STATE OF SOUTH CAROLINA	)
)	IN THE MAGISTRATES COURT
COUNTY OF	)

)
)
)
PETITIONER(S)	)
VS.	)
PETITION AND MOTION
)
FOR ACCESS TO CEMETERY, BURIAL GROUND, OR GRAVE
)	(for use by Landowner)
)
)
RESPONDENT(S)	)
CIVIL CASE NUMBER

The Petitioner alleges:

1.	Petitioner owns or occupies real property located at , which is in County.

2.	The Petitioner is informed and believes that said property contains a cemetery, burial ground or grave.
3.	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.

4.	Petitioner responded to Respondent’s request in writing by proposing the following schedule of access: (a copy of which is attached)

5.

6.	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.

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 .

7.	Petitioner requests the following additional relief from this Court:

SWORN to and Subscribed before me	)
)
This day of , 20 .	)
)
)
Notary Public for South Carolina	)	Signature of Petitioner or Person Filing

On Be on Behalf of Petitioner
My Commission expires:	)

SCCA/682	10/2007

STATE OF SOUTH CAROLINA

traines

2008-03-06

Winkie Clark

SC Judicial Dept.