Petition And Motion For Access To Cememtry Burial Ground Or Grave

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STATE OF SOUTH CAROLINA
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IN THE MAGISTRATES COURT
COUNTY OF
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PETITIONER(S)
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VS.
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PETITION AND MOTION
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FOR ACCESS TO CEMETERY,
BURIAL GROUND, OR GRAVE
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RESPONDENT(S) )
CIVIL CASE NUMBER
The Petitioner alleges:
1.
The Respondent owns or occupies real property located at ___________________________
__________________, which is in ____________________ County.
2.
The Petitioner is informed and believes that he should be allowed reasonable ingress and
egress to the above-referenced property as it contains a cemetery, burial gound or grave and
Petitioner is one of the following:
a family member or descendant of a deceased person buried on the private property; or
a cemetery plot owner; or
a person lawfully participating in a burial; or
a person engaging in genealogy research who has received lawful written permission to
conduct said research pursuant to SC Code Section 27-43-310(A)(4)(a)(b).
3.
On _________________, 20_____, Petitioner made a written request to ________________
____________ (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.
4.
Thirty (30) days have passed and the Respondent has failed to respond with a written
proposal to allow such access. Petitioner alleges that the defendant has unreasonably denied
Petitioner reasonable access to the cemetery, burial ground, or grave, and that this action
requesting injunctive relief is therefore proper and necessary.
5. Therefore, Petitioner requests that this Court issue injunctive relief pursuant to § 27-43-310
(C)(4) & (5) of the South Carolina Code of Laws, allowing Petitioner access to the above stated
SCCA/680
10/2007

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