On January 06, 2023 a
Motion,Ex Parte
was filed
involving a dispute between
Welch, Edward O,
and
Detar, Stephen D,
for Common Pleas
in the District Court of Hampton County.
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ELECTRONICALLY FILED - 2023 Apr 25 9:59 AM - HAMPTON - COMMON PLEAS - CASE#2023CP2500008
STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS
) FOURTEENTH JUDICIAL CIRCUIT
COUNTY OF HAMPTON )
) CIVIL ACTION NO.: 2023-CP-25-00008
)
Edward O. Welch, )
Plaintiff, )
)
vs. ) PLAINTIFF’S MOTION TO COMPEL
)
Stephen D. Detar, )
Defendant. )
)
To: Robert E. Kneece, III, Esquire, Attorney for the Defendant, Stephen D. Detar:
PLEASE TAKE NOTICE that the undersigned as attorney for the plaintiff(s), Edward O.
Welch, by and through their undersigned counsel will move before the court at a time and date set by
the court for an order compelling the defendant, Stephen D. Detar, to Answer Plaintiff’s First Set of
Interrogatories and respond to Plaintiff’s First Set of Requests for Production dated February 28, 2023
(Exhibits A & B) completely and without objection.
The undersigned attorney for the plaintiff hereby certifies that he has consulted with opposing
counsel prior to filing this motion to no avail. (Exhibit C).
BARNES LAW FIRM, LLC
_/s/William F. Barnes, III_____________
William F. Barnes, III, SC Bar #78220
13 Mulberry Street East
P.O. Box 897
Hampton, SC 29924
Phone: (803) 943-4529
wbarnes@barneslawfirmsc.com
ATTORNEY FOR THE PLAINTIFF
April 25, 2023
Hampton, South Carolina
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ELECTRONICALLY FILED - 2023 Apr 25 9:59 AM - HAMPTON - COMMON PLEAS - CASE#2023CP2500008 STATE OF SOUTH CAROLINA ) IN THE COURT OF COMMON PLEAS ) FOURTEENTH JUDICIAL CIRCUIT COUNTY OF HAMPTON ) ) CIVIL ACTION NO.: 2023-CP-25-00008 ) Edward O. Welch, ) Plaintiff, ) ) vs. ) PLAINTIFF’S MOTION TO COMPEL ) Stephen D. Detar, ) Defendant. ) ) To: Robert E. Kneece, III, Esquire, Attorney for the Defendant, Stephen D. Detar: PLEASE TAKE NOTICE that the undersigned as attorney for the plaintiff(s), Edward O. Welch, by and through their undersigned counsel will move before the court at a time and date set by the court for an order compelling the defendant, Stephen D. Detar, to Answer Plaintiff’s First Set of Interrogatories and respond to Plaintiff’s First Set of Requests for Production dated February 28, 2023 (Exhibits A & B) completely and without objection. The undersigned attorney for the plaintiff hereby certifies that he has consulted with opposing counsel prior to filing this motion to no avail. (Exhibit C). BARNES LAW FIRM, LLC _/s/William F. Barnes, III_____________ William F. Barnes, III, SC Bar #78220 13 Mulberry Street East P.O. Box 897 Hampton, SC 29924 Phone: (803) 943-4529 wbarnes@barneslawfirmsc.com ATTORNEY FOR THE PLAINTIFF April 25, 2023 Hampton, South Carolina