Petition And Motion For Access To Cemetery Burial Ground (Use By Landowner) {SCCA-682}

STATE OF SOUTH CAROLINA COUNTY OF ) ) ) ) ) ) ) ) ) IN THE MAGISTRATES COURT PETITIONER(S) VS. ) ) ) RESPONDENT(S) ) The Petitioner alleges: 1. PETITION AND MOTION FOR ACCESS TO CEMETERY, BURIAL GROUND, OR GRAVE (for use by Landowner) CIVIL CASE NUMBER Petitioner owns or occupies real property located at _______________________________, which is in ______________ County. The Petitioner is informed and believes that said property contains a cemetery, burial ground or grave. On ______________ ____, 20_____, Respondent made a written request to Petitioner (a copy of which is attached hereto) for reasonable access for the purpose of: visiting a grave(s) maintaining the gravesite or cemetery lawfully burying a deceased person in a cemetery or burial plot by those granted rights of burial to that plot conducting genealogy research. Petitioner responded to Respondent's request in writing by proposing the following schedule of access: _________________________________________________________________ __________________________________________________________________________ ___________________________________________________(a copy of which is attached) 2. 3. 4. 5. Respondent has failed to agree to Petitioner's proposed terms of access and as a result, Petitioner and Respondent are unable to resolve this matter without the intervention of the court. 6. Therefore, Petitioner requests that this Court issue injunctive relief pursuant to § 27-43-310 (C) (5) of the South Carolina Code of Laws, allowing Respondent access to the above stated premises subject to the following conditions ______________________________________ ___________________________________________________________________________. SCCA/682 10/2007 American LegalNet, Inc. www.FormsWorkFlow.com 7. Petitioner requests the following additional relief from this Court: ______________________ ___________________________________________________________________________ ___________________________________________________________________________ ) ) This ____ day of _______________, 20______. ) ) ) Notary Public for South Carolina ) Signature of Petitioner or Person Filing My Commission expires: ________________ ) e on Behalf of Petitioner SWORN to and Subscribed before me SCCA/682 10/2007 American LegalNet, Inc. www.FormsWorkFlow.com