ELECTRONICALLY FILED - 2021 Dec 22 11:18 AM - HORRY - COMMON PLEAS - CASE#2021CP2608174

STATE OF SOUTH CAROLINA IN THE COURT OF COMMON PLEAS

THE FIFTEENTH JUDICIAL CIRCUIT
HORRY COUNTY CASE NO.: 2021-CP-26-

State of South Carolina on the relation of

Jimmy A. Richardson, II, Solicitor of the
Fifteenth Judicial Circuit,

PETITIONER, SUMMONS
vs.

Shammond Jackson, Veronica Jackson,

Marlina Jackson, and Robert Jackson,

RESPONDENTS.

TO THE RESPONDENTS ABOVE-NAMED:

YOU ARE HEREBY SUMMONED and required to answer the Petition in this action, a
copy of which is herewith served upon you, and to serve a copy of your Answer to said Petition
on the subscribers at their offices at Post Office Box 530, Conway, South Carolina 29528-0530,
within thirty (30) days after the service hereof, exclusive of the day of such service; and if you
fail to answer the Petition, or to otherwise responsively plead to the Petition, or to otherwise
appear and defend, within the time aforesaid, the Petitioner in this action will apply to the Court
for judgment by default against you, for the relief demanded in the Petition.

s/James R. Battle
SC Bar #73604
Special Prosecutor for the 15th Judicial Circuit
Battle Law Firm, LLC
P.O. Box 530
Conway, South Carolina 29528
P: 843-248-4321
jbattle@battlelawsc.com
December 21, 2021

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 ELECTRONICALLY FILED - 2021 Dec 22 11:18 AM - HORRY - COMMON PLEAS - CASE#2021CP2608174
STATE OF SOUTH CAROLINA IN THE COURT OF COMMON PLEAS
THE FIFTEENTH JUDICIAL CIRCUIT
HORRY COUNTY CASE NO.: 2021-CP-26-

State of South Carolina on the relation of

Jimmy A. Richardson, II, Solicitor of the
Fifteenth Judicial Circuit,

PETITIONER, PETITIONER’S VERIFIED PETITION

vs.

Shammond Jackson, Veronica Jackson,

Marlina Jackson, and Robert Jackson,

RESPONDENTS.

Petitioner respectfully alleges:

1. Petitioner is the duly elected Solicitor of the Fifteenth Judicial Circuit of the State of

South Carolina.

2. Petitioner brings this action in the name of the State of South Carolina, pursuant to South

Carolina Code §§ 15-43-10 through 130.

3. This action is brought and prosecuted for the purpose of temporarily and permanently

enjoining and abating a certain public and common nuisance, as defined by S.C. Code §§ 15-43-

10 through 130, existing as a nightclub called Turk’s Place located at 4337 Redenbo Dr., Loris,

South Carolina in Horry County (hereinafter “Turk’s Place”).

4. Turk’s Place is a makeshift club located in a small wooden structure at the end of a rural

dirt road known as Redenbo Dr. Surrounding Turk’s Place are several trailers where the

Respondents live. Turk’s Place does not maintain normal working hours and does not have a

business license. Instead, it is periodically opened by its owner, Shammond Jackson a.k.a. Turk.

When open, it operates as a nightclub with doormen, bartenders, and DJ’s.

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5. Respondents live on the same property as Turk’s Place and control the activity on the

property. There has not been a filed deed for this property since 1923.

7. Petitioner personally served written notice of the public nuisance on Respondents on

December 3, 2021.

8. More than ten days has elapsed since the service of the notice of public nuisance and to

date the nuisance remains unabated.

9. Petitioner is informed and believes that Turk’s Place has been used for a continuous

breach of the peace, to wit:

On November 27, 2021 at 2:50am, Colloyd Jackson and Tyson Pressley were shot
inside Turk’s Place. Jackson and Pressley were transported to the hospital by
individuals at the Club, and Jackson later died from his wounds. Horry County
Police Department (“HCPD”) learned about the shooting when Jackson and
Pressley arrived at the hospital, and no one from Turk’s Place called police. Once
police arrived at Turk’s Place, people leaving the Club told them they did not see
anything. Once inside the Club, officers found Timothy Bellamy sweeping up
shell casings and bloody items. Officers told Mr. Bellamy to stop and cleared the
scene for its investigation.

This was not the first murder at Turk’s Place. On June 23, 2020 at 4:15am,
Heiden Goodman was shot at Turk’s Place and found lying face down in the
middle of Redenbo Dr. Prior to this date, on December 25, 2019 at 3:15am,
Heiden Goodman and Destiny McKoy were shot at Turk’s Place after a fight
broke out.

The third murder occurred on December 20, 2017 at 3:37am, when Bryan Marlow
was shot at Turk’s Place and found deceased in the middle of Redenbo Dr.

Beyond these murders, every year there are innumerable calls to the police
regarding loud noise and shots fired at Turk’s Place.

10. The above-mentioned acts and conduct which occur on the premises are offensive to

public decency, morals, peace, and health, and constitute a public nuisance which is subject to

abatement under S.C. Code Ann. §§ 15-43-10 through 130 and should be forthwith enjoined and

abated.

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11. Petitioner is further informed and believes that the furniture, personal property, and other

fixtures located on said premises are owned by the Respondents and are used for the purpose of

furthering the public nuisance.

12. Petitioner is informed and believes it is entitled to a temporary injunction closing Turk’s

Place until such time that the matter can be heard on its merits.

13. Petitioner is informed and believes it is entitled to an injunction closing Turk’s Place for

a period of one year pursuant to S.C. Code Ann. §§ 15-43-10 through 130.

14. Petitioner is informed and believes it is entitled to a judgment for its costs incurred in

abating the public nuisance of Turk’s Place.

15. Petitioner is informed and believes that unless Respondents are enjoined by the court,

Turk’s Place will continue to operate as a public nuisance to the harm and detriment of Horry

County.

Wherefore, Petitioner requests:

a. All of the above-named Respondents and their agents, servants, subordinates, and

employees, and each and every one of them, be enjoined and restrained from using, maintaining,

and assisting in the using and maintaining of Turk’s Place, as a place where the above alleged

conduct, acts and public nuisance are carried on in violation of S.C. Code Ann. §§ 15-43-10

through 130.

b. This court shall by order direct and command the Horry County Police Department to

summarily abate the public and common nuisance now existing on the premises and for that

purpose to take possession of the premises and to close the same and take possession of all the

furniture, equipment, fixtures and other property now used on the premises in connection with

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the violation alleged above as constituting a nuisance and to remove the same and all of the same

to a place of safekeeping to await further order of this court;

c. This court shall forthwith issue a temporary injunction, pursuant to S.C. Code Ann. § 15-

43-30, restraining Respondents from conducting or permitting the continuance of the nuisance

and shall order that the building and premises be closed until the conclusion of the trial of this

case; and that such temporary injunction restrain Respondents, and their agents, servants,

subordinates, and employees and all persons, from removing or in any way interfering with the

furniture, equipment fixtures and other property used in connection with the violation of the

statute;

d. This court shall enter a decree perpetually restraining Respondents and their agents,

servants, subordinates, employees and each and every one of them, from maintaining or

permitting the nuisance and from using the premises or buildings in which the same is

maintained for any purpose for a period of one year, and perpetually restraining Respondents and

their agents, servants, subordinates, and employees, from maintaining any such nuisance within

the State of South Carolina;

e. This court shall enter an order of abatement as part of this decree, which order shall direct

the Chief of Police for the Horry County Police Department to remove from the building or

premises all fixtures and movable property used in conducting or aiding or abetting the nuisance,

and to sell the same in the manner provided by law for the sale of personal property, and to close

the building or premises or such place against its use for the purpose and to keep it closed for a

period of one year;

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f. This court shall order and direct that service of any orders in this matter, temporary or

perpetual, on the employees and affiliates of Respondents be accomplished by posting a copy of

the order in plain view on the main front door entrance of Turk’s Place;

g. This court shall order the Respondents to pay the costs incurred by the Petitioner in

abating the public nuisance;

h. For such other relief as to this court may deem just and proper.

s/James R. Battle
SC Bar #73604
Special Prosecutor for the 15th Judicial Circuit
Battle Law Firm, LLC
P.O. Box 530
Conway, South Carolina 29528
P: 843-248-4321
jbattle@battlelawsc.com
December 21, 2021