days of the service of the Summons and complaint against you. YOU SHALL ALSO BE ADVISED that if you fail to respond to the foregoing subpoena, the plaintiff will seek an order to dismiss this matter from the master in equity/special arbitrator in/for that county, which order shall, pursuant to rule 53 of the South Carolina Civil Procedure Rules, specifically provide that said master in equity/special arbitrator is authorized and empowered to enter final judgment in this matter 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 SUBMISSION AND COMPLAINT FILING TO THE ABOVE NAMED DEFENDANTS: YOU PLEASE NOTE that the foregoing subpoena, together with the Complaint, have been filed with the Clerk of Court for Florence County, South Carolina on January 24, 2022. NOTICE OF INTERVENTION OF FORECLUSION PLEASE NOTE, Pursuant to Administrative Order of the Supreme Court of South Carolina 2011-05-02 -01, you may be entitled to foreclosure intervention. To be considered for any available foreclosure intervention, you may contact and deal with the plaintiff through their law firm, Hutchens Law Firm LLP, PO Box 8237, Columbia, SC 29202 or call ( 803) 726-2700. Hutchens Law Firm LLP represents the plaintiff in this action and does not represent you. Under our ethics rules, we are prohibited from giving you legal advice. You must submit any request for foreclosure intervention review within 30 days of the date of this notice. IF YOU FAIL, REFUSE, OR WILLFULLY CHOOSE NOT TO PARTICIPATE IN FORECLUSION ACTION, YOUR MORTGAGE COMPANY/AGENT MAY PROCEED TO FORECLUSION ACTION. If you have already attempted to mitigate losses with the claimant, this advice does not guarantee the availability of loss mitigation options or further consideration of your qualifications. CORONAVIRUS AID, RELIEF, AND ECONOMIC SECURITY ACT COMPLIANCE CERTIFICATION of this page. I am able to do this certification. The facts stated in the certification are within my personal knowledge and are true and correct. 1. Verification Pursuant to Administrative Orders of the Supreme Court of South Carolina 2020-04-30-02 and 2020-05-06-01 and based on information provided by the Applicant and/or its Authorized Service Agent such as maintained in its case management/records database, the undersigned makes the following certifications: Applicant seeks to enter the following property commonly referred to as: 3500 East King Henry Drive, Florence, SC 29506 Address and Unit Number (if applicable ) City, State Zip Code I confirm that this property and more specifically the mortgage subject of this action: [X] is NOT a “Federally Guaranteed Mortgage Loan” as defined by § 4022(a)(2) of the Federal Coronavirus Aid, Relief, and Economic Security (“CARES”) Act . [ ] is a “Federally Guaranteed Mortgage Loan” as defined by § 4022(a)(2) of the Federal Coronavirus Aid, Relief, and Economic Security (“CARES”) Act. Specifically, the foreclosure moratorium cited in Section 4022(c)(2) of the CARES Act expired on May 18, 2020, and the property and mortgage are not currently subject to a forbearance plan such as defined only in Sections 4022(b) and (c) of the CARES Act. Please identify the database or other information you used to determine that the property does not have a Federally Backed Mortgage or Federally Backed Multifamily Mortgage: I hereby certify that I have reviewed the loan administration records and case management records/database of the applicant or their licensed mortgage agent, in digital or printed form, and that this mortgage loan is not currently under a plan of forbearance as defined only in sections 4022(b) and (c) of the CARES Act. Pursuant thereto, I certify that the facts set forth in this attestation are within my personal knowledge, except for matters based upon my information and beliefs as to said Loan Management Records and Case Management Records/Database of the applicant or mortgage manager, and these things I believe to be true. See, Rule 11(c), SCRCP; BB&T of South Carolina v. Fleming, 360 SC 341, 601 SE2d 540 (2004). 2. Declaration: I certify that the previous declarations made by me are true and accurate. I am aware that if any of the previous statements made by me are willfully false, I may be subject to contempt. NOTICE TO APPOINT COUNSEL FOR DEFENDANT(S) IN MILITARY SERVICE UNKNOWN OR KNOWN DEFENDANTS WHO MAY BE IN THE MILITARY SERVICE OF THE UNITED STATES OF AMERICA, ALL BEING A DESIGNATED CLASS AS RICHARD ROE: YOU ARE IN ADDITION SUMMONED AND NOTIFIED that the plaintiff’s lawyer has applied for the appointment of a lawyer to represent you. If you fail to request the appointment of counsel to represent you within thirty (30) days of service of this subpoena and notification, the plaintiff’s appointment shall be made absolute without further action by the 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 THIS PURPOSE, except as set forth below in the case of bankruptcy protection. IF YOU ARE UNDER THE PROTECTION OF THE BANKRUPTCY COURT OR HAVE BEEN RELEASED AS A RESULT OF BANKRUPTCY PROCEEDINGS, THIS NOTICE IS GIVEN TO YOU IN ACCORDANCE WITH STATUTORY REQUIREMENTS AND FOR INFORMATIONAL PURPOSES AND IS NOT INTENDED AS AN ATTEMPT TO COLLECT ANY DEBT OR AS AN ACT TO COLLECT, ASSESS OR RECOVER ALL OR ANY PART OF THE DEBT FROM YOU PERSONALLY.